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How the FAR Overhaul Benefits Small Businesses

The Revolutionary FAR Overhaul cuts more than half the information needed to register on SAM.gov, collapses the small-business set-aside test into one rule, and rewrites all 53 FAR parts in plain language. Here is where it stands in August 2026 and what to do about it.

By The Bid Lab Team·Published 7/19/2025·Updated 8/28/2026

The Revolutionary FAR Overhaul benefits small businesses by shrinking what it takes to register, compete and win a federal contract: it cuts more than half the information required for a SAM.gov registration, collapses the small-business set-aside test into one rule that applies to every contract above the micro-purchase threshold, and rewrites all 53 parts of the Federal Acquisition Regulation in plain language. As of August 2026 the effort has moved out of temporary agency deviations and into formal rulemaking.

What Is the Revolutionary FAR Overhaul?

The Federal Acquisition Regulation has governed how the federal government buys goods and services since 1984. It tells agencies how to plan an acquisition, choose a contract type, run the competition and manage the resulting contract. Every executive-branch agency works from it, which is why a change to the FAR changes the rules for every business selling to the government.

The Revolutionary FAR Overhaul, usually shortened to RFO, began with Executive Order 14275, “Restoring Common Sense to Federal Procurement,” signed in April 2025 and implemented through OMB Memorandum M-25-25 on 2 May 2025. Its instruction was blunt: strip the FAR back to what statute actually requires, delete the rest, and say it in plain language.

Where Does the FAR Overhaul Stand Right Now?

This is the part that has changed most since the overhaul began, and it is where most published guidance is out of date. The work has run in two distinct phases:

PhaseWhat happenedStatus
Phase 1 — model deviationsThe FAR Council drafted revised “model deviation” text for all 53 FAR parts and agencies adopted it through class deviations, so the new language took effect before any rule was final.Complete
Phase 2 — formal rulemakingFour proposed rules published in the Federal Register on 23 June 2026, converting the deviation text into permanent regulation.Comment period closed 23 July 2026
Final rulesThe FAR Council reviews comments and issues final rules, part by part.Pending

The four proposed rules cover roughly twenty parts between them: FAR Case 2026-001 (Parts 1, 2, 4, 33, 39, 40 and 53), FAR Case 2026-002 (Parts 6, 7, 10, 18, 26, 37 and 41), FAR Case 2026-005 (Parts 5, 24 and 29) and FAR Case 2026-007 (Parts 3 and 49). The remaining parts are still operating under class deviation text while their rules are drafted.

The practical consequence for a small business bidding today: you are already working under the overhauled rules on most solicitations, because the deviations are live even though the regulation is not yet final.

How Does the FAR Overhaul Benefit Small Businesses?

Four changes matter more than the rest if you are a small business trying to break into federal work.

  1. A much shorter SAM.gov registration. FAR Case 2026-001 keeps only entity-level representations and certifications in SAM and removes the procurement-specific ones, including Section 889 supply-chain attestations. The FAR Council's own estimate is that this removes over half of the information previously required to register. If a stalled registration has kept you out of federal bidding, this is the change to act on — our guide to registering on SAM.gov walks through what is still required.
  2. One set-aside rule instead of two. See the next section — this is the single biggest structural change for small business.
  3. Higher sole-source approval authority. Contracting officers can approve larger sole-source awards without escalating: up to $10 million at the Department of Defense, NASA and the Coast Guard, and up to $900,000 at other agencies. More awards can be made quickly to a capable incumbent or a specialised supplier.
  4. Plain language throughout. The rewrite strips duplicated and non-statutory material from every part. That does not change what you must do, but it makes the requirement legible without a compliance consultant — which disproportionately helps businesses without one.
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Does the Rule of Two Survive the Overhaul?

Yes — and this was the open question that worried the small-business community most. The overhauled FAR Part 19 keeps the Rule of Two: a contracting officer must set an acquisition aside for small business when there is a reasonable expectation of receiving offers from two or more responsible small business concerns at fair market prices.

What changed is the structure. The old FAR drew a line between purchases above the micro-purchase threshold but under the simplified acquisition threshold and those above it, with different rules for each. The overhauled Part 19 applies one unified rule to everything above the micro-purchase threshold, and requires the contracting officer to document the reason whenever a contract is not set aside.

One caveat worth knowing before you plan around it: the Rule of Two does not apply to orders under multiple-award contracts. A contracting officer may set aside such an order for small business but is not required to. If most of your pipeline runs through task orders on a GWAC or an IDIQ, the Rule of Two is not protecting you there.

Which Dollar Thresholds Changed?

Separately from the overhaul, the FAR Council's five-year inflation adjustment raised the core thresholds effective 1 October 2025. These are the numbers that decide which rules apply to a given buy:

ThresholdPreviousCurrent
Micro-purchase threshold$10,000$15,000
Simplified acquisition threshold$250,000$350,000
Subcontracting plan required (FAR 19.702)$750,000$900,000

Raising the simplified acquisition threshold to $350,000 widens the band in which small-business set-asides and streamlined procedures apply — by one estimate around 5,000 additional awards a year now fall inside it.

The Part 19 sole-source ceilings for socioeconomic programmes are unchanged: $8.5 million for manufacturing NAICS codes and $5.5 million otherwise for HUBZone, WOSB and 8(a), and $8.5 million / $5 million for SDVOSB. If you are not yet certified, small business certifications remain one of the highest-leverage moves available.

What Should Your Small Business Do Next?

  1. Refresh your SAM.gov registration against the shorter requirement. If you abandoned a registration because of the reps-and-certs burden, the burden is now materially smaller.
  2. Re-check solicitations you previously screened out. A higher simplified acquisition threshold and a unified Rule of Two mean opportunities that were open competitions last year may be set aside this year.
  3. Read the deviation text for the parts that govern your work, not just the final rules. The deviations are what contracting officers are applying today.
  4. Review your compliance posture against the new language. Simplification is not deregulation — statutory requirements survive intact. Our comparison of public and private sector compliance covers what does not change.
  5. Start bidding while competitors are still reading. Periods of regulatory change reward businesses that move first, and responding to federal bids is more approachable now than it has been in a decade.

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Frequently asked questions

What is the Revolutionary FAR Overhaul?

The Revolutionary FAR Overhaul is a government-wide rewrite of the Federal Acquisition Regulation launched by Executive Order 14275 in April 2025. It strips the FAR back to what statute requires, removes duplicated and non-statutory material, and restates the rules in plain language across all 53 parts. Agencies adopted the new text through class deviations before formal rulemaking began.

Has the FAR overhaul been finalized?

Not yet. The overhaul ran in two phases. Model deviation text for all 53 FAR parts is complete and agencies are applying it now. Formal rulemaking began on 23 June 2026 with four proposed rules covering about twenty parts, and the comment period closed on 23 July 2026. Final rules are still pending, so contractors are working under deviation text in the meantime.

Does the FAR overhaul eliminate small business set-asides?

No. The overhauled FAR Part 19 retains the Rule of Two, which requires a set-aside when a contracting officer reasonably expects offers from two or more responsible small businesses at fair market prices. The change is structural: one unified rule now applies above the micro-purchase threshold instead of separate rules at different thresholds.

How does the FAR overhaul change SAM.gov registration?

Under FAR Case 2026-001, only entity-level representations and certifications stay in SAM.gov. Procurement-specific reps and certs, including Section 889 supply chain attestations, move out. The FAR Council estimates this removes over half of the information previously required to register, which lowers the entry barrier for first-time federal bidders.

What are the current micro-purchase and simplified acquisition thresholds?

Effective 1 October 2025, the micro-purchase threshold rose from $10,000 to $15,000 and the simplified acquisition threshold rose from $250,000 to $350,000. The subcontracting plan threshold rose from $750,000 to $900,000. The higher simplified acquisition threshold widens the band where small business set-asides and streamlined procedures apply.

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