FAR Overhaul Unveils New Part 19 Deviation Model (2025)
A comprehensive look at the FAR Overhaul’s Part 19 deviation model, the Nov 3, 2025 class deviation, and practical guidance for agencies and small businesses navigating the transition.
FAR Overhaul Unveils New Part 19 Deviation Model (2025)
Implementation Window
Key dates to watch: September 26, 2025 – FAR Council releases the Part 19 model deviation text; November 3, 2025 – Class Deviation RFO-2025-19 becomes effective. Agencies should begin updating templates and training staff now to align with the RFO Part 19 language.
What changed in Part 19 under the RFO
Adoption steps for agencies and contractors
- 1
Review the Part 19 deviation text and deviation guide
Start with the Part 19 model deviation text and the FAR Overhaul deviation guide to understand the new structure and plain-language approach.
- 2
Apply the RFO Part 19 deviations to new procurements
For upcoming solicitations, use the RFO Part 19 deviations to ensure consistency with the updated framework.
- 3
Update templates, SOWs, and checklists
Align contract templates and boilerplate with the RFO deviations; revise SOW language and evaluation criteria accordingly.
- 4
Coordinate with SBA and OSDBU during planning and postaward
Establish pre-solicitation and postaward coordination channels with SBA PCRs and OSDBU staff as part of ongoing governance.
"Small businesses remain a cornerstone of federal procurement, driving innovation, competition, and regional economic impact, as reflected in SBA scorecards and year-over-year gains."
- Adopt the Part 19 RFO deviations for new procurements to ensure consistency with the updated framework.
- Coordinate early with SBA OSDBU and procurement governance to align pre-solicitation planning with the Part 19 lifecycle.
- Update templates, SOW language, and evaluation scripts to reflect the RFO Part 19 deviation language and lifecycle structure.
Sources & Citations
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