Class Deviation RFO-2025-06: FAR Class Deviation for FAR Part 6 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-06
June 26, 2025
MEMORANDUM FOR GSA CONTRACTING ACTIVITIES
FROM AND DIGITALLY SIGNED BY: Jeffrey A. Koses, Senior Procurement Executive, Office of Acquisition Policy (MV)
SUBJECT: FAR Class Deviation for FAR Part 6 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

On this page:

Purpose
Background
Summary of changes
Instructions
Applicability
Authority
Effective date
Have a question?

1. Purpose

This memorandum approves a class deviation to Federal Acquisition Regulation (FAR) part 6 for purposes of implementing the FAR Council’s model deviation to FAR part 6.

2. Background

Executive Order (E.O.) 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025, mandates a comprehensive review and simplification of the Federal Acquisition Regulation.

The FAR is being updated to:

Eliminate non-statutory language.
Remove redundant or obsolete language.
Enhance clarity through plain language.
Align with the new FAR framework.
Preserve essential governmentwide acquisition standards.

This project is referred to as the Revolutionary FAR Overhaul (RFO) initiative. This initiative will make the FAR more concise, understandable, and focused on core procurement requirements.

3. Summary of changes

FAR part 6, Competition Requirements, has been streamlined to strengthen clarity and focus, helping to ensure procedures that support full and open competition are easier to understand and apply.

Statutory requirements retained in the RFO FAR part 6 model deviation include, but are not limited to, the following:

41 U.S.C. § 1705, Advocates for Competition
41 U.S.C. § 3301 and 10 U.S.C. § 3201, Full and Open Competition
41 U.S.C. § 3303 and 10 U.S.C. § 3203, Exclusion of Particular Source or Restriction of Solicitation to Small Business Concerns
41 U.S.C. § 3304, Use of Noncompetitive Procedures
10 U.S.C. § 3204, Use of Procedures Other than Competitive Procedures
15 U.S.C. Chapter 14A, Aid to Small Business
42 U.S.C. § 5150, Major Disaster and Emergency Assistance, Use of Local Firms and Individuals

Change	Description
Retained	FAR part 6 continues to apply to all acquisitions, with limited exceptions for specific contracts and orders. Advocates for Competition, previously at subpart 6.5, has been moved to section 6.003. Details about the role and responsibilities have been streamlined. Guidance pertaining to Sealed Bidding has been streamlined and moved from subpart 6.4 to section 6.101. Authorities for other than full and open competition, including only one responsible source, remain. Contracting officers retain discretion to set aside acquisitions for small business concerns, including contract actions conducted under the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, and local firms during a major disaster or emergency. Justification and approval requirements to support noncompetitive procedures. These requirements have been significantly streamlined. The revised language highlights that contracting officers require support from the broader acquisition team when making decisions regarding competition. The approval levels are now reflected in a plain language table format.
Removed	Unnecessary or redundant language was removed throughout. Examples include- The word “advance” was removed from the phrase, “A lack of advance planning by the requiring activity.” The language now reads, “A lack of planning by the requiring activity.” This avoids ambiguity surrounding the meaning of “advance” planning. The list of specific small business socioeconomic categories was removed and replaced with a reference to part 19. Illustrative examples of when to use certain exceptions to full and open competition have been removed and may be moved to non-regulatory content.

Change

Description

Retained

FAR part 6 continues to apply to all acquisitions, with limited exceptions for specific contracts and orders.
Advocates for Competition, previously at subpart 6.5, has been moved to section 6.003. Details about the role and responsibilities have been streamlined.
Guidance pertaining to Sealed Bidding has been streamlined and moved from subpart 6.4 to section 6.101.
Authorities for other than full and open competition, including only one responsible source, remain.
Contracting officers retain discretion to set aside acquisitions for small business concerns, including contract actions conducted under the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, and local firms during a major disaster or emergency.
Justification and approval requirements to support noncompetitive procedures.
- These requirements have been significantly streamlined.
- The revised language highlights that contracting officers require support from the broader acquisition team when making decisions regarding competition.
- The approval levels are now reflected in a plain language table format.

Removed

Unnecessary or redundant language was removed throughout. Examples include-
- The word “advance” was removed from the phrase, “A lack of advance planning by the requiring activity.” The language now reads, “A lack of planning by the requiring activity.” This avoids ambiguity surrounding the meaning of “advance” planning.
- The list of specific small business socioeconomic categories was removed and replaced with a reference to part 19.
Illustrative examples of when to use certain exceptions to full and open competition have been removed and may be moved to non-regulatory content.

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce shall follow the RFO part 6 model deviation text instead of FAR part 6 as codified at 48 CFR Chapter 1. The Council’s RFO part 6 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
Review templates and related standard operating procedures to align with this deviation and remove unnecessary processes and steps.

5. Applicability

This class deviation applies to all GSA procurements.

6. Authority

This class deviation is issued under the authority of EO 14275, OMB Memo M-25- 26 [PDF], 48 CFR 1.4, and RFO FAR 1.304.

7. Effective date

This class deviation is effective immediately and remains in effect until rescinded or incorporated into the FAR.

8. Have a question?

Try asking GSAi first (upload the new RFO language and GSA’s implementing deviation, then ask your question. Please note, GSAi is accessible to GSA employees only). If you still need clarification, email the GSA Acquisition Policy Division at GSARPolicy@gsa.gov.