Government Contracts

U.S. Department of War Memo – Revolutionary FAR Overhaul Phase 1 Class Deviations

The U.S. Department of War (DoW) Principal Director, Defense Pricing, Contracting, and Acquisition Policy (DPCAP), published a memo on December 19, 2025 to announce the initial release of the DoW’s Revolutionary FAR Overhaul (RFO) Phase 1 class deviations. The initial release includes 31 class deviations, effective February 1, 2026, covering DoW-specific statutory requirements and requirements considered necessary for sound procurement.

The December 19 memo states that the Phase 1 changes include actions that can be taken unilaterally prior to the formal rulemaking process. Phase 2 will continue throughout 2026 with the issuance of proposed FAR and DFARS rules for public notice and comment.

The DoW’s RFO Phase 1 class deviations are available on the DPCAP website. The class deviations include the revised DFARS part and the revised Procedures, Guidance, and Information. Noteworthy is the introduction of Tables 212.2, 212.3, and 212.4 in the DFARS Part 212 class deviation. These tables include specific provisions and clauses for use in solicitations and contracts for commercial products and services.

The December 19 memo can be found here. The DPCAP RFO class deviations are available here.

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