The FAR Overhaul Has Entered a New Phase. Most Contractors Haven’t

For much of the past several months, the conversation surrounding the Revolutionary FAR Overhaul has focused on executive orders, agency deviations, and the Administration’s stated goal of simplifying the Federal Acquisition Regulation (FAR).

On June 23, 2026, the discussion entered a new phase.

The Federal Acquisition Regulatory (FAR) Council, composed of representatives from the Department of Defense (DoD), General Services Administration (GSA), National Aeronautics and Space Administration (NASA), and the Office of Federal Procurement Policy (OFPP), published the first package of proposed regulations implementing Executive Order 14275, Restoring Common Sense to Federal Procurement. The initial package spans four rulemaking cases affecting roughly twenty FAR Parts, with public comments due by July 23, 2026.

The publication of proposed regulations marks the point where procurement reform begins moving from executive direction toward permanent acquisition policy.

Executive Orders establish priorities. Agency deviations can accelerate implementation. Formal rulemaking is the process through which those priorities are translated into regulations that may ultimately govern how federal agencies buy goods and services.

For contractors, GovTech companies, and federal market leaders, the conversation should now shift from the idea of procurement reform to the substance of the proposed regulations. The most important question is no longer whether the FAR will change. It is how those changes may reshape the federal acquisition environment over the coming years.

Why This Stage Matters

Notice-and-comment rulemaking is more than an administrative requirement. It is one of the few points in the federal acquisition process where industry has a formal opportunity to influence the regulations that ultimately govern federal contracting.

The current proposals are not final regulations. Portions may change in response to public comments, the FAR Council has not announced when final rules will be issued, and additional rulemaking packages are expected. This first tranche should therefore be viewed as the beginning of a broader effort rather than its conclusion.

For contractors, that distinction matters because the current comment period provides an opportunity to engage before the acquisition framework is finalized. Even organizations that choose not to submit comments can gain valuable insight by understanding the direction federal acquisition leadership appears to be taking.

The Proposed Rules Reveal More Than Individual Regulatory Changes

Much of the early coverage has understandably focused on identifying which FAR Parts were revised.

That is only part of the story.

Viewed collectively, the initial rulemaking package reflects several consistent themes that have characterized the Revolutionary FAR Overhaul from the beginning. The proposed regulations seek to simplify acquisition procedures, remove or consolidate prescriptive regulatory language, increase reliance on professional judgment where appropriate, and reduce administrative burdens that acquisition leaders believe have accumulated over time.

Several proposed changes illustrate that broader philosophy.

For example, one proposal would increase approval thresholds for certain sole-source acquisitions, expanding the authority available to contracting officers and senior acquisition officials under specified circumstances. Other proposed revisions remove detailed procedural language that acquisition leaders believe is better addressed through guidance, training, or professional judgment than through regulation itself.

Whether every individual proposal survives the rulemaking process unchanged is ultimately less important than the broader procurement signal these proposals send. Taken together, they suggest an acquisition system that may rely less on prescriptive process and more on informed acquisition judgment.

If that philosophy continues through future rulemaking packages, it could influence federal acquisition practice well beyond the specific regulatory changes contained in this first set of proposals.

What Most Contractors Are Missing

The most common mistake organizations make during periods of procurement reform is treating regulatory change as something to address only after it appears in an active solicitation.

By that point, capability statements have been developed, business development messaging has been established, proposal libraries have matured, and internal governance practices are often well entrenched. Strategic adjustments made under proposal deadlines are possible, but they are rarely ideal.

Regulatory transitions provide organizations with something active procurements rarely do: time. Time to review market positioning, strengthen governance documentation, reassess business development messaging, and determine whether existing assumptions still align with the direction federal procurement appears to be moving.

The notice-and-comment period is not simply an opportunity to react to procurement reform. It is one of the few opportunities industry has to help shape the acquisition environment before it becomes permanent.

What Kettle Hill Is Watching

Rather than focusing exclusively on individual FAR revisions, Kettle Hill Advisory is watching several broader procurement signals that may have longer-term implications.

First, how much additional discretion contracting officers ultimately receive. The balance between regulatory prescription and acquisition judgment has been a recurring theme throughout the reform effort.

Second, whether future rulemaking packages reinforce the same philosophy. The initial package does not include every major FAR Part, and additional proposals are expected. Whether subsequent releases continue emphasizing simplification, flexibility, and reduced regulatory burden will provide important insight into the long-term direction of the reform effort.

Third, how quickly agencies begin incorporating the underlying philosophy of these reforms into acquisition planning and procurement practice. While proposed regulations do not immediately change agency requirements, acquisition organizations often begin internal planning, workforce training, and policy discussions well before final rules take effect.

Finally, how industry participates during the public comment process. Thoughtful comments frequently improve regulatory language, identify unintended consequences, and provide practical implementation perspectives that are difficult to capture through policy development alone.

Together, these signals provide a more meaningful picture of where federal procurement may be heading than any individual FAR revision viewed in isolation.

Looking Beyond the Headlines

The Revolutionary FAR Overhaul is often discussed as a political initiative or a regulatory project. It is also a rare opportunity for industry to participate in shaping the acquisition system before those reforms become permanent.

The current proposals remain exactly that: proposed regulations. Portions may change following public comment, additional rulemaking packages are expected, and no final implementation schedule has been announced.

Those uncertainties should not discourage organizations from paying attention. They are precisely what make the current moment strategically important.

Federal procurement rarely changes overnight. It evolves through a series of policy decisions, proposed regulations, public comments, and agency implementation efforts that collectively shape how contracting officers buy, how agencies manage acquisition risk, and how industry competes.

The current rulemaking process represents one of those moments.

For contractors, GovTech companies, and federal market leaders, the immediate question is not whether every proposed provision will survive unchanged. It is whether their organization understands the broader direction of travel well enough to prepare for the acquisition environment that ultimately emerges.