FAR Overhaul Part 19 Deviation: New Model Posted (2025)

FAR Overhaul Unveils New Part 19 Deviation Model (2025)

The FAR Council’s Revolutionary FAR Overhaul (RFO) advances a refreshed Part 19 deviation model as part of a broader effort to streamline small-business procurement. A government-wide class deviation, RFO-2025-19, issued by GSA, takes effect November 3, 2025, and directs agencies to apply the Part 19 model deviation text in new procurements. The official deviation guide explains the full set of deviations and the transition path for agencies and contractors.

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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

The Part 19 overhaul reorganizes content around the procurement lifecycle (Presolicitation, Evaluation/Award, Postaward), introduces clearer cross-references (SBS replacing DSBS in several contexts), and elevates a lifecycle-based approach to small-business considerations. The deviation guide and the new model text are intended to harmonize how agencies implement set-aside procedures and small-business goals across procurements.

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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.

$183B

FY2024 prime contracting to small businesses

Source: Biden-Harris Administration Awards Record-Breaking $183B in Federal Contracts to Small Businesses, Marking Fourth Consecutive Year of Growth | U.S. Small Business Administration

Beyond the topline growth, 2023–2024 data show strong performance across small-business subcategories: Small Disadvantaged Businesses (SDB) spent about $76.2B; SDVOSBs about $31.9B; WOSBs about $30.9B; and HUBZones about $17.5B. These figures underscore the ongoing emphasis on socio-economic set-asides alongside the Part 19 overhaul.

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"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."
SBA
Small business procurement scorecard | U.S. Small Business Administration

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.

Conclusion: The Part 19 deviation model posted under the Revolutionary FAR Overhaul marks a significant milestone in modernizing federal procurement language, with an emphasis on readability, lifecycle alignment, and strengthened small-business participation. Agencies should begin implementing now and monitor SBA data dashboards for impact.

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Sources & Citations

1. FAR Overhaul New Model Deviation Text for Part 19 | Acquisition.GOV [Link ↗](government site)

2. FAR Overhaul Part Deviation Guide – FAR Overhaul Part 19 [Link ↗](government site)

3. New Model Deviation Text Posted – FAR Overhaul Initiative | Acquisition.GOV [Link ↗](government site)

FAR Overhaul Unveils New Part 19 Deviation Model (2025)

FAR Overhaul Unveils New Part 19 Deviation Model (2025)

Implementation Window

What changed in Part 19 under the RFO

Adoption steps for agencies and contractors

Review the Part 19 deviation text and deviation guide

Apply the RFO Part 19 deviations to new procurements

Update templates, SOWs, and checklists

Coordinate with SBA and OSDBU during planning and postaward

Sources & Citations

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