Stephanie Barna, Scott A. Freling, Sarah Schuler, Daniel Raddenbach and Victoria Skiera

From Paper Reform to Practice: How Agencies Are Actually Implementing the Revolutionary FAR Overhaul

Over one year ago, on May 2, 2025, the FAR Council took the first concrete step in the administration’s “Revolutionary FAR Overhaul” (“RFO”) initiative by issuing the initial round of rolling model deviation guidance—a deliberate move to translate reform of the Federal Acquisition Regulation (“FAR”) from an abstract policy goal into acquisition text. That mo