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Class Deviation RFO-2025-41
September 25, 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 41 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement
On this page:
This memorandum approves a class deviation to Federal Acquisition Regulation (FAR) part 41 for purposes of implementing the FAR Council’s model deviation to FAR part 41.
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:
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.
FAR part 41, Acquisition of Utility Services, has been retained, streamlined, and improved for clarity. All subparts have been retained. Plain language edits or other updates have been made throughout the part to remove unnecessary information or otherwise clarify the content. All clauses and provisions are retained.
Notably, the definition of “utility service” is updated. Services such as broadband internet and information technology services, which were nascent or nonexistent when the original regulation was drafted, are now explicitly carved out. This prevents agencies from incorrectly applying utility acquisition procedures. This change reduces the risk of improper sole-source justifications and promotes full and open competition in those dynamic markets.
Statutory requirements retained in the RFO FAR part 41 model deviation include, but may not be limited to, the following:
This class deviation applies to all GSA procurements.
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.
This class deviation is effective November 3, 2025 and remains in effect until rescinded or incorporated into the FAR.
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.
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