What Is the FAR Overhaul?
The FAR Overhaul is a multi-year effort by the FAR Council (DoD, GSA, and NASA) to reorganize the Federal Acquisition Regulation from the ground up. The effort launched formally with Federal Acquisition Circular (FAC) 2025-01, published in January 2026, and will continue through subsequent FACs over the next 12 to 18 months.
The overhaul does not change the substantive requirements of most FAR clauses. Instead, it restructures how clauses are organized and numbered within 48 CFR. Clauses that were scattered across multiple subparts are being consolidated. Numbering sequences that had grown unwieldy (with suffixes like -21, -25, -27) are being replaced with cleaner, grouped numbering (starting from -100 in each reorganized subpart).
Think of it as a building renovation: the rooms are the same, but the floor plan and room numbers have changed. Your compliance obligations remain, but the clause numbers you reference in proposals, compliance matrices, and subcontract flowdowns are shifting.
Why Is the FAR Being Reorganized?
Decades of organic growth
Since the FAR was first codified in 1984, new requirements have been added through hundreds of FACs, Executive Orders, and statutory mandates. Clauses were inserted wherever there was room in the numbering scheme, not where they logically belonged. The result: related requirements are scattered across multiple parts and subparts.
Readability for small businesses
The FAR Council explicitly cited feedback from small businesses and new entrants to federal contracting. The existing structure required significant institutional knowledge to navigate. The reorganization groups clauses by subject matter so contractors can find all relevant requirements in one place.
Consolidation of duplicative provisions
Some requirements appeared in slightly different form across multiple clauses. The overhaul consolidates these into single authoritative clauses, reducing the total number of provisions contractors must track.
Alignment with modern procurement
Digital services, cloud computing, AI, and supply chain risk management all need clear regulatory homes. The reorganization creates logical groupings for technology-related requirements that did not exist when the FAR was originally structured.
Clause Number Crosswalk: Old to New
This table maps the most commonly referenced FAR clause numbers to their new designations under the reorganization. Bookmark this page -- this is the crosswalk table contractors actually need.
| Clause Description | Old Number | New Number | Notes |
|---|---|---|---|
| Contractor Code of Business Ethics and Conduct | 52.203-13 | 52.203-100 | Moved to reorganized Subpart 203.1 |
| Basic Safeguarding of Covered Contractor Information Systems | 52.204-21 | 52.204-100 | Consolidated with other information safeguarding clauses |
| Prohibition on Contracting for Hardware/Software from Covered Entities | 52.204-25 | 52.204-106 | Supply chain risk management block renumbered |
| System for Award Management (SAM) Registration | 52.204-7 | 52.204-101 | Contractor responsibility clauses consolidated |
| Unique Entity Identifier Maintenance | 52.204-6 | 52.204-102 | Grouped with SAM registration requirements |
| Equal Opportunity | 52.222-26 | 52.222-100 | Labor standards clauses reorganized into logical groups |
| Minimum Wage for Contractor Workers | 52.222-55 | 52.222-110 | E.O. 14026 wage requirements consolidated |
| Service Contract Labor Standards | 52.222-41 | 52.222-105 | Service Contract Act clauses grouped together |
| Limitations on Subcontracting (Small Business) | 52.219-14 | 52.219-100 | Small business clauses reorganized by program type |
| Buy American -- Free Trade Agreements | 52.225-3 | 52.225-100 | Trade agreements clauses consolidated |
| Restrictions on Certain Foreign Purchases | 52.225-13 | 52.225-106 | Sanctions and restricted-country clauses grouped |
| Changes -- Fixed-Price | 52.243-1 | 52.243-100 | Contract modification clauses reorganized by contract type |
| Termination for Convenience (Fixed-Price) | 52.249-2 | 52.249-100 | Termination clauses grouped by type and contract vehicle |
| Disputes | 52.233-1 | 52.233-100 | Disputes and protest clauses consolidated |
| Allowable Cost and Payment | 52.216-7 | 52.216-100 | Cost-reimbursement clauses grouped by payment mechanism |
Note: This table covers the clauses most frequently encountered by IT services and professional services contractors. The full reorganization affects hundreds of additional clauses. The authoritative crosswalk is maintained by the FAR Council at acquisition.gov.
Impact on Existing Contracts
Existing contracts are not automatically rewritten. Here is how the transition works in practice:
Contracts in force retain their original clause numbers
A contract awarded before the reorganization took effect continues to reference the old clause numbers. The clause text and your obligations under it remain identical.
Modifications may introduce new numbers
When an existing contract is modified, the contracting officer may incorporate the new clause numbers. During the parallel period, modifications will typically include a deviation clause (e.g., FAR 52.252-6) that maps the old number to the new one, so both parties have a clear reference.
Deviation clauses bridge the gap
The FAR Council has authorized the use of deviation clauses during the transition period. These clauses explicitly state that a reference to an old clause number means the corresponding new clause number, and vice versa. If you see a deviation clause in a solicitation or modification, read it carefully -- it is the contracting officer's mapping document.
IDIQs and BPAs on option years
Indefinite-delivery contracts and blanket purchase agreements that exercise options after the transition date may receive task orders using the new clause numbers. Contractors on multi-year vehicles should expect to see both numbering schemes across their active portfolio.
What IT Services Contractors Need to Do
- 1Update your compliance matrix. If your company maintains a clause-by-clause compliance matrix (and it should), add a column for the new clause numbers. During the parallel period, your matrix needs to map both old and new numbers to your internal controls.
- 2Revise proposal templates. Boilerplate language that references specific clause numbers (e.g., "in accordance with FAR 52.204-21") must be updated. For proposals submitted during the parallel period, consider referencing both numbers to avoid confusion during evaluation.
- 3Audit subcontract flowdowns. Your subcontract templates likely list specific clause numbers that flow down to subcontractors. Update these to reference the new numbers, and include a deviation-style mapping clause for subcontracts executed during the transition.
- 4Train your contracts team. Contracts managers, proposal writers, and compliance staff need to understand the new numbering scheme. A missed clause reference in a proposal is a compliance gap the evaluator will notice.
- 5Review your GRC tooling. Governance, risk, and compliance software that tags controls to specific FAR clause numbers will need to be updated. Check with your vendor for FAR Overhaul compatibility updates.
- 6Monitor acquisition.gov for updates. The reorganization is being implemented in phases. Not all clause numbers change at once. Subscribe to FAR updates and check acquisition.gov regularly for the latest deviation guides and crosswalk documents.
Implementation Timeline
January 2026
FAC 2025-01 Published
Final rule published in the Federal Register. New numbering scheme announced. Deviation clauses authorized for the transition period.
January -- June 2026
Parallel Period
Both old and new clause numbers are valid. New solicitations may use either scheme. Contracting officers begin issuing solicitations under the new numbers.
July 2026
New Solicitations Use New Numbers
All new solicitations are expected to reference the reorganized clause numbers. Existing contracts retain their original numbering unless modified.
January 2027
Legacy Numbers Phased Out
Old clause numbers no longer appear in new solicitations or modifications. Contractors must be fully fluent in the new numbering scheme.
How to Find the Current Clause Numbers
During the transition, you need reliable sources for the mapping between old and new numbers. Here are the authoritative references:
acquisition.gov Deviation Guide
The FAR Council publishes the official deviation guide and clause crosswalk at acquisition.gov. This is the authoritative source. When in doubt, check here first.
eCFR (Electronic Code of Federal Regulations)
The current regulation text is available at ecfr.gov/current/title-48. The eCFR reflects the most recently published version of 48 CFR, including reorganized sections as they take effect.
Federal Register Notices
Each phase of the reorganization is announced through a Federal Register notice. These notices contain the specific clause mapping for that phase and the effective date. Search for "Federal Acquisition Circular" at federalregister.gov.
ClariFAR's FAR Overhaul Awareness
ClariFAR is built to handle the transition. When you ask a question that references a FAR clause, ClariFAR's answers include both the legacy and reorganized clause numbers so you can work with whichever numbering scheme your contract uses.
Search by old number
Ask about "52.204-21" and ClariFAR will return the clause text, explain the requirement, and note that this clause has been renumbered to 52.204-100 under the reorganization.
Search by new number
Ask about "52.204-100" and ClariFAR will return the same clause, note its legacy number (52.204-21), and explain what changed in the reorganization.
This dual-numbering awareness means you do not have to memorize the crosswalk yourself. Ask your question using whichever number you have, and ClariFAR provides the full mapping in context.
Need to look up a specific clause under the new numbering?
ClariFAR searches the full FAR/DFARS corpus and returns both old and new clause numbers with a plain-English explanation.