Class Deviation RFO-2025-46
August 18, 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 46 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 46 for purposes of implementing the FAR Council’s model deviation to FAR part 46.
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 46, Quality Assurance, has been updated for clarity and usability.
Statutory requirements retained in the RFO FAR part 46 model deviation include, but are not limited to, the following:
- 41 U.S.C. § 1711, Value Engineering
- 41 U.S.C. § 3307, Preference for Commercial Products and Commercial Services
- Pub. L. 103-355, Federal Acquisition Streamlining Act of 1994 (FASA)
- Pub. L. 112-81 Sec 818, Detection and Avoidance of Counterfeit Electronic Parts
| Change | Description |
|---|
| Retained | - Subparts 46.1, 46.2, 46.3, 46.4, 46.5, 46.6, 46.7, 46.8 and the sections therein, remain mostly intact and are streamlined, with some shifting and reorganizing of sections and subsections throughout.
- All “Definitions” at 46.101 are retained.
- All existing clauses are retained (or remain reserved if previously reserved) with no changes to the text.
|
|---|
| Removed | - Section 46.105, “Contractor Responsibilities” is deleted and marked reserved, as the content was redundant to contract clauses.
- Section 46.704, “Authority for use of warranties” is deleted and marked reserved. This section stated that warranty use must be approved by agency procedures. This language does not need to be included in the FAR.
|
|---|
This table is not an exhaustive list.
4. Instructions
- The GSA acquisition workforce must follow the RFO part 46 instead of FAR part 46 as codified at 48 CFR chapter 1. The Council’s RFO part 46 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.