The Defense Federal Acquisition Regulation Supplement's Phase 1 FAR overhaul put 31 class deviations into effect on February 1, 2026, implementing the first tranche of regulatory simplification measures identified by the Defense Acquisition Regulatory Council's comprehensive DFARS review. The 31 deviations span contract administration, small business, cybersecurity, cost accounting, environmental reporting, and commercial item acquisition provisions, with the largest cluster affecting the contract data requirements list process, quality assurance provisions, and compliance certifications required at time of offer. The February 1 effective date applies to solicitations issued on or after that date; existing contracts continue under the prior provisions until modified. The deviations collectively eliminate over 80 pages of DFARS regulatory text across the affected areas, reduce the number of mandatory certification requirements at time of offer from 43 to 28, and streamline the contract data requirements list approval process by eliminating category D data requirements for contracts under $10 million. A Phase 2 rulemaking is expected to convert the class deviations to permanent DFARS rule text through the formal notice-and-comment process beginning in the third quarter of FY 2026.
Key Changes in the Phase 1 Deviations
The most practically significant changes in the 31 Phase 1 deviations affect three areas that contractors encounter on virtually every DFARS-covered solicitation. First, the certification consolidation reduces the separate certification statements required in the Representations and Certifications section from 43 to 28 by combining related certifications into single cross-referencing certifications and eliminating certifications that duplicate information already provided in other required submissions. Contractors have long criticized the Reps and Certs section of DFARS solicitations as a compliance theater exercise that consumes hours of attention without producing meaningful information the government does not already have through SAM.gov registration and prior contract performance records. Second, the contract data requirements list changes eliminate Category D data items — administrative and program management reporting that serves primarily internal agency documentation purposes — from contracts below $10 million, reducing the number of deliverables on small and mid-tier contracts by an estimated 20 to 30 percent based on historical CDRL population data. Third, the quality assurance provision changes update MIL-SPEC references that have been obsolete since the mid-1990s and replace them with current commercial quality standards, reducing confusion in contracts where outdated MIL-SPEC citations created ambiguity about applicable requirements.
Phase 2 Rulemaking and Long-Term Trajectory
The February 2026 class deviations are explicitly temporary regulatory measures intended to demonstrate the practical effect of the proposed changes while the formal notice-and-comment rulemaking that would make them permanent is underway. The Defense Acquisition Regulatory Council has scheduled Phase 2 rulemaking publication for August 2026, with a 60-day comment period and a target effective date of early 2027. In parallel, the FAR Council's comprehensive review — which addresses FAR provisions that apply to civilian agencies as well as DoD — is expected to publish its first tranche of proposed changes in the same timeframe, potentially creating a coordinated simplification of both the FAR and DFARS in early 2027. Contractors who have comments on the Phase 1 class deviations — including concerns about interpretive ambiguities, unintended consequences, or provisions that were changed but should have been eliminated entirely — should submit comments during the Phase 2 public comment period to ensure their perspective is incorporated into the permanent rule text.
What It Means for Contractors
The 31 Phase 1 DFARS class deviations reduce proposal preparation burden on new solicitations and streamline contract administration on awards made after February 1, 2026.
- Contractors receiving DFARS solicitations issued after February 1, 2026 should verify that they are working from current solicitation templates that incorporate the class deviation changes; using prior-version proposal templates on new solicitations may result in submitting obsolete certifications or missing updated representations that contracting officers are now expecting.
- The CDRL reduction for contracts under $10 million is a direct cost reduction for contractors with significant mid-tier contract volumes; proposal teams should update their standard CDRL deliverable assumptions for new proposals in this range to reflect the elimination of Category D items and price their contract administration support accordingly.
- The certification consolidation does not change the substantive representations being made — contractors still certify to the same underlying facts — but the reorganized certification structure may require updating proposal preparation checklists and internal compliance review processes to ensure all required certifications are addressed in their new consolidated form.
- Contractors with pending proposals on solicitations issued before February 1 are not affected by the class deviations; the changes apply only to solicitations issued on or after the February 1 effective date, which means ongoing source selections may involve two different certification and CDRL structures simultaneously during the transition period.
Contractor Compliance During the Transition Period
The February 1, 2026 effective date of the 31 DFARS class deviations creates a transition period during which contractors will encounter both old and new clause sets depending on when their contracts were awarded. Solicitations issued before February 1 proceed under the old DFARS provisions; solicitations issued after February 1 incorporate the class deviation changes. Because many major defense contracts are multi-year vehicles with active task order competitions, a contractor may simultaneously be performing on base contracts awarded under the old framework, competing for task orders on vehicles that were awarded after February 1 under the new framework, and bidding on new indefinite-delivery vehicles issued under the revised provisions. This concurrent exposure requires contractors to maintain compliance familiarity with both the pre- and post-deviation clause sets during the transition — a period that could extend several years as legacy contracts run their courses. The most practical approach for contract administration teams is to create a contract registry that flags which contracts were awarded before versus after February 1 and applies the appropriate clause set to each contract's administration activities. The quality assurance and CDRL changes are particularly prone to confusion in this context, as the specific deliverable types and inspection standards differ between the old and new frameworks in ways that can affect contractor performance obligations if the wrong framework is applied. Defense Contract Management Agency contract administrators are being trained on the transition framework, but contractor legal and contracts teams should not assume that all COs and CORs will apply the correct framework automatically — flagging the applicable clause set explicitly in deliverable submissions and correspondence is a prudent practice during the transition period.