FAR Overhaul + SAM.gov Consolidation: 2026 Guide
TL;DR: Three structural changes hit federal contracting in February 2026. (1) Revolutionary FAR Overhaul (RFO) Phase 1 class deviations took effect Feb 1, 2026 — 23 FAR parts have been revised through April 2026 under Executive Order 14275. (2) FPDS.gov was decommissioned Feb 24, 2026 — contract-award search now lives in SAM.gov Contracting. (3) eSRS was decommissioned Feb 20, 2026 — subcontracting plan reporting now runs through SAM.gov. If you bid on US federal contracts, your SAM.gov account is now load-bearing for more than registration. Browse US federal tenders.
If you've been doing federal contracting research the same way for the last decade — open FPDS.gov, run a search, export a CSV — you've already hit the new redirect to SAM.gov. The FAR Overhaul and the SAM.gov consolidation are separate initiatives that landed in the same window, and together they reshape three things small businesses do every week: searching past awards, complying with subcontracting reports, and reading FAR clauses in solicitations.
This guide breaks down what changed, what you have to do differently now, and what's coming next.
The Revolutionary FAR Overhaul (RFO)
Executive Order 14275, "Restoring Common Sense to Federal Procurement," was signed in April 2025 and launched the Revolutionary FAR Overhaul — the most significant rewrite of the Federal Acquisition Regulation since the FAR was first issued in 1984.
The rollout is happening in two phases:
Phase 1 — class deviations (interim). Effective February 1, 2026. Class deviations are interim rule changes that take effect immediately while formal rulemaking catches up. Per Acquisition.gov, 23 FAR parts have been released or revised through April 2026 under the RFO, including:
- FAR Part 1 (Federal Acquisition Regulations System) — issued May 2, 2025; updated March 16, 2026
- FAR Part 9 (Contractor Qualifications) — issued August 21, 2025; updated April 20, 2026
- FAR Part 12 (Commercial Products/Services) — issued August 14, 2025; updated April 20, 2026
- FAR Part 19 (Small Business) — issued September 26, 2025; updated February 20, 2026
- Parts 2–8, 10, 13–18, 22, 23 — issued May–September 2025
Phase 2 — permanent rulemaking. Notice-and-comment rulemaking is underway to make the class deviation changes permanent through the Federal Register. Exact final-rule dates are agency-specific [VERIFY: founder — confirm any agency-specific Phase 2 dates relevant to your sector against acquisition.gov/far-overhaul/announcements].
Agency deviations are widespread. As of April 2026, over 40 federal agencies have issued their own implementing guidance against the RFO parts. If you do business with a specific agency, check that agency's deviation guidance — it may modify or supplement the base FAR changes.
Browse US federal contracts now - free
Search live US federal and municipal tenders from SAM.gov in one place with plain-English summaries and free filters.
Browse US TendersWhat changed in FAR Part 19 (Small Business)
This is the part most small businesses should read first. The September 2025 issuance and February 20, 2026 update restructured FAR Part 19 around the acquisition lifecycle:
- Presolicitation — set-aside determinations, market research, NAICS code assignment
- Evaluation and Award — price evaluation preferences, certifications, sole-source authority
- Postaward — performance, subcontracting reporting (now via SAM.gov), HUBZone certification maintenance
The substance of small business programs — 8(a), HUBZone, WOSB, SDVOSB, the 23% federal small business goal — is unchanged. What changed is how the rules are organized and where the clauses live. If you maintain a proposal template with FAR Part 19 clause references, the clause numbers and section structure have shifted.
FPDS is gone — what to do instead
Decommission date: February 24, 2026, for FPDS.gov, including the public site, login, and ezSearch.
What replaced it: SAM.gov Contracting (sam.gov/contracting) is now the authoritative source for federal contract-award data — historical awards, contract modifications, and award notices. Anyone with a SAM.gov account (free, via Login.gov) can search the full dataset.
The new ezSearch is in SAM.gov. The Contract Opportunities and Contract Data sections are both inside SAM.gov now. If you were a regular FPDS user, you'll find the same award fields — award number, NAICS, set-aside code, dollar value, awardee — surfaced through the SAM.gov search interface.
ATOM feed. FPDS exposed an ATOM feed for programmatic award data. The ATOM feed retires later in fiscal year 2026 [VERIFY: founder — if your sales pipeline tooling consumes the FPDS ATOM feed, check sam.gov announcements for the exact retirement date and the replacement API endpoint].
No-login alternative. USASpending.gov continues to expose federal contract and grant data without requiring a Login.gov account. The data set is the same authoritative source; the search UI differs. For quick public lookups, USASpending.gov is still the path of least friction.
eSRS is gone — subcontracting reports moved to SAM.gov
Decommission date: February 20, 2026, for the Electronic Subcontracting Reporting System (eSRS).
What replaced it: SAM.gov now hosts the subcontracting plan reporting workflow. The compliance obligations — Individual Subcontracting Reports (ISR) for each contract, Summary Subcontracting Reports (SSR) aggregated by NAICS, and the underlying subcontracting plan documents — are unchanged. Only the system you submit them through has changed.
Action item for prime contractors with subcontracting plans:
- Confirm your SAM.gov entity registration is active and your administrator user has the subcontracting-plan role.
- Find your in-flight subcontracting plans — the ones that previously lived in eSRS — and confirm they migrated cleanly to SAM.gov. If something didn't migrate, you'll need to recreate it.
- Update internal compliance calendars to reference SAM.gov submission deadlines, not eSRS deadlines.
Action item for small business subcontractors: Your prime's subcontracting plan tracking now flows through SAM.gov instead of eSRS. The data your prime collects from you (the subcontracting commitments you fulfill) hasn't changed; the upstream filing path has.
What this means for proposal boilerplate
Three things to check in any template you use for federal proposals:
1. FAR clause references. The RFO renumbered and reorganized clauses across multiple parts. Boilerplate that cites specific FAR section numbers needs an update. Cross-check against the current FAR sections on Acquisition.gov before submission.
2. Reps and certs. The representations and certifications cycle through SAM.gov is unchanged in mechanism, but several FAR Part 4 / Part 9 / Part 19 reps have been updated under the RFO. Re-confirm your active SAM.gov representations reflect the current FAR Part numbering [VERIFY: founder — confirm against current SAM.gov rep & cert wizard, which auto-tracks the RFO updates].
3. Subcontracting language. If your proposal commits to a subcontracting plan or includes an explicit FAR 52.219-9 reference, the substance is the same but the reporting system is now SAM.gov. Update any text that mentions eSRS by name.
CMMC and CUI — the parallel track
The Cybersecurity Maturity Model Certification (CMMC) program is integrating into the FAR/DFARS framework on its own timeline, separate from the RFO. If you handle Controlled Unclassified Information (CUI) or work with DoD, expect CMMC-related contract clauses to appear in your solicitations. The current rule is that DoD contractors handling CUI need CMMC Level 2 certification; the certification process can take months [VERIFY: founder — current CMMC requirement levels and effective dates for non-DoD agencies can shift; verify against acquisition.gov and the CMMC Accreditation Body].
CMMC is also moving into SAM.gov workflows, similar to FPDS and eSRS. The Contractor Performance Assessment Reporting System (CPARS) is slated to migrate into SAM.gov later in fiscal year 2026.
What small businesses should do this quarter
A practical checklist:
1. Re-verify your SAM.gov entity registration. It's the load-bearing element of your federal contracting setup now. Confirm your registration is active (annual renewal), your UEI is correct, your NAICS codes reflect what you actually sell, and your reps and certs are current.
2. Confirm Login.gov access. SAM.gov requires Login.gov for full-functionality access. If your team had FPDS bookmarks tied to individual users, those users need a Login.gov account linked to your SAM.gov entity role.
3. Audit FAR references in your proposal templates. Specifically: any FAR Part 12, 19, 22, or 23 clause numbers, any eSRS references, any FPDS references. Update them.
4. If you have subcontracting plans, confirm they migrated to SAM.gov. Don't assume — log in and check. Reach out to your contracting officer if anything looks incomplete.
5. Watch acquisition.gov/far-overhaul for Phase 2 final rules. The interim class deviations are subject to change in the formal rulemaking. Final-rule effective dates are the ones that matter for permanent compliance.
What didn't change
For all the structural shift, the fundamentals are intact:
- Set-aside programs are still operating. 8(a), HUBZone, WOSB, EDWOSB, SDVOSB — all still in place. FAR Part 19's reorganization made them easier to find, not different in substance.
- Federal contract opportunities post in the same place. SAM.gov Contract Opportunities (formerly the beta.SAM.gov solicitations search) remains the primary federal opportunity portal.
- The 23% federal small business goal is unchanged. Set-aside math, the "rule of two," and SBA scorecard reporting all continue.
- DUNS replacement is settled. Unique Entity Identifier (UEI) is your federal ID. No change here from the RFO.
How GovBid helps
Tracking SAM.gov manually means filtering tens of thousands of federal solicitations across hundreds of agencies. GovBid aggregates US federal and municipal tenders into one free index with plain-English summaries, daily updates, and free email alerts matched to your industry and location.
For RFO-era federal contracting specifically, you can filter by set-aside type and value range to focus on opportunities that benefit from the streamlined Part 12 and Part 19 changes. Browse open US tenders or sign up for free daily alerts — no payment required.
Further reading
- SAM.gov Beginner's Guide — Registration walkthrough, UEI, and reps & certs
- Understanding NAICS Codes — Federal procurement classification
- Government Set-Aside Contracts — Small business, 8(a), HUBZone, WOSB, SDVOSB
- How to Bid on Your First Government Contract — 30-day plan for new contractors
- Browse open US federal tenders — live opportunities updated daily
Sources
- Acquisition.gov, Revolutionary FAR Overhaul — FAR Part Deviation Guidance and Announcements pages (current FAR part release / update dates)
- Executive Order 14275, "Restoring Common Sense to Federal Procurement" (April 2025)
- SAM.gov, "Contract Award Data in SAM.gov" and "Contract Awards Data and Searching Now in SAM.gov" announcements
- GSA / SAM.gov decommission notices for FPDS (Feb 24, 2026) and eSRS (Feb 20, 2026)
- USASpending.gov — alternative no-login federal spending data
- Department of Energy, PF 2026-10 and PF 2026-35 — Class Deviations adopting RFO Part 19 Small Business
- Department of Defense / Department of War, December 19, 2025 DFARS class deviations
- Wolters Kluwer, "The Revolutionary FAR Overhaul — what is changing and what to do next"
- SmallGovCon, "FAR 2.0 Update: Deviations and FAR Companion Guide"
- Gormley Group, "FPDS Contract Data Search Moves to SAM.gov February 24, 2026"
- Coley & Associates, "GSA eSRS & FPDS Shutdown 2026: SAM.gov Transition Guide"