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ARTICLE · 18 SEPTEMBER 2026

Revolutionary FAR Overhaul (RFO) Update: Second Batch Of Proposed Rules Released

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United StatesStrategy
Nikole Snyder
Nikole Snyder
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On September 18, 2026, the Revolutionary FAR Overhaul (“RFO”) continued its rulemaking phase with the release of a second batch of four proposed rules (the “Proposed Rules”). Collectively, the Proposed Rules cover an additional 16 parts of the FAR (plus associated Part 52 clauses). The Proposed Rules are available here: FAR Case 2026-003, FAR Case 2026-006, FAR Case 2026-010, and FAR Case 2026-011. Comments for all four New Proposed Rules are due by October 19, 2026.

Where Are We In The RFO Process?

With the June 23, 2026 publication of the first four proposed rules in the Federal Register (see our blog here), we entered Phase 2 of the RFO process – the official rulemaking phase – where the FAR Council will eventually publish all FAR Parts as proposed rules, solicit feedback from industry, and then issue final rules. The RFO Phase 2 rule-making process has been organized in 12 FAR Cases. The second batch of four proposed rules was released last night, continuing that process. If

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