Over one year ago, on May 2, 2025, the FAR Council took the first concrete step in the administration’s “Revolutionary FAR Overhaul” (“RFO”) initiative by issuing the initial round of rolling model deviation guidance—a deliberate move to translate reform of the Federal Acquisition Regulation (“FAR”) from an abstract policy goal into acquisition text.  That moment marked the beginning of a new implementation reality: rather than waiting for a single, comprehensive rulemaking, the government began operationalizing the overhaul in increments, part by part, through deviations.  Now, a year later, the question for contractors is no longer whether the overhaul is “coming,” but how it is being implemented across agencies and systems.  This is therefore a good time to take stock of where implementation stands, where friction is emerging, and what sophisticated contractors can do to stay ahead of the curve.  For additional information, our prior coverage of the RFO roll-out can be found here and here.