A contract specialist sits down on a Tuesday to release a solicitation. The contract writing system prompts her for a provision. She knows her agency’s class deviation removed it weeks ago. The system does not. The FAR she trained on, the deviation she is working under, and the proposed rule she read about last month each treat the same question a little differently.

She has to release today. So she makes a call, a reasonable one, defensible on its merits, made in about ninety seconds. She does not write down why.

Eighteen months later, someone may ask her to explain it. That gap, between what changed on paper and what changed in practice, is where much of the next two years of acquisition risk is likely to sit.

Which authority governs your acquisition today: FAR, class deviations, and proposed rules

Four categories of material are circulating right now, and only two of them carry regulatory force.

The codified FAR (48 CFR). Still in force. No Revolutionary FAR Overhaul (RFO) final rule has been published in the Federal Register as of mid-July 2026, and none carries an effective date. The codified FAR remains the baseline except where an agency deviation displaces it.

Agency class deviations. What actually governs your file. Executive Order 14275, signed April 15, 2025, directed the overhaul; OMB implemented it in two phases. Phase one produced model deviation text, published on acquisition.gov, which agencies adopted through their own class deviations: GSA’s RFO-2025-09 for Part 9, effective November 3, 2025; DHS Class Deviation 25-06 for Part 10, issued June 12, 2025; and many others, each adopting the model text verbatim or with local modification, each with its own effective date.

Proposed rules, preparatory, not operative. On June 23, 2026, the FAR Council published four proposed rules covering Parts 1–7, 10, 18, 24, 26, 29, 33, 37, 39, 40, 41, 49, 52, and 53. Twelve proposed rules will issue in total across three batches. Comments on the first four closed July 23, 2026; two associated Paperwork Reduction Act notices carry a separate deadline of August 24, 2026. These texts inform planning. They do not yet govern awards.

The FAR Companion and Practitioner Albums, informational only. Useful, non-regulatory, and explicit about it.

The two regimes do not always align. Under the proposed rules, Part 10 is marked reserved and its market research content relocates to Subpart 7.2. Under the deviations governing files today, Part 10 still stands on its own. A contracting officer drafting to proposed text is drafting to language that has not taken effect.

Determining what applies has a sequence worth making routine: FAR 1.107(d)(2) on how changes apply to solicitations; then your agency’s class deviation for that part, including whether it adopted model text verbatim or modified it; then whether a later deviation superseded it. Agencies may also issue implementation guidance through acquisition alerts, procurement notices, or other internal policy communications that affect how the overhaul is executed in practice. Those agency-specific directives should be considered alongside applicable class deviations. Deviations have been revised over the past year, so currency matters as much as content.

One way to frame the practical exposure: the risk right now is less about misreading the new FAR than about two people in the same room reading different versions of it. Version control has become an authority question. It is worth treating it as one.

What FAR prescription was actually doing

Here is an interpretation worth sitting with, because it may explain a discomfort that experienced practitioners feel without naming.

For decades, the standard criticism of the FAR was that it substituted process for judgment. Fair enough. But one way to understand prescription is that it was doing something else at the same time, distributing professional risk away from individuals and toward the institution.

When a contracting officer followed the checklist, the checklist carried much of the justification. If an outcome drew criticism, the process had been followed. That is not a heroic defense, but it is a real one, and it shaped how a profession learned to work.

Reduce the prescription and some of that shelter goes with it. The decision becomes more visibly attributable to a person exercising judgment. That is not a violation, it is exposure. And it arrives without additional time, staff, or cover.

Discretion granted without institutional support functions as an unfunded mandate. Agencies that treat the overhaul as a policy update may find it lands differently than expected. Agencies that treat it as a change in how professional risk is distributed will be better positioned.

A question worth putting to leadership directly: if one of your contracting officers makes a defensible but unconventional call under the new flexibility, and it draws scrutiny two years from now, who is standing next to them?

If the answer is unclear, the flexibility may go unused. History suggests that is the more common outcome.

Why acquisition reform tends to fail at the confidence layer

After the Federal Acquisition Streamlining Act, the last comparable simplification of federal procurement, GAO reported in 1998 that only 17 percent of DoD actions between $25,000 and $100,000 used the new simplified acquisition procedures.

The authority existed. The training existed. The utilization did not.

That figure is among the more instructive data points available on what may happen next, and it is rarely cited in overhaul commentary. The lesson is not that people resist change. It is narrower: practitioners tend not to exercise discretion they do not believe they can defend. A regulation can grant authority. Whether it becomes usable is an organizational question.

A pattern that often accompanies regulatory transitions: the first several months produce little behavioral change, because people are waiting to see how the first unconventional decision is received. How that decision is treated, backed, second-guessed, or quietly reversed, tends to set the ceiling on how much of a reform an organization ever captures. That moment is easy to miss while it is happening.

Three FAR Overhaul changes that matter more than their coverage suggests

Acquisition planning becomes discretionary in form. Proposed FAR 7.102(a) provides that agencies “should establish procedures to determine when a written or oral acquisition plan is required,” and the proposed definition of “planner” refers to a plan “whether written or not.” Content that appeared at FAR 7.105 now sits in the FAR Companion at FC 7.104(c).

Terminations move toward a risk basis. Proposed FAR 49.107 would replace the mandatory audit of termination settlement proposals with a permissive, risk-based approach and remove the certified cost or pricing data threshold as a trigger. Not raised, removed, with the determination left to the termination contracting officer. Inventory schedule submission would compress from 120 days to 60.

Order-level set-aside decisions gain protection from protest. Proposed FAR 19.111-2(a) would provide that a contracting officer’s decision to set aside or not set aside an order is “an exercise of discretion granted to agencies and not a basis for protest.” At the same time, new FAR 19.104-1(b)(1) requires the contracting officer to “document the reason when a contract is not set aside for small business as required.”

Note the direction of that last one, and the pattern it belongs to. Several of the rewritten provisions attach documentation duties to decisions that generate no natural paper trail: the decision not to set aside, not to audit a settlement proposal, not to prepare a written plan. Acting produces a record on its own. Declining to act produces silence. Documenting an absence is a demanding habit to build and, under workload pressure, a plausible first casualty.

What has not changed may matter more. The Competition in Contracting Act still binds, the proposed rule says so, noting CICA compliance “may necessitate market research.” Service contracting under Part 37 is streamlined but, in the rule’s own words, does “not substantively change policy or procedures.”

And the standard by which these decisions are reviewed appears largely unaffected.

The bottom line for the acquisition workforce

The Revolutionary FAR Overhaul is not, at its core, a story about fewer rules. It is a story about where responsibility moves when prescription recedes, and for the federal acquisition workforce, it moves toward judgment and toward the record that judgment leaves behind.

Three practical conclusions follow. First, know which authority governs before you act: the codified FAR, an applicable agency class deviation, or a proposed rule that does not yet apply. Second, treat contract file documentation as the control it has quietly become: when the regulation explains less, the file has to explain more. Third, remember that discretion is only as usable as an organization makes it defensible.

Federal acquisition is shifting from a compliance discipline toward a judgment discipline. The teams that adapt will be the ones that decide, deliberately, what a defensible file looks like before a reviewer decides for them.

For practical support translating the overhaul into repeatable practice, contact Aalis Management Consulting. Visit our Acquisition and Procurement capability page.