PF 2026-28 Class Deviation to Adopt Revolutionary FAR Overhaul (RFO) Part 25 – Foreign Acquisition
DATE: Issued: January 15, 2026 (Updated March 18, 2026)
TO: HCAs/Procurement Directors/Contracting Officers
FROM: Director, Contract and Financial Assistance Policy Division, Office of Policy, Office of Acquisition Management
SUMMARY: This class deviation, issued pursuant to Section 2 of Executive Order 14275, Restoring Common Sense to Federal Procurement, Office of Management and Budget (OMB) memorandum M-25-26, Overhauling the Federal Acquisition Regulation, and FAR Council memorandum titled Deviation Guidance to Support the Overhaul of the Federal Acquisition Regulation, implements the FAR Council’s RFO model deviation text for FAR Part 25 and relevant sections of FAR Part 52. Contracting offices shall follow the RFO Model Deviation text for Part 25 in lieu of 48 Code of Federal Regulations (CFR) Part 25 and the RFO Model Deviation text for the applicable sections of Part 52 in lieu of 48 CFR 52.225-1 through 52.225-26.
The DOE class deviation, OMB Memorandum M-25-26, Overhauling the Federal Acquisition Regulation, FAR Council Memorandum titled Deviation Guidance to Support the Overhaul of the Federal Acquisition Regulation, and RFO Parts 25 and 52 model deviation text are attached. The FAR Council’s RFO Part 25 and Part 52 model deviation text are available at Acquisition.gov, under the FAR Overhaul link.
Contracting officers should review the FAR Part 25 Practitioner Album at Practitioner Album: FAR Part 25 - Foreign Acquisition for further information regarding a summary of changes, line out, smart accelerators, and earning CLPs by completing the Practitioner Album.
The model deviation text attached to the class deviation has been updated to implement FAC 2026-01, FAR Case 2025-007, Trade Agreements Thresholds and to make other minor, editorial updates, including replacing the use of the term “shall” with “must” or “will,” as appropriate, to impose requirements. As a result, some of the provisions and clauses (including alternates) may have new or updated deviations and deviation dates.
Questions concerning this policy flash should be directed to the Contract and Financial Assistance Policy Division at DOE_oapmpolicy@hq.doe.gov.
For NNSA questions concerning this policy flash, please contact the Acquisition Policy and Oversight Division, Policy & Oversight Branch (NA-PAS-111), at (505) 845-5639.