CMMC & Defense Cybersecurity Brief
Headline
FAR Council proposes sweeping overhaul of federal acquisition regulations under Executive Order 14275
Executive Summary
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a proposed rule on June 23, 2026 to amend Parts 1, 2, 4, 33, 39, 40, 52, and 53 of the Federal Acquisition Regulation. The proposal is one of twelve coordinated rules implementing Executive Order 14275, which directs elimination of regulations the order characterizes as excessive.
Bottom Line
The proposed rule initiates the most structurally broad FAR revision in the regulation's modern history, touching administrative, disputes, IT procurement, and newly created organizational parts across a twelve-rule coordinated package. Every entity holding or pursuing a federal contract, and every attorney or compliance officer supporting federal procurement, operates under a regulatory baseline that is now formally in flux. The comment period is the sole mechanism through which affected parties can shape the final text before it becomes binding.
Key Regulatory Signals
- Twelve-Rule Coordinated Overhaul: The FAR Council is issuing twelve proposed rules simultaneously to restructure the FAR in its entirety. Contractors, contracting officers, and legal counsel supporting federal procurement must assess exposure across all twelve rules, not only this installment covering Parts 1, 2, 4, 33, 39, 40, 52, and 53.
- Parts 33 and 39 Revisions Affect Disputes and IT Procurement: Proposed changes to Part 33 (protests, disputes, and appeals) and Part 39 (acquisition of information technology) carry direct procedural consequences for contractors with active disputes or pending IT vehicle awards. Affected parties must track whether existing rights or timelines are altered by the proposed text.
- Part 4 Revisions Touch Contractor Records and Reporting: Part 4 governs administrative matters including contractor records, reporting, and system-for-award-management requirements. Proposed revisions here affect the administrative compliance baseline for every entity holding or pursuing a federal contract.
- New Part 40 Introduced: The proposal references Part 40, which does not currently exist as a substantive FAR part. Its introduction signals a structural reorganization of the FAR, not merely a streamlining of existing text. Contractors and counsel must review what obligations or authorities are being relocated or newly codified there.
- Comment Period Governs Industry Input Window: As a proposed rule, this action opens a formal comment period. Federal contractors, trade associations, and procurement counsel have a defined window to submit comments before any provisions become binding. The Federal Register notice states the specific close date.
Regulatory Delta
- No prior FAR overhaul of comparable scope has been issued as a coordinated twelve-rule package. Earlier FAR reform efforts, such as the 2014 OFPP category management initiative, addressed discrete parts individually.
- The structural introduction of a new Part 40 represents a reorganization of the FAR's architecture, not a revision of existing provisions.
- Executive Order 14275 aligns with concurrent OMB and DOGE-directed federal spending reduction initiatives, placing this rulemaking within a broader executive deregulatory posture affecting all civilian and defense procurement.
Materiality Classification
HIGH — A twelve-rule coordinated proposed overhaul of the FAR in its entirety, issued under a direct executive order, requires every federal contractor and procurement counsel to assess compliance posture across all affected parts before the comment period closes.
Intelligence Outlook
Monitor the Federal Register for the comment period close date on this proposed rule and for the remaining eleven coordinated FAR overhaul proposed rules expected under Executive Order 14275.