The "Commercial-First" FAR Shift: Bye-Bye Specs, Hello Solutions
The "Revolutionary FAR Overhaul" (RFO) has officially entered its most aggressive phase. As part of a government-wide push to "restore common sense" to procurement, multiple agencies are now utilizing Class Deviations that prioritize Commercial Services Openings (CSOs) over traditional, specifications-heavy bidding.
What is the RFO?
The RFO is a comprehensive initiative led by the FAR Council to return the Federal Acquisition Regulation (FAR) to its statutory roots. By removing more than 1,600 "burdensome" non-statutory requirements, the government is moving away from telling contractors how to do the work and focusing strictly on what it wants to buy.
The Rise of "Commercial Services Openings" (CSOs)
The core of this "Commercial-First" strategy is the expansion of CSO authority. Traditionally reserved for innovative tech, CSOs are now being deployed across a broader range of commercial services.
The Key Differences:
The Shift in Government Procurement
Traditional FAR procurement is defined by rigid, government-unique specifications that often require vendors to submit massive, 100-page technical volumes. This process is notoriously slow, typically taking anywhere from 6 to 18 months to reach a contract award, with a primary focus on finding the lowest price that is technically acceptable.
In contrast, the new "Commercial-First" (CSO) approach flips the script by using outcome-based "Problem Statements" rather than strict specs. Instead of lengthy manuals, companies can submit short "Solution Briefs" or "Pitch Decks," allowing the government to move at a fast-track pace—often awarding contracts in under 30 days. The ultimate goal of this model is to prioritize best value and commercial innovation over simply picking the cheapest option.
The "Class Deviation" Wave
Because formal rulemaking can be slow, agencies are using Class Deviations to adopt these RFO changes immediately.
Batch 2 is Live: As of today, RFO deviations are active for FAR Parts 6, 19, 27, 43, 46, and 52.
Agency Adoption: Leading the charge are the GSA, Department of Energy, and DOD, all of whom are now empowered to bypass legacy "specification-heavy" clauses in favor of commercial standards.
The Bottom Line
The government is tired of "Hail Mary" requirements that never get fulfilled. They now want the "80% commercial solution" that works today over a 100% custom solution that arrives in three years.
Action Steps for TIKC Members
Stop Leading with Specs: In your capability statements, stop focusing on how you follow government-unique processes. Lead with your commercial success and how your "ready-made" solution solves a specific agency problem.
Master the "Solution Brief": Practice condensing your value proposition into a 5-page brief or a 10-slide deck. Under the RFO, if you can’t explain your value in plain language, you’re out.
Download the Practitioner Albums: The GSA has released "Practitioner Albums" for each overhauled FAR part. These are the "cheat codes" for how your Contracting Officer (KO) is being trained to buy in this new environment.
Monitor "Notice of Intent": Agencies using CSOs often post "Areas of Interest" rather than traditional RFPs. Check SAM.gov frequently for these less-formal solicitations.
The TIKC Take: Adapt or Get Left Behind
The 8(a) "January Purge" and the "Commercial-First" FAR shift are two sides of the same coin: the government is professionalizing its vendor base. Whether it’s proving your eligibility through a rigorous individualized narrative or winning a contract with a 10-slide solution brief, the era of "checking the box" is over. This February, your mission is to audit your compliance, sharpen your commercial story, and ensure your business is built on results, not just status.
