On April 15, 2025, President Donald J. Trump issued Executive Order 14275, Restoring Common Sense to Federal Procurement, to implement a “comprehensive reform of the FAR [Federal Acquisition Regulation].” To achieve the objectives of Executive Order 14275, the FAR Council has issued model deviation guidance for many FAR parts and requested informal public feedback by November 3, 2025.

From July to September, the FAR Council published the following notable model deviation guidance:

• FAR Part 12, Acquisition of Commercial Products and Commercial Services: The model deviation consolidated commercial procedures and terms and conditions within FAR Part 12, including moving simplified procedures for commercial acquisitions authorized by statute from FAR Part 13 to FAR Part 12. It also established a preference for fixed-price contracting to the maximum extent practicable (see new Subpart 12.104, Contract Type) and emphasized the government’s desire to use innovative approaches when soliciting quotations or issuing purchase orders.
• FAR Part 15, Contracting by Negotiation: The model deviation aims to shift FAR Part 15 from topic-based to a more intuitive acquisition flow. To do so, FAR Part 15 is reduced from six subparts to five subparts. Further, Subpart 15.4, Contract Pricing, has been restructured, and the internal section numbering and organization have been updated. Certain terms and concepts have been replaced or modified, including replacing “discussions” with “negotiations” and redefining the term “deficiencies.” Last, the model deviation clarifies that not all changes made during negotiations are proposal revisions, particularly those that are not substantive in nature.
• FAR Part 30, Cost Accounting Standards Administration: Most of FAR Part 30 was determined to be statutorily required, although it is notable that the Cost Accounting Standards Board (CAS Board) may be making additional changes. The model deviation regroups certain subparts to align more closely with the proposal submission timeline. It also moved FAR 30.202-7, Determinations, to the FAR Companion (see below).
• FAR Part 31, Contract Cost Principles and Procedures: Only minimal changes were made to FAR Part 31. In addition to the removal of certain definitions, changes included removing a FAR 31.205-6(m)(2) provision addressing the unallowability of company-provided automobiles for personal use, a FAR 31.205-33(f) provision that allowed a retainer without a scope of work, and a FAR 31.205-35(c) provision regarding mortgage title policy allowability.
• FAR Part 44, Subcontracting Policies and Procedures: The model deviation adds clarifying language stating that if a prime contractor maintains an approved purchasing system, consent to subcontract is only required when subcontracts are identified by the Contracting Officer. It also adds language to clearly specify a three-year cycle for Contractor Purchasing System Reviews and emphasizes the government’s preference for commercial acquisition.

On October 30, 2025, the FAR Council released version 2.0 of the FAR Companion, which “provides context, additional information, and practical advice for planning, awarding, managing, and closing out contracts, consistent with the FAR’s core buying principles.” The goal of this resource is to help transition the acquisition workforce and other acquisition stakeholders from rigid compliance requirements to judgment-based procurement practices. Notably, the FAR Companion states that it does not constitute mandatory compliance requirements.

Executive Order 14275 can be found here. The model deviation guidance can be found here. The FAR Companion can be found here.