FAR’s Plain-Language Overhaul Is Here: What Small Contractors Need to Know Now

The federal government just dropped a sweeping rewrite of four key parts of the FAR, and while it won’t shake the ground under your feet, it does shift the terrain. The changes are designed to streamline language, not add new rules. But if you’re a small business working in federal procurement, it’s time to update your playbooks.

Effective November 3, 2025, new “model deviation” texts for FAR Parts 3 (ethics), 17 (special contracting methods), 27 (IP/data rights), and 45 (government property) will be in use across GSA, DoD, NASA, and other agencies under class deviations. These aren’t optional rewrites, contracting officers will start using the new language immediately. And while no new obligations are introduced, if your proposal templates, internal policies, or clause libraries still reference deleted provisions, you’re setting yourself up for compliance headaches.

What Changed and What Didn’t

At its core, this overhaul is a plain-language cleanup. Executive Order 14275 and OMB Memo M-25-26 called for a government-wide push to eliminate confusing, outdated, or duplicative FAR content. The result? Four major parts just got reorganized and stripped of obsolete clauses.

Here’s the snapshot:

• Part 3 (Ethics/Conflicts of Interest): Retains all core ethics, kickback, and conflict rules. Deletes Recovery Act whistleblower clause (52.203-15) and an old antitrust reporting rule. You still need COI disclosures, ethics training, and NFCA compliance.

• Part 17 (Special Contracting Methods): Same option and multiyear rules, but reorganized. No changes to J&A requirements, thresholds, or procedures.

• Part 27 (IP/Data Rights): Key clauses for “existing works” (52.227-18) and proposal data (52.227-23) are removed. SBIR protections (52.227-20) remain, but DoD now allows 20 years of protection under DFARS 252.227-7018.

• Part 45 (Government Property): No substantive changes. But DoD now mandates use of the GFP Module under DFARS 252.245-7005 for tracking property use, loss, and disposal.

All of this takes effect via deviation starting 11/03/2025, with formal FAR rulemaking still to follow.

Why This Matters for Small Businesses

If you’re a small prime or subcontractor, especially one working with SBIR, GSA, or DoD, this update affects your:

• Proposal templates and clause libraries: You’ll need to remove deleted clauses (e.g., 52.227-18) and ensure the correct ones are flowed down.

• Subcontractor agreements: If you use SBIR data or government property, you must update your flowdown clauses to match the new DFARS and FAR interpretations.

• Internal ethics and COI policies: Outdated language could cause confusion or non-compliance. If your team still trains on 52.203-15, it’s time to cut it.

• Data rights strategy: The government no longer receives automatic licenses to “existing works.” You need to negotiate rights proactively and mark data accurately,  especially in SBIR work.

• Property management systems: If you're in DoD contracts and not using the PIEE GFP Module, you’re likely out of compliance. Seven-day reporting windows are now the norm.

What You Should Do Next

Use the next 45 days to get your house in order. Here's your action checklist:

1. Ethics and Compliance

• Update your ethics code and training modules to reflect new Part 3 language

• Remove references to 52.203‑15

• Confirm your COI forms match the new plain-language definitions

2. Contracts and Templates

• Audit your clause libraries: remove 52.203-15, 52.227-18, and 52.227-23

• Make sure proposal checklists reference current clause numbers and cross-references

• Add DFARS 252.227‑7018/7019 to SBIR subcontract flowdowns

3. Data and IP Protections

• Ensure you’re still using 52.227-14 as the base clause

• Carefully mark all deliverables per 27.404‑5, unmarked means unlimited use by the government

• Renegotiate rights for any “existing works” used in new contracts

4. GFP (Government Property)

• Adopt PIEE GFP Module reporting if doing DoD work, required under DFARS 252.245‑7005

• Maintain clear inventory records and property loss logs

• Ensure your team understands the unchanged rules under FAR Part 45

5. Train Your Team

• Contracts staff: micro-training on new clause numbers

• Engineers: refreshers on marking data rights

• Property managers: walkthrough of PIEE GFP usage

• Program managers: SBIR data timelines and subcontract flowdowns

6. Submit Comments by 10/27/2025
You have until October 27 to comment on the model texts. If you have concerns about how the changes impact SBIR protections, IP negotiations, or ethics clarity, this is your shot to shape the final rulemaking. Go to Regulations.gov and search for the FAR Overhaul dockets for Parts 3, 17, 27, and 45.

Final Takeaway

This isn’t one of those “nice to know” updates. If you don’t realign your documentation, training, and proposal materials with the new FAR structure, you’ll run into problems with contracting officers; or worse, misstep on a compliance audit.

The good news? This overhaul is actually an opportunity. With clearer rules and fewer legacy clauses, your team can train faster, flow down more accurately, and protect your IP more strategically.

Want to dig deeper into how these updates intersect with your certification status or proposal workflows? Check out our post on Crafting a Winning Government Contract Proposal: Key Steps and Strategies, it’ll help you shore up the basics before things get messy.

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