Class deviation RFO-2025-10: FAR Class Deviation for FAR Part 10 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-10
May 22, 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 10 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
Points of Contact

1. Purpose

This memorandum approves a class deviation to Federal Acquisition Regulation (FAR) part 10 for purposes of implementing the Federal Acquisition Regulatory Council’s (the Council’s) model deviation text to FAR Part 10.

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 FAR.

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 10, concerning Market Research, has been updated to offer acquisition teams more flexibility in their research methods:

Greater flexibility in techniques: The FAR no longer lists specific market research considerations or techniques that must be used.
- You have the flexibility to choose the market research method that best fits your needs. For example, you might host a reverse industry day or expert panel. This allows industry experts to share their perspectives, commercial practices, and experiences with the acquisition team.
- For more information on reverse industry days, and to read about more good market research techniques, check out the “Smart Accelerators” in the Practitioner Album available at Acquisition.gov/far-overhaul.
Competition requirements remain: Acquisition professionals must still comply with the Competition in Contracting Act (CICA) (41 U.S.C.§ 3301 et seq), which may necessitate market research.
Flexibility at all dollar values: Acquisition professionals can apply market research concepts to procurements of any size.
While FAR clause 52.210-1 Market Research is not required by statute, across Government, it has been retained as essential to the acquisition process.

Statutory requirements retained in the RFO FAR part 10 model deviation include, but are not limited to, the following:

10 U.S.C. §3453, Preference for Commercial Products and Commercial Services
41 U.S.C. §3306, Planning and Solicitation Requirements
41 U.S.C. § 3307, Preference for Commercial Products and Commercial Services
41 U.S.C.§ 1703 note, Effective Communication Between Government and Industry; inclusive of 41 U.S.C.§ 3301 et seq and 41 U.S.C.§ 2101 et seq.

Change	Description
Retained	Subparts “10.001 Policy” and “10.002 Procedures” are combined and streamlined to remove duplicative and discretionary guidance. FAR clause 52.210-1, Market Research, in solicitations and contracts for noncommercial acquisitions over $6 million. Language encouraging exchanges with industry is moved from FAR part 1 to FAR part 10.
Removed	Requirements to consider various issues in market research, including for consolidation or bundling procurements are removed. Content stemming from 15 U.S.C. 644(e) and 15 U.S.C. 657(q) is mandatory, however the requirement is covered in FAR part 7. Requirements for disaster relief purchasing are removed. Content stemming from 6 U.S.C. 796 is mandatory, however the requirement is covered in FAR part 26.

Change

Description

Retained

Subparts “10.001 Policy” and “10.002 Procedures” are combined and streamlined to remove duplicative and discretionary guidance.
FAR clause 52.210-1, Market Research, in solicitations and contracts for noncommercial acquisitions over $6 million.
Language encouraging exchanges with industry is moved from FAR part 1 to FAR part 10.

Removed

Requirements to consider various issues in market research, including for consolidation or bundling procurements are removed. Content stemming from 15 U.S.C. 644(e) and 15 U.S.C. 657(q) is mandatory, however the requirement is covered in FAR part 7.
Requirements for disaster relief purchasing are removed. Content stemming from 6 U.S.C. 796 is mandatory, however the requirement is covered in FAR part 26.

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce shall follow the RFO part 10 model deviation text instead of FAR part 10 as codified at 48 CFR Chapter 1. The Council’s RFO part 10 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 remove unnecessary process 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, 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. Points of Contact

Questions regarding this class deviation may be directed to the GSA Acquisition Policy Division at GSARPolicy@gsa.gov.