Wait…Which FAR Am I Supposed to Be Following?

If you've been following the Revolutionary FAR Overhaul (RFO), you may have had the same thought as a lot of government contracting professionals lately:

Wait…which version of the FAR am I actually supposed to be following?

It's a fair question.

The FAR is being rewritten and streamlined. Agencies are issuing deviations. Acquisition.gov contains both the codified FAR and RFO resources. Solicitations may incorporate revised language. Existing contracts still contain clauses that were incorporated when they were awarded.

For contractors trying to stay compliant, "just check the FAR" isn't quite as simple as it used to be.

So, let's break it down.

First: What Is Actually Happening to the FAR?

The Revolutionary FAR Overhaul is a government-wide effort to substantially streamline the Federal Acquisition Regulation.

The stated objectives include removing regulations that are not required by statute or executive order, eliminating unnecessary or duplicative requirements, using clearer language, and moving some non-regulatory acquisition guidance out of the FAR.

But there's an important distinction for contractors:

A rewritten FAR part doesn't automatically rewrite your existing contract.

During this transition, contractors may encounter the codified FAR, newly rewritten FAR language, model deviations, agency-specific deviations, and solicitation-specific requirements. Sometimes at the same time.

That's where things can get confusing.

Think of Compliance in Layers

Instead of asking, "Which FAR should I follow?", a better question is:

"What requirements apply to this particular contract?"

Start with these layers.

1. Your Awarded Contract

For an existing contract, this is your starting point.

Look at the clauses, terms, attachments, modifications, and other requirements actually incorporated into the agreement.

A regulatory change somewhere on Acquisition.gov doesn't necessarily mean the terms of your existing contract changed overnight.

If the government modifies your contract to incorporate a new requirement, however, that's another story—which is one reason modification review is so important.

2. Contract Modifications

Don't stop with the original award.

Your contract today may look very different from the document you signed three years ago.

Modifications can change funding, periods of performance, scope, deliverables, clauses, reporting requirements, and other contractual obligations.

When evaluating compliance, you need the current contract as modified, not simply the original award document.

3. The Applicable FAR Requirements

The codified FAR remains an important regulatory source, but the RFO transition has introduced another layer contractors need to understand.

The FAR Council is publishing rewritten FAR parts along with implementation materials and model deviation text as the overhaul progresses.

That does not mean contractors should simply find the newest-looking version of a FAR provision online and assume it governs their contract.

Context matters.

4. Agency Deviations

This is where contractors need to pay particularly close attention.

Agencies are implementing portions of the FAR overhaul through deviations, and the applicable language may vary depending on which agency issued the solicitation or contract.

A contractor supporting the Army may therefore need to evaluate different implementation guidance than a contractor supporting NASA, VA, DHS, or another agency.

Acquisition.gov maintains a FAR Part Deviation Guide to help users identify the deviations agencies have issued as part of the overhaul.

For contractors pursuing new opportunities, reviewing applicable agency deviations should become part of the solicitation review process—not something discovered after award.

5. The Solicitation

For new business, read the solicitation you actually received.

The solicitation tells you what the Government is asking you to agree to.

Don't assume that because you've responded to ten similar RFPs, number eleven contains the same requirements.

During a period of significant regulatory change, relying on an old proposal compliance matrix, clause template, or previous solicitation becomes particularly risky.

Read what's actually there.

What Does This Mean for Contractors?

The RFO may ultimately make federal acquisition regulations simpler.

But during the transition, contractors need strong processes for determining which requirements apply to each contract.

This is a good time to review:

• Contract review procedures

• FAR/DFARS and agency supplement matrices

• Solicitation review checklists

• Clause and flowdown matrices

• Contract modification procedures

• Standard proposal templates

• Internal compliance policies

If those tools were built around the assumption that someone can simply look up the current FAR and determine the requirement, they may need another look.

And Don't Forget Your Subcontracts

Prime contractors have another important consideration: flowdowns.

When solicitation provisions, contract clauses, or agency requirements change, don't assume your existing subcontract templates automatically reflect those changes.

Part of evaluating a new award should include determining:

What applies to us—and what must we flow down to our subcontractors?

That's a separate analysis, and it's one that deserves attention during both proposal review and post-award administration.

The Biggest Takeaway

The FAR overhaul isn't a reason to panic, and contractors don't need to relearn federal contracting every time another FAR part is rewritten.

But it is a reason to be more deliberate.

Don't manage compliance based on what you remember the FAR saying.

Don't assume the clause from your last contract is still the right one.

And don't assume that finding a FAR provision through a quick internet search tells you everything you need to know.

Start with the specific procurement or contract in front of you. Identify the applicable requirements. Check for relevant agency deviations. Review modifications. Document your determination.

Because ultimately, compliance isn't about knowing every FAR clause from memory.

It's about knowing what applies, knowing where to find it, and having a process to make sure your organization follows it.

Want to know where your contract administration processes stand?

Ally Compliance Solutions' FREE 20-Question Contract Compliance Check takes just a few minutes and can help identify potential gaps in your organization's post-award contract management processes.

Take the free check: allycompliancesolutions.com/compliance-check