A comprehensive analysis of the RFO from a Contracting Officer's perspective

The RFO is returning the FAR to its statutory roots, rewriting it in plain language, and removing most non-statutory rules. This represents the most significant rewrite of the FAR in over 40 years. I'm waiting to see how the implementation part will play out with risk adverse Agency Officers.

Implementation Approach:

Phase I: 31 class deviations due to be implemented effective 1 Feb 2026.

Phase II: Formal rulemaking through 2026 of the notice and comment process for revised FAR parts

Major Changes:

1. Moving non-statutory buying strategies out of the FAR and into OFPP-endorsed "buying guides"

2. Creating the Strategic Acquisition Guidance (SAG) framework, which includes the streamlined FAR and buying guides working together

3. Most FAR parts have been rewritten, with GSA, USDA, and DHS issuing Agency specific deviations.

4. DoD is still awaiting issuance of remaining class deviations in Jan 2026.

Impact on 1102 Acquisition Professionals

1. Increased Professional Autonomy: Empowerment, decision making, and flexibility. Encourage personal initiatives and sound business judgment to meet the agency's mission and manage risk. Delegation of authority to make decisions and the accountability for the decisions to the lowest level, consistent with law

2. Reduced Regulatory Burden

FAR more accessible and easier to understand

Removal of redundant and non-statutory requirements

Streamlined processes reduce administrative overhead

3. Innovation Support

The FAR encourages acquisition team members to pursue new approaches, and document successes and lessons learned

Permission to use strategies not explicitly prohibited

4. Professional Development

Emphasis on judgment over rigid compliance develops critical thinking skills

Broader authority enhances professional growth

Focus on risk management vs. risk elimination aligns with modern program management

5. Team Collaboration

Acq team members must work together as a team and be empowered to make decisions within their area of responsibility

Challenges:

1. Increased Personal Liability and Risk

More discretion means more personal accountability for decisions

Lack of prescriptive guidance creates uncertainty about "right" answers

Potential for inconsistent application across contracting officers

Higher protest risk during transition period

2. Steep Learning Curve

Must shift and adapt decades of compliance-based thinking

Need to develop business judgment skills that may have atrophied under prescriptive rules. How are risk adverse Agency officials going to mitigate the risk of reduced regulatory mandates?

FAR sections expire in 4 years unless renewed, requiring constant adaptation

Multiple versions of rules in effect simultaneously (old FAR, deviations, final rules)

3. Decreased Certainty and Predictability

Less guidance for acquisitions with increased coordination and documentation

Difficulty explaining decisions to oversight bodies

Variable interpretation across agencies

4. Resource and Training Demands

Massive retraining requirement for entire acquisition workforce

Need for enhanced documentation skills to support discretionary decisions

Time needed to review all changes while maintaining workload

Investment in new tools, templates, and systems

5. Management and Oversight Challenges

Quality assurance becomes more difficult without clear checklists

Increased complexity in peer reviews

Potential for mission creep in contracting officer authority

6. Cultural Transformation Requirements

Shift from compliance culture to judgment culture requires organizational change

Resistance from risk-averse personnel and leadership

Tension between innovation encouragement and accountability for mistakes

Need to develop "safe to fail" environment

The RFO represents both opportunity and challenge. Success will depend on how effectively acquisition professionals adapt to increased discretion and how well contractors pivot to demonstrate value in this new, streamlined environment.

Critical success factors for 1102 Professionals:

Embrace the Philosophy: Shift from compliance mentality to judgment-based decision-making

Document Thoroughly: Exercise personal initiative and sound business judgment, but document the rationale

Collaborate Actively: Work together as a team and be empowered to make decisions within your area of responsibility

Pursue Innovation: Pursue new approaches and document successes and lessons learned

Manage Risk Intelligently: Focus on reasonable risk management, not risk elimination

Conclusion

The Revolutionary FAR Overhaul represents a fundamental transformation of federal acquisition from a compliance-based to a judgment-based system. The changes documented in this official RFO FAR volume are extensive and far-reaching, affecting every aspect of the acquisition process.

For 1102 acquisition professionals, the RFO offers both opportunity (increased authority, flexibility, and professional growth) and challenge (increased accountability, uncertainty, and learning curve). Success will require embracing the new philosophy, developing strong business judgment, and documenting decisions thoroughly.

The key to success for the Acquisition professionals community is recognizing that this is not just a regulatory update - it's a cultural transformation. The RFO empowers acquisition professionals to exercise judgment and encourages innovation, while expecting both government and industry to focus on mission success, customer satisfaction, and intelligent risk management rather than rigid compliance with prescriptive rules.

Those who embrace this transformation and develop the skills and approaches needed for the new environment will thrive. Those who resist or cling to the old compliance-based mindset will struggle.

The future of federal acquisition is judgment-based, outcome-focused, and innovation-driven. The Revolutionary FAR Overhaul makes that future possible - but realizing it will require commitment, courage, and continuous learning from all participants in the acquisition system.