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ARTICLE · 07 OCTOBER 2025

FAR Part 19 Rewrite: Key Developments For Small Business Contracting

Bass, Berry & Sims PLC
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The Federal Acquisition Regulatory (FAR) Council recently released its long-awaited overhaul of FAR Part 19, the section governing small business programs.

United StatesGovernment, Public Sector
Richard W. Arnholt
Richard W. Arnholt
Sylvia Yi
Sylvia Yi

The Federal Acquisition Regulatory (FAR) Council recently released its long-awaited overhaul of FAR Part 19, the section governing small business programs. While the rewrite is part of the Trump administration's broader initiative to reduce the FAR to statutory and "essential" provisions, the changes to Part 19 carry significant implications for both small and large contractors.

Rule of Two

Perhaps the most closely watched issue in this rewrite was the outcome of the Rule of Two, which requires that acquisitions be set aside for small businesses if the contracting officer has a reasonable expectation that two or more small businesses will submit offers and awards will be made at fair market prices. While this requirement is statutory for procurements between the micro-purchase threshold (MPT) and the simplified acquisition threshold (SAT), it is not statutory for procurements over the SAT. Effective October 1, the MPT increases to $15,000 and the SAT increases

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