The Revolutionary FAR Overhaul deserves a place on your list

Most of the compliance world is watching CMMC right now, and rightly so. The Phase 2 timeline and the C3PAO landscape are demanding real attention.

But CMMC lives entirely in the DFARS, and while eyes have been on it, something much broader has been reshaping the FAR itself. The Revolutionary FAR Overhaul is rewriting the Federal Acquisition Regulation in its entirety, and one change many teams haven't clocked is a renumbering of provisions and clauses. The FAR Council is considering a new subpart in Part 52 and relocating every provision and clause underneath it, so a clause that sits at 52.2 today could begin with 52.4 tomorrow. If your clause matrices, templates, or compliance libraries reference the current numbering, a mapping exercise is waiting to happen.

This reaches well beyond the defense industrial base. FAR 52.204-21, "Basic Safeguarding of Covered Contractor Information Systems," establishes the 15 baseline controls for protecting Federal Contract Information, and it flows into nearly every federal contract that touches nonpublic information. Those same 15 controls are what a contractor implements to meet CMMC Level 1, so applying them satisfies both, but the two obligations are not equivalent or interchangeable.

Here's the part worth acting on: the FAR Council is actively seeking public comment on how this renumbering will affect contractors and compliance teams. That's a genuine opportunity to shape the outcome before it locks in, and windows like that don't stay open for long.

CMMC deserves the spotlight. The Revolutionary FAR Overhaul deserves a place on the list too.

Is the Revolutionary FAR Overhaul on your radar yet? If you have questions or want to think through what it means for your compliance program, reach out to me or The Vizius Group Group. We're glad to help.

#GovCon #FederalContracting #FAROverhaul #FCI #CMMC #ComplianceStrategy The Vizius Group