Class Deviation RFO-2025-07: FAR Class Deviation for FAR Part 7 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-07
September 2, 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 7 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 7 for purposes of implementing the FAR Council’s model deviation to FAR part 7.

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 7, Acquisition Planning, is streamlined to emphasize flexibility and move away from prescriptive checklists in favor of a dynamic planning process.

The deviation recognizes the distinctions between task and delivery orders and award of new contracts, requiring appropriate acquisition planning for each. The placing of task and delivery orders is a faster and more streamlined process with significantly less pre-award actions required than in awarding new contracts. The level of detail should vary with the size and complexity of the acquisition.

The deviation to part 7 also picks up on requirements previously found in FAR 10 to ensure small business concerns are appropriately considered. Requirements for bundling, substantial bundling, and consolidation are unified to ensure common consideration of any potential negative impact on small business.

While there is no longer a requirement for acquisition plans with specific elements, there should still be forethought in what is being procured. Having a plan is key to ensuring the guiding principles of the acquisition system are met. By emphasizing early engagement, this change creates more opportunities to foster innovation and achieve successful results, reflecting a shift toward a more agile and strategic approach.

Statutory requirements and executive requirements retained in the RFO FAR part 7 model deviation include, but may not be limited to, the following:

41 U.S.C. §§ 3301 et seq, Planning and Solicitation
10 U.S.C. § 3453, Preference for Commercial Products and Commercial Services
15 U.S.C. § 657q, Consolidation of Contract Requirements
15 U.S.C. § 644, Awards or Contracts
Pub. L. 115-254, Sec 555, Cost-Effectiveness Analysis of Equipment Rental
OFPP Policy Letter 11-01, Performance of Inherently Governmental and Critical Functions

Change	Description
New/Retained/Updated	Updated: In section 7.000, “Scope of Part”, para (a) is revised from “Developing acquisition plans” to “Acquisition planning and developing acquisition plans”. This broadens the scope to encompass the entire planning process, not just the act of creating a document. Retained: The definitions at 7.101, “Definitions”, are retained and most have been simplified to improve clarity. New: Section 7.102, is renamed “Requirements” and establishes the fundamental requirement for acquisition planning in all acquisitions. It mandates that agencies establish procedures for determining whether a written or oral plan is needed and lists high-level outcomes that planning must promote: Acquisition of commercial products or services Full and open competition Selection of appropriate contract type Use of existing contracts Note - Although 7.102 gives agencies discretion in establishing procedures for written or oral plans, 7.102(d) retains the requirement to use a written plan for cost reimbursement and other high-risk contracts. Updated: Section 7.103, “Agency-head Responsibilities”, is updated from a long list of specific tasks to a list of high-level responsibilities, such as creating streamlined procedures for different acquisition types (e.g., orders, commercial products and services), establishing criteria for high-risk contracts, and ensuring small business opportunities are considered. Updated: Section 7.104, “General Procedures”, is updated to highlight that early planning can create opportunities to structure the procurement approach in a way that promotes competition and innovation. Practitioners should review the FAR Companion for best practices for innovative acquisition planning techniques. Updated: Section 7.107, “Additional Requirements for Acquisitions Involving Consolidation, Bundling, or Substantial Bundling”, is updated to streamline and standardize the analysis, determination, and notification requirements – there are no longer separate requirements for each, with the goal of ensuring this important step in the acquisition process is understood by the workforce. 7.107-1(a) retains the requirement for market research before conducting an acquisition that consolidates or bundles requirements. Updated: Section 7.108, “Additional Requirements for Teleworking”, is updated to reflect modern terminology and simplified language. For example, the term “telecommuting” has been updated to “teleworking”. Updated: Section 7.403, formerly titled “General Services Administration Assistance and OMB Guidance,” has been retitled “OMB Guidance”. Paragraphs (a) and (b) of the former section, which described the types of assistance available from GSA, have been removed. The content of the former paragraph (c), which provides references to relevant OMB circulars, has been retained and updated with new hyperlinks. The removal of the GSA assistance information streamlines the text by deleting content that is informational rather than regulatory. The process agencies use to perform a lease-versus-purchase analysis remains intact in clause 52.207-5. Retained: Subpart 7.5, “Inherently Governmental Functions”, is retained and revised for clarity and readability, primarily through plain-language edits and structural reorganization. Retained clauses and provisions, with no changes in text: 52.207-4 Economic Purchase Quantity—Supplies 52.207-5 Option To Purchase Equipment 52.207-6 Solicitation of Offers from Small Business Concerns and Small Business Teaming Arrangements or Joint Ventures (Multiple-Award Contracts)
Removed	Section 7.105, “Contents of Written Acquisition Plans” is removed and marked “Reserved.” Relevant content will be reflected in the FAR Companion. Section 7.200, “Scope of Subpart” regarding economic quantities of purchases, has been deleted and marked “Reserved” as it is unnecessary. Section 7.204, “Responsibilities of Contracting Officers” has been deleted as the content is covered by FAR 52.207-4. Subpart 7.3, “Contractor Versus Government Performance”, and its underlying sections have been deleted and marked “Reserved” as Congress has consistently placed a statutory hold on A-76 competitions since 2008. The following clause and provisions are removed: 52.207-1 Notice of Standard Competition 52.207-2 Notice of Streamlined Competition 52.207-3 Right of First Refusal of Employment

Change

Description

New/Retained/Updated

Updated: In section 7.000, “Scope of Part”, para (a) is revised from “Developing acquisition plans” to “Acquisition planning and developing acquisition plans”. This broadens the scope to encompass the entire planning process, not just the act of creating a document.
Retained: The definitions at 7.101, “Definitions”, are retained and most have been simplified to improve clarity.
New: Section 7.102, is renamed “Requirements” and establishes the fundamental requirement for acquisition planning in all acquisitions. It mandates that agencies establish procedures for determining whether a written or oral plan is needed and lists high-level outcomes that planning must promote:
- Acquisition of commercial products or services
- Full and open competition
- Selection of appropriate contract type
- Use of existing contracts
  Note - Although 7.102 gives agencies discretion in establishing procedures for written or oral plans, 7.102(d) retains the requirement to use a written plan for cost reimbursement and other high-risk contracts.
Updated: Section 7.103, “Agency-head Responsibilities”, is updated from a long list of specific tasks to a list of high-level responsibilities, such as creating streamlined procedures for different acquisition types (e.g., orders, commercial products and services), establishing criteria for high-risk contracts, and ensuring small business opportunities are considered.
Updated: Section 7.104, “General Procedures”, is updated to highlight that early planning can create opportunities to structure the procurement approach in a way that promotes competition and innovation.
- Practitioners should review the FAR Companion for best practices for innovative acquisition planning techniques.
Updated: Section 7.107, “Additional Requirements for Acquisitions Involving Consolidation, Bundling, or Substantial Bundling”, is updated to streamline and standardize the analysis, determination, and notification requirements – there are no longer separate requirements for each, with the goal of ensuring this important step in the acquisition process is understood by the workforce.
- 7.107-1(a) retains the requirement for market research before conducting an acquisition that consolidates or bundles requirements.
Updated: Section 7.108, “Additional Requirements for Teleworking”, is updated to reflect modern terminology and simplified language. For example, the term “telecommuting” has been updated to “teleworking”.
Updated: Section 7.403, formerly titled “General Services Administration Assistance and OMB Guidance,” has been retitled “OMB Guidance”. Paragraphs (a) and (b) of the former section, which described the types of assistance available from GSA, have been removed. The content of the former paragraph (c), which provides references to relevant OMB circulars, has been retained and updated with new hyperlinks. The removal of the GSA assistance information streamlines the text by deleting content that is informational rather than regulatory. The process agencies use to perform a lease-versus-purchase analysis remains intact in clause 52.207-5.
Retained: Subpart 7.5, “Inherently Governmental Functions”, is retained and revised for clarity and readability, primarily through plain-language edits and structural reorganization.
Retained clauses and provisions, with no changes in text:
- 52.207-4 Economic Purchase Quantity—Supplies
- 52.207-5 Option To Purchase Equipment
- 52.207-6 Solicitation of Offers from Small Business Concerns and Small Business Teaming Arrangements or Joint Ventures (Multiple-Award Contracts)

Removed

Section 7.105, “Contents of Written Acquisition Plans” is removed and marked “Reserved.” Relevant content will be reflected in the FAR Companion.
Section 7.200, “Scope of Subpart” regarding economic quantities of purchases, has been deleted and marked “Reserved” as it is unnecessary.
Section 7.204, “Responsibilities of Contracting Officers” has been deleted as the content is covered by FAR 52.207-4.
Subpart 7.3, “Contractor Versus Government Performance”, and its underlying sections have been deleted and marked “Reserved” as Congress has consistently placed a statutory hold on A-76 competitions since 2008.
The following clause and provisions are removed:
- 52.207-1 Notice of Standard Competition
- 52.207-2 Notice of Streamlined Competition
- 52.207-3 Right of First Refusal of Employment

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce must follow the RFO part 7 and corresponding 52 model deviation text instead of FAR part 7 and 52 as codified at 48 CFR Chapter 1. The Council’s RFO part 7 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
For new solicitations or contracts, when using any provisions or clauses that have been revised, utilize the RFO model deviation language at RFO FAR part 52.
For open solicitations or awarded contracts, the contracting officer has discretion regarding the need to enforce or amend the provisions or clauses. Note that without some of the removed provisions or clauses, the contracting officer may be required to separately address certain aspects in the contract.
Contracting activities must review templates and related standard operating procedures to align with this class 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 November 3, 2025 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.