Deviation Tracker: A Live Record of the FAR Overhaul

From the Essential Guide to the FAR Overhaul Crisis

For an analysis of what these changes mean for your business, read our Small Business Impact Deep Dive.

This tracker documents the two-level assault on federal regulations. First, we show the top-level changes made by the FAR Council. Then, we track the individual Class Deviation Memos filed by each federal agency to implement—and sometimes alter—those changes. This is a living record, updated as new rules and memos are issued.

Important Note on Implementation

The FAR Council has stated: "Agencies are expected to adopt and start using the model deviation text within 30 days of when the FAR Council issues the text." Agencies are explicitly advised they are NOT to wait for the completion of the overhaul of all FAR Parts or for publishing in the Federal Register, breaking with Administrative Procedures Act (APA) requirements.

FAR Part 1: Federal Acquisition Regulations System

Impact: Removes the legal infrastructure for public transparency.

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FAR Part 10: Market Research

Impact: Directly disables the Rule of Two by removing mandatory small business market research.

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FAR Part 11: Describing Agency Needs

Impact: Allows agencies to write requirements implicitly tailored for large firms.

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FAR Part 18: Emergency Acquisitions

Impact: Allows agencies to bypass SB protections during emergencies.

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FAR Part 34: Major System Acquisition

Impact: Locks small businesses out of major, long-term government programs.

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FAR Part 39: Acquisition of IT

Impact: Favors large-scale enterprise IT solutions over agile small business tech.

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FAR Part 43: Contract Modifications

Impact: Eases adding work to existing large contracts (scope creep) instead of new competition.

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FAR Part 52: Solicitation Provisions and Contract Clauses

Impact: Makes protections legally unenforceable by removing them from contracts.

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Table of Contents

Appendices & Key Resources