Federal contracting has always required commercial companies to adapt.
Standard services are often reshaped around government-specific procedures. Familiar pricing models give way to additional documentation. Solicitation requirements are spread across multiple parts of the Federal Acquisition Regulation, forcing agencies and contractors to spend significant time determining which rules apply before they can focus on the work itself.
The Federal Acquisition Regulatory Council is now proposing a different approach: bring federal buying closer to the way the commercial marketplace already operates.
On September 18, 2026, the Office of Federal Procurement Policy, Department of Defense, General Services Administration, and NASA published a major package of proposed FAR revisions covering Parts 8, 12, 13, 15, 38, 44, 51, and 52. The proposal is part of the formal rulemaking phase of the Revolutionary FAR Overhaul established under Executive Order 14275, Restoring Common Sense to Federal Procurement. Public comments on this proposed rule are due October 19, 2026. Federal Register
The proposal is not yet final. However, it provides a clear view of where federal procurement is heading: fewer duplicative requirements, greater reliance on commercial practices, more use of existing contract vehicles, and a simpler path from requirement development through award and performance.
For prime contractors, subcontractors, and commercial firms considering federal work, that creates opportunity. It also places a greater premium on preparation.
Commercial Buying Becomes the Starting Point
Federal policy has long directed agencies to acquire commercial products and services when they can meet the government’s needs. The proposed overhaul does not create that principle from scratch. It makes the requirement more direct and more visible.
The revised FAR Part 12 would state that agencies must acquire commercial products or commercial services when they are available to meet the requirement. It would also direct prime contractors and subcontractors at all tiers to incorporate commercial products, commercial services, and nondevelopmental items to the maximum extent practicable. Federal Register
That distinction matters.
Commercial acquisition would no longer appear primarily as one option among several complicated buying pathways. It would become the clear starting point for determining how an agency should satisfy its need.
For commercial firms, this could reduce some of the friction that has historically made federal contracting difficult to enter. Agencies would be encouraged to begin with products, services, pricing structures, warranties, quality processes, and licensing terms already used in the marketplace rather than automatically creating a government-specific version of the same requirement.
But commercial-first does not mean compliance-free.
Contractors will still need to demonstrate that their offering qualifies as commercial, that their pricing is supportable, and that they can meet applicable federal requirements. The advantage will go to companies that can explain their commercial model clearly and connect it directly to the agency’s mission.
One Commercial Procurement Lifecycle
One of the most practical changes is the proposed restructuring of FAR Part 12 around the actual phases of an acquisition.
The new structure would organize commercial buying into:
- Presolicitation activities
- Solicitation, evaluation, and award
- Post-award administration
- Micro-purchases
Procedures currently spread across FAR Parts 5, 12, and 13 would be consolidated into a more complete commercial acquisition framework. The FAR Council describes the revised Part 12 as a “one-stop shop” intended to reduce the need for contracting officers to reconcile overlapping requirements across multiple parts of the regulation. Federal Register
The proposal would also place the authority to use simplified procedures for commercial acquisitions valued up to $9 million directly within Part 12. That ceiling would increase to $15 million for certain contingency, emergency, disaster response, and national security-related acquisitions. Federal Register
In practice, this could lead to simpler solicitations, more combined synopsis and solicitation notices, fewer unnecessary proposal requirements, and shorter acquisition timelines.
That is good news for contractors prepared to respond quickly.
It could be more challenging for firms that wait until a solicitation is released to begin identifying personnel, validating pricing, developing teaming arrangements, or collecting past-performance information. A streamlined federal process will not necessarily give contractors more time. In many cases, it may reduce it.
Commercial Solicitations Could Become Leaner
The proposed overhaul also addresses one of the most persistent frustrations in commercial federal contracting: the number and complexity of contract clauses.
The rule would retain the primary commercial solicitation, evaluation, and terms-and-conditions provisions at FAR 52.212-1, 52.212-2, and 52.212-4. However, it proposes removing the broad representations and certifications provision at 52.212-3 and the omnibus clause at 52.212-5.
Instead of requiring contractors to work through incomplete lists of potentially applicable clauses, contracting officers and agency clause systems would be responsible for identifying the provisions that apply to each acquisition. Adding a clause that is not prescribed for commercial products or services would generally require an approved deviation. Federal Register
The intended result is fewer unnecessary clauses and less uncertainty about which requirements apply.
That does not reduce the importance of contract review. Contractors will still need to evaluate every solicitation, modification, task order, and flowdown requirement carefully. The difference is that commercial solicitations may become more focused on the requirements that actually apply rather than presenting contractors with a broad collection of clauses to interpret on their own.
Existing Contract Vehicles Will Matter Even More
The overhaul is not only about how agencies write solicitations. It also changes the order in which they consider available buying channels.
Under the proposed FAR Part 8, agencies would first use an existing governmentwide contract or blanket purchase agreement if it has been designated as a required-use vehicle. If no suitable required-use vehicle exists, agencies would consider a best-in-class vehicle. If neither is appropriate, they would still be expected to consider another existing governmentwide contract before creating a new contract vehicle. Federal Register
The proposal would also remove FAR Part 38 because Federal Supply Schedule policies are already administered through the General Services Administration Acquisition Regulation. This does not eliminate the Federal Supply Schedule program. It removes duplicative FAR coverage while retaining GSA’s Schedule ordering procedures. Federal Register
For industry, the practical message is clear: contract vehicle strategy will become increasingly important.
Companies with direct access to the appropriate Schedule, governmentwide acquisition contract, indefinite-delivery vehicle, or blanket purchase agreement may be better positioned for streamlined opportunities. Companies without that access may need to develop relationships with qualified vehicle holders earlier.
For subcontractors and specialized small businesses, teaming should not begin after an opportunity is released. It should be part of ongoing business development and capture planning.
Subcontracting Is Being Reorganized, Not Eliminated
The proposed revisions would consolidate commercial subcontracting requirements in FAR Part 44 and connect them more clearly to the post-award provisions in Part 12.
Importantly, the FAR Council states that the Part 44 changes are intended to revise, reorganize, streamline, and clarify existing policies without substantively changing them. Requirements involving subcontract consent, contractor purchasing systems, competition, and applicable clause flowdowns would remain. Federal Register
Prime contractors would still be required to manage subcontractors responsibly. Commercial product and service subcontracts would still be subject to specified flowdown clauses, and primes would still be expected to use commercial products, services, and nondevelopmental items throughout the supply chain when practicable. Federal Register
The regulatory structure may become easier to navigate, but the underlying responsibility remains.
Primes should continue evaluating subcontractor qualifications, pricing, compliance systems, past performance, and ability to mobilize. Subcontractors should be prepared to demonstrate more than technical capability. They must be able to show that they can perform within the prime contractor’s reporting, safety, quality, schedule, and contract administration requirements.
What This Could Mean for Construction and Engineering
The overhaul may have particular significance for the construction, engineering, environmental, and infrastructure markets.
A related proposed revision would allow certain construction services to be treated as commercial services when they are sold competitively in substantial quantities in the commercial marketplace, based on established market or catalog pricing, and under standard commercial terms.
A contracting officer would still have to determine that the specific construction requirement meets the commercial-service definition. Even when Part 12 procedures are used, applicable FAR Part 36 construction requirements would continue to apply. Federal Register
Not every federal construction or engineering scope will qualify. Highly specialized, site-specific, mission-sensitive, or architect-engineer work may continue to require other acquisition procedures.
However, repeatable and commercially established services may become easier to acquire through streamlined methods. That could include certain inspection, testing, maintenance, remediation, field support, project controls, environmental monitoring, logistics, and technical support functions when those services are routinely offered in the commercial marketplace.
Contractors should begin identifying which capabilities fit that model and what evidence supports the determination. Established pricing, commercial customers, standard service descriptions, customary contract terms, and documented market demand may all become more important.
What Primes and Subcontractors Should Do Now
Because the rule is still proposed, contractors should not assume that every provision will be adopted exactly as written. They can still begin preparing for the direction of travel.
Define which offerings are truly commercial. Companies should document how their products and services are sold outside the federal market, including pricing methods, standard terms, warranties, quality controls, and expected outcomes.
Review contract vehicle access. Contractors should identify which required-use, best-in-class, Schedule, GWAC, IDIQ, and agency-specific vehicles are most relevant to their services. Firms that do not hold those vehicles should strengthen relationships with companies that do.
Build proposal readiness before the solicitation. Current resumes, labor categories, pricing, project examples, safety information, quality processes, and mobilization plans should be maintained in a reusable format.
Review subcontracting templates and flowdowns. Reorganization does not eliminate subcontract management responsibilities. Primes and subcontractors should confirm that their agreements, purchasing procedures, and compliance reviews remain aligned with applicable clauses.
Consider submitting public comments. Contractors have until October 19, 2026, to comment on FAR Case 2026-003. Organizations that identify unclear language, unintended operational burdens, or practical implementation concerns have an opportunity to provide input before the final rule is developed. Federal Register
Readiness Will Become the Real Differentiator
The proposed overhaul is designed to make federal acquisition faster and easier to navigate.
That does not mean execution will become less demanding.
As procurement timelines shorten, agencies and prime contractors will need partners capable of moving quickly from opportunity to performance. Specialized personnel must be identified. Pricing must be supportable. Compliance requirements must be understood. Subcontracting relationships must be established. Mobilization plans must be credible.
The companies best positioned to benefit will be those that combine commercial agility with federal execution discipline.
How Certis Government Services Can Help
Certis Government Services supports prime contractors, agencies, and project partners across the federal acquisition lifecycle, from pre-award planning, proposal and pricing support through mobilization, project execution, surge support, and contract closeout.
As a certified small business supporting construction, engineering, environmental, infrastructure, emergency management, and disaster recovery programs, CGS provides project-ready resources that can be deployed across CONUS and OCONUS requirements. Its capabilities include project management, construction management, quality and safety support, project engineering, environmental compliance, scheduling, field services, and contract administration.
As federal procurement becomes more commercially focused, primes will need partners that can respond with the speed of the commercial market while still operating within the requirements of federal contracting.
That is where an agile, mission-ready small business can create real value.
The FAR overhaul may simplify the buying process. Success will still depend on having the right team ready to perform when the opportunity arrives.