Class Deviation RFO-2025-09: FAR Class Deviation for FAR Part 9 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-09
August 19, 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 9 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 9 for purposes of implementing the FAR Council’s model deviation to FAR part 9.

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 9 - largely based in statute - establishes the standards and procedures for determining contractor responsibility and eligibility for federal contracts, ensuring that only qualified, reliable contractors receive government awards. It protects the government’s interests by requiring contractors to demonstrate they have adequate financial resources, technical capability, integrity, and past performance to successfully fulfill contract requirements.

Statutory requirements and presidential directives retained in the RFO FAR part 9 model deviation include, but are not limited to, the following:

6 U.S.C. § 395, Prohibition on Contracts with Corporate Expatriates
10 U.S.C. § 3206 and 41 U.S.C. § 3306, Planning and Solicitation Requirements
10 U.S.C. § 3243 and 41 U.S.C. § 3311, Qualification Requirements
22 U.S.C. § 2593e, Measures Against Activities that Violate Arms Control Treaties
41 U.S.C. § 113, Responsible Source
41 U.S.C. § 2303, Ethics Safeguards Related to Contractor Conflicts of Interest
41 U.S.C. § 2304, Conflict of Interest Standards for Consultants
41 U.S.C. § 2313, Database for Suspension and Debarment Officials
Pub. L. 103-355 Sec 2455, Uniform Suspension and Debarment
Pub. L. 111-84 Sec 815, Clarification of Uniform Suspension and Debarment Requirement
Pub. L. 117-324, Preventing Organization Conflicts of Interest in Federal Acquisition
E.O. 12549 and E.O. 12689, Debarment and Suspension

Change	Description
Retained	Subparts 9.1, 9.2, and 9.3 are significantly streamlined with some shifting and reorganizing of sections and subsections throughout. Subparts 9.4 “Debarment, Suspension, and Ineligibility”, and 9.5 “Organizational and Consultant Conflicts of Interest”, are retained and updated with plain language edits. All existing provisions and clauses are retained (or remain reserved if previously reserved) with no changes to the text.
Removed	Section 9.000 “Scope of Part”, has been removed as the language was duplicative. The definition of “Surveying activity” has been removed from section 9.101, “Definitions”. Section 9.104-2 “Special Standards”, has been removed and may be moved to non-regulatory content. Section 9.106 “Preaward Surveys”, has been removed and may be moved to non-regulatory content. This includes the reference to utilizing the Standard Form 1403, Preaward Survey of Prospective Contractor (General). Section 9.107 “Surveys of Nonprofit Agencies Participating in the AbilityOne Program” has been removed. The AbilityOne Program is covered in part 8 and nuances of pre-award surveys relevant to the AbilityOne Program are now covered in non- regulatory content. Subpart 9.6 “Contractor Team Arrangements”, has been removed and may be moved to non-regulatory content. Subpart 9.7 “Defense Production Pools and Research and Development Pools”, has been removed and may be moved to non-regulatory content.

Change

Description

Retained

Subparts 9.1, 9.2, and 9.3 are significantly streamlined with some shifting and reorganizing of sections and subsections throughout.
Subparts 9.4 “Debarment, Suspension, and Ineligibility”, and 9.5 “Organizational and Consultant Conflicts of Interest”, are retained and updated with plain language edits.
All existing provisions and clauses are retained (or remain reserved if previously reserved) with no changes to the text.

Removed

Section 9.000 “Scope of Part”, has been removed as the language was duplicative.
The definition of “Surveying activity” has been removed from section 9.101, “Definitions”.
Section 9.104-2 “Special Standards”, has been removed and may be moved to non-regulatory content.
Section 9.106 “Preaward Surveys”, has been removed and may be moved to non-regulatory content. This includes the reference to utilizing the Standard Form 1403, Preaward Survey of Prospective Contractor (General).
Section 9.107 “Surveys of Nonprofit Agencies Participating in the AbilityOne Program” has been removed. The AbilityOne Program is covered in part 8 and nuances of pre-award surveys relevant to the AbilityOne Program are now covered in non- regulatory content.
Subpart 9.6 “Contractor Team Arrangements”, has been removed and may be moved to non-regulatory content.
Subpart 9.7 “Defense Production Pools and Research and Development Pools”, has been removed and may be moved to non-regulatory content.

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce must follow the RFO part 9 instead of FAR part 9 as codified at 48 CFR chapter 1. The Council’s RFO part 9 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
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.