RGCI - DoD Issues FAR and DFARS Revolutionary Overhaul Class Deviations Effective as Early as January 2026

Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.

Highlights

  • Revolutionary FAR Overhaul Implementation. The Department of Defense began issuing FAR and DFARS class deviations through Defense Pricing, Contracting, and Acquisition Policy in December 2025 to implement the Revolutionary FAR Overhaul across DoD acquisitions.
  • Early Effective Dates. Many deviations became effective as early as February 1, 2026, with additional parts effective in January and February 2026, requiring contractors to review solicitation language and contract clauses tied to award timing.
  • Clause and Structure Changes. Revised DFARS text, updated PGI guidance, and relocated procedures change how certain provisions and clauses are applied, including the movement of security and cybersecurity clauses to new FAR numbering.
  • Contract Administration Implications. Prime contractors and subcontractors must verify which provisions are in effect for each contract and ensure accurate clause flowdowns to maintain alignment with revised regulatory language.
  • Acquisition Reform Focus. The overhaul emphasizes streamlining regulations to reduce barriers, but introduces complexity around interpretation, definitions, and contract language that may increase operational and compliance review requirements.

As part of the EO Restoring Common Sense to Federal Procurement issued on April 15, 2025, the Government was required to make changes to the FAR and applicable Agency Supplements to only include provisions required by statute or essential to sound procurement. The Revolutionary FAR Overhaul was completed in October 2025, and most agencies, excluding the Department of Defense, issued agency deviations with effective dates. On November 7, 2025, the Department of War’s Acquisition Transformation Strategy continued to address slashing the FAR and DFARS rules to only include what is absolutely vital and remove anything that slows down government contracts.

DPCAP Issues Class Deviations for DoD to begin using the Revolution FAR Overhaul

On December 19, 2025, Defense Pricing, Contracting, and Acquisition Policy (DPCAP) announced in its Memorandum Revolutionary Federal Acquisition Regulation Overhaul Phase 1 Class Deviations that it would release Department of War class deviations to the FAR and DFARS in two phases. Phase 1 class deviations consisted of 31 class deviations to the FAR, and DFARS codified text with the additional deviations to follow. DoD has accepted all the changes made by the FAR Council in the 31 deviations it has issued with effective dates beginning as early as February 1, 2026. DoD planned to develop the remaining class deviations and release them in January 2026. In addition, each class deviation includes DFARS text streamlined by removing, revising, or relocating the procedure to the DFARS PGI. Phase 2 requires the issuance of proposed FAR and DFARS rules for public notice and comment, planned for FY 2026.

On December 18, 2025, DPCAP began issuing DFARS Revolutionary FAR Overhaul Class Deviations for DoD Contracting Officers to use. Each class deviation is by FAR/DFARS part consisting of the following:

  • Acceptance of Revolutionary FAR Overhaul Language;
  • Effective date;
  • Revised DFARS language;
  • Solicitation provisions and contract clauses, if applicable; and
  • Revised DFARS PGI language.

The deviations include separate attachments with line-out changes to the current DFARS and PGI, similar to the Revolutionary FAR Overhaul process. DFARS Part 2, Definitions, was not addressed in Phase I. However, DPCAP’s website states that the definitions listed in the RFO FAR Part 2 should be used. If a definition is not listed, contractors should revert back to the official version of FAR 2.101 (48 CFR Chapter 1).

Since the DPCAP memorandum was issued in December 2025, the following class deviations have been issued as of February 9, 2026:

Takeaways

If you have a DoD contract or subcontract, you will need to make sure you understand which provisions and clauses from the Revolutionary FAR and DFARS are in effect for your solicitation and resulting contract. Prime contractors need to ensure they are flowing down the correct clauses.

While the stated intent of the regulation overall is to reduce requirements and barriers to entry, when dealing with the U.S. Government, especially DoW, understanding the actual language in your contracts and subcontracts is extremely important. Do not let a contracting officer or higher-tier buyer talk you into accepting vague or unclear contract language.

One significant change is that security, prohibition, and cybersecurity provisions and clauses have been moved from FAR 52.204-xx clauses to FAR 52.240-xx.

Understanding the Practical Impact of Ongoing Regulatory Changes

As DoD continues implementing the Revolutionary FAR Overhaul through class deviations, government contractors should expect ongoing adjustments to solicitation language, clause structure, and acquisition procedures that affect both new awards and existing contracts. Redstone GCI helps contractors evaluate revised FAR and DFARS language, review contract clauses and subcontract flowdowns, align purchasing and accounting processes with updated requirements, and provide role-based training so contracts, accounting, procurement, and leadership teams understand how these changes impact contract administration, billing, and internal procedures.

Learn More About Our Federal Acquisition Regulations (FAR) Compliance Services

Frequently Asked Questions (FAQs)

  • What are the DoD Revolutionary FAR/DFARS Overhaul class deviations? These deviations allow the Department of Defense to begin using updated FAR and DFARS language before formal rulemaking is complete. They revise contract clauses, procedures, and guidance that contracting officers must follow.
  • Who do these deviations apply to? They primarily apply to DoD contracting officers, but they also directly affect prime contractors and subcontractors working on DoD contracts. Any company supporting DoD programs will need to review the updated provisions and clauses.
  • When do the new requirements take effect? Many of the deviations became effective as early as February 1, 2026, with some effective dates in January and mid-February 2026. The applicable version depends on the timing of the solicitation and contract award. Additionally, changes may occur during the award process as new deviations emerge and final rulemaking is undertaken.
  • What types of changes should contractors expect? Contractors will see revised FAR/DFARS language, relocated procedures, and updated clauses, including the movement of certain security and cybersecurity clauses. These changes will affect how contracts are written and administered.
  • Why do these deviations matter for compliance and operations? Contract language determines which requirements apply, so understanding the updated clauses helps prevent misunderstandings during negotiations and performance.
  • Does the overhaul reduce contractors' compliance requirements? While the stated goal is to streamline regulations, there was limited, if any, real reduction in compliance requirements.

Written by Lynne Nalley and John Shire

Lynne Nalley and John Shire

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)