In November 2025, the Department of War (DOW) announced its blueprint for its Acquisition Overhaul, and savvy defense contractors took note of DOW’s plan to realign its processes with its goals—namely, accountability, speed, and industry investment. In concert with the broader Revolutionary FAR Overhaul (RFO), DOW is now implementing a sweeping rewrite of the Defense Federal Acquisition Regulation Supplement (DFARS). In this blog, we provide an overview of how the DFARS rollout will occur and some key insights on a few of the class deviations that are already in effect—many of which are changing compliance obligations for government contractors now, not later. For more information on the DOW Acquisition Overhaul, click here to access our webinar on the topic, click here for Parts 1-3 of this series, and for more on the RFO, click here.
The Process
Revising the acquisition regulations that govern defense contracting has been on DOW’s agenda since at least April 2025, when President Trump issued Executive Orders (EO) 14265 and 14275 titled “Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base” and “Restoring Common Sense to Federal Procurement,” respectively. EO 14275 precipitated the RFO, which the FAR Council and Office of Federal Procurement Policy bill as the “first-ever comprehensive overhaul of the FAR.” The stated goal of the RFO is to “return the FAR to its statutory roots, rewrite it in plain language, and remove most non-statutory rules” to bring about “faster acquisitions, greater competition, and better results.”
Accordingly, on December 19, 2025, DOW’s Principal Director of Defense Pricing, Contracting, and Acquisition Policy issued a memo that explained changes coming to the DOW’s acquisition process to maximize “acquisition flexibility through reduced regulations and processes,” pursuant to Executive Orders 14265 and 14275. Specifically, this memo laid out a two-phase plan:
- Phase 1: DOW issued a series of class deviations revising multiple DFARS parts on an interim basis. These deviations immediately replaced existing regulatory text and had an effective date of February 1, 2026.
- Phase 2: DOW will hold a notice-and-comment rulemaking period, which is a formal process where the government will publish proposed rules for public comment. According to the memo, this period will extend throughout 2026.
Notable Changes
It is important to note that the DFARS Overhaul is happening in real time. Defense contractors need to keep up with the changes and ensure their companies are doing what it takes to comply with any new regulations. As of the date of this blog post, there have been 42 class deviations (this number keeps climbing, so click here for a link to DOW’s most updated information). Here are a few of the most notable so far:
- Part 203: DFARS 203.906 revises whistleblower procedures. Previously, a whistleblower could bring an action in district court if the head of the agency failed to issue an order on a complaint within a certain period and if “there [was] no showing” that the delay is due to bad faith on the part of the complainant. Now, however, the DFARS replaces the requirement for there to be “no showing” with a requirement that “no evidence exists” that the delay is due to bad faith. While seemingly innocuous, this change may very well alter the standard for when a contractor can bring an action in district court.
- Part 205: This part of the DFARS refers to publicizing contract actions. While the changes here are more organizational than substantive, it is worth noting DFARS 205.205-70, which previously required the DOW to publish its intent to bundle requirements, no longer exists. This may be of little surprise as delivering support to the warfighter with speed is a hallmark of DOW’s Acquisition Overhaul, and removing this administrative step may allow for more services and supplies to be purchased in one acquisition.
- Part 219: While there are minimal substantive changes to this section, it is worth noting because it is such a critical section of the DFARS for small businesses. DOW reorganized DFARS Part 219 to align with the RFO’s update to FAR Part 19, changing it from a topic-based structure into lifecycle subparts: Subpart 219.1 (Presolicitation), Subpart 219.2 (Evaluation and Award), and Subpart 219.3 (Postaward).
Key Takeaways
- This is happening in real time and defense contractors must adapt in real time. With many class deviations already in effect, contractors should update internal compliance matrices and revise contract agreements with the new DFARS parts where applicable. As further changes occur, contractors should periodically review these documents to ensure compliance.
- The notice-and-comment rulemaking period will occur throughout the year. Contractors should take this opportunity to voice their concerns and thoughts to keep the DOW informed as they revise the DFARS. This administrative period is a critical part of effective governance and requires input from the industry to make the best decisions.
- More changes could be on the horizon and DOW wants to hear from industry before making them. In addition to the notice-and-comment period, DOW Undersecretary of Defense for Acquisition and Sustainment, Michael P. Duffey, issued a letter on February 13, 2026, requesting industry’s suggestions for additional changes to the FAR and DFARS for what he referred to as Phase 2 of the RFO. Specifically, his letter asked industry to help acquire field technology and modernizing systems at a faster rate than U.S. adversaries, with a goal to put the acquisition system and defense industrial base on a “wartime footing” by developing surge capacity for key capabilities.
As this DFARS Overhaul unfolds incrementally, contractors should stay informed. Should you have any questions regarding the DFARS Overhaul or DOW’s Acquisition Overhaul in general, please contact Lauren Brier, Josie Farinelli, Adel Mansour, or another member of PilieroMazza’s Government Contracts Group.
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If you’re seeking practical insights to gain a competitive edge by understanding the government’s compliance requirements, tune into PilieroMazza’s podcasts: GovCon Live!, Clocking in with PilieroMazza, and Ex Rel. Radio.
