Independent, not SAM.gov

Where every FAR clause is moving by Oct 2026

Updated 6 October 2026

ZeroGov covers the lane where US federal contract clauses meet small business reality, independent of SAM.gov and independent of any agency. This page maps where each clause in the Federal Acquisition Regulation is moving as of October 2026, where the new home lives, and which solicitations you will see the change in first. It is not affiliated with the General Services Administration, the Office of Management and Budget, or any contractor help desk.

Why the FAR is being split up, in one paragraph

Since the 2024 Office of Management and Budget memorandum on acquisition reform, every federal agency has been told to move its internal policy out of the Federal Acquisition Regulation and into a separate agency supplement. The reasons given are speed, clarity, and the long-standing complaint that the FAR has become a junk drawer of policy that does not really belong with regulation. The result, for the small contractor reading a solicitation, is a long transition in which a single clause can move three times: out of the FAR, into an agency supplement, and then into a new agency-wide issuance that may not look like the FAR at all.

For October 2026, the practical effect is that solicitations now carry a mix of FAR, GSAR, DEAR, DFARS, and a growing number of agency-issued clauses that look like the FAR but cite a different regulation number. The trick is no longer whether a clause is in the FAR, but which agency owns it and whether the clause number has changed. ZeroGov is independent of SAM.gov and of every agency, and this map is built for the contractor who needs to read a solicitation quickly and decide which clauses still apply to their bid.

Clauses staying in the FAR for now

Some clauses are too central to the way the government buys to move at all. The clauses that govern the formation of a contract, the duty to perform, the duty to pay, and the core definitions of cost and pricing remain in the FAR. As of October 2026 the following groups of clauses are confirmed to remain in the FAR through the next two procurement cycles:

• Contract formation clauses in FAR Part 16, including the contract type definitions and the limitations on use of cost-reimbursement contracts.
• Competition clauses in FAR Part 6, including the justification and approval requirements for other than full and open competition.
• Small business set-aside clauses in FAR Part 19, including the clauses that require prime contractors to acknowledge subcontracting plans and to flow down certain requirements.
• Bid protest and agency-level administrative remedies in FAR Subpart 33.1, including the file a protest and request a debriefing clauses.
• Cost accounting standards clauses in FAR Part 30, including the CAS applicability clauses and the cost accounting standard administration clauses.
• Termination clauses in FAR Part 49, including the convenience and default termination clauses that flow down to most cost-type contracts.

If a solicitation cites one of these clauses by its old FAR number, the clause is still valid even if the agency supplement in the same solicitation cites a newer authority. The Federal Acquisition Regulation remains the default rulebook for the basic duties of the parties, and small contractors should treat any deviation as a flag to read the deviation language carefully before signing.

Clauses moving to the General Services Administration

The largest single move is happening inside the General Services Administration, where the GSA Acquisition Manual is replacing the old GSAR clauses one part at a time. The October 2026 GSAR migration touched FAR Part 38, the part that covers Federal Supply Schedules, and FAR Part 37, the part that covers service contracting. The new GSAR parts now read:

• GSAR Part 538 replaces the former FAR Part 38 for most schedule contracting, with the new ordering procedures for schedules, the new contractor team arrangement clauses, and the new scope review language now living in GSAR Subpart 538.71.
• GSAR Part 537 covers service contracting for GSA, with the new performance-based service acquisition clauses and the new service contract labor standards clauses now sitting beside the original FAR text in a side-by-side issuance.
• GSAR Part 536 covers construction and architect-engineer contracts awarded by GSA, with the clauses on design-build and the clauses on value engineering now issued as GSAR clauses rather than FAR clauses.

For small contractors who hold a GSA Schedule, the practical change is that a solicitation issued by GSA in October 2026 will reference GSAR clauses rather than the equivalent FAR clauses. The substance has not changed for most clauses, but the citation will be different, and any internal compliance tracking that quotes the FAR clause number will need to be updated. ZeroGov is independent of SAM.gov and of the GSA, and our reading of the GSAR migration is based on the published 2026 GSAR rewrite that is now in effect.

There is one important caveat. When a non-GSA agency uses a GSA Schedule contract under the authority of FAR Subpart 8.4, the ordering procedures still come from the GSAR, not from the ordering agency's supplement. A small contractor that has been asked to accept an order from the Department of the Interior that cites GSAR clauses should treat those clauses as binding even though the order is not coming from GSA.

Clauses moving to the Department of Defense

The Department of Defense moved faster than any other agency. The DFARS clauses that have been moved out of the FAR were already largely in place by the end of 2024, and the October 2026 cycle is mostly a tidying exercise. The new DFARS clauses that small contractors will see in October solicitations include:

• DFARS Subpart 204.73 on contractor compliance with the Defense Federal Acquisition Regulation Supplement, including the new contractor responsibility clauses and the new covered defense information clauses.
• DFARS Subpart 225.77 on the trade agreements clause, which has been moved out of FAR Part 25 and into a separate DFARS section for the trade agreements that apply only to DoD.
• DFARS Subpart 252.204-7012 on safeguarding covered defense information, which has been moved out of the DFARS clause numbering scheme and into a new clause numbered 252.204-7012-A for contracts awarded after October 1 2026.
• DFARS Subpart 232.5 on progress payments and the new performance-based progress payment clauses for DoD contracts above the simplified acquisition threshold.

For the small contractor, the DoD change with the most practical effect is the new safeguarding clause. The clause text is the same as the previous safeguarding clause, but the clause number has changed, and a number of legacy contract audit reports that reference the old clause number will not match the new clause number. ZeroGov recommends that any October 2026 proposal that cites the old clause number be revised to cite the new clause number before submission.

Clauses moving to civilian agency supplements

The civilian agency supplements are the slowest part of the migration, and they are also the part that will change the most through the end of 2026. The Department of Homeland Security, the Department of Veterans Affairs, the Department of the Interior, and the Department of Agriculture have all published draft agency supplements in 2026, and the final versions are expected in the November procurement cycle. The clauses that are moving include:

• Clauses on contractor fitness and responsibility determinations in FAR Part 9, which are moving to the agency supplement for each civilian agency.
• Clauses on contract financing in FAR Part 32, which are moving to the agency supplement for the Department of Veterans Affairs and to the Department of Homeland Security in separate issuances.
• Clauses on the service contract labor standards in FAR Subpart 22.10, which are moving to the agency supplement for the Department of Agriculture and to the Department of the Interior.
• Clauses on the Walsh-Healey Public Contracts Act and the McNamara-O'Hara Service Contract Act, which are moving to the Department of Labor's regulations in 29 CFR rather than to agency supplements.

The hardest part of the civilian agency migration is that the clause number may not survive. A clause that was FAR 52.222-41 may now appear as HHSAR 352.222-41, USDA 352.222-41, or DOI 1352.222-41, depending on which agency issued the solicitation. Small contractors that maintain a clause library indexed only by FAR clause number will need to add a column for the agency supplement clause number, and they will need to keep that column updated as each agency publishes its final rule.

A clause-by-clause table for the October 2026 cycle

The following table is a current reading of where the most common clauses cited in small business solicitations have moved. It is built from the published FAR, GSAR, DFARS, and civilian agency supplements as of October 1 2026. It is not exhaustive, and ZeroGov is independent of every source, so this table is best read as a working map rather than a complete reference.

What this page is not

This page is not a legal opinion and it is not a substitute for the published FAR, GSAR, DFARS, and civilian agency supplements. ZeroGov is independent of SAM.gov, independent of the General Services Administration, independent of the Department of Defense, and independent of every civilian agency that has published an agency supplement. This page does not list every clause in the FAR, does not represent that the table above is complete, and does not represent that any specific clause will or will not be moved in the next procurement cycle. The reader is responsible for confirming the current citation of any clause before relying on it for a bid, a protest, or a compliance file. The page also is not affiliated with the SAM.gov help desk, the Federal Service Desk, or any contractor service that charges a fee for SAM.gov registration.

What small contractors should do in October 2026

For a small contractor reading solicitations in the October 2026 cycle, the practical workflow has changed in three ways. First, the clause number on a solicitation now requires a quick check against the issuing agency's supplement, and any deviation from the FAR clause number should be flagged for review before the bid is signed. Second, the agency supplement for each civilian agency is the new home for clauses that used to be in the FAR, and small contractors should subscribe to the supplement's update notice to know when a new clause is published. Third, the GSAR and the DFARS have been reissued with new clause numbers for the most common clauses, and a clause library that was last updated before October 2026 will need to be reindexed against the new numbers before it is used in a proposal.

The most common mistake in the October 2026 cycle is to assume that a clause number change is also a clause text change. The reverse is also true. A small contractor that reads a clause as if it were the old FAR text may miss a new deviation language. ZeroGov is independent of every agency and every system, and the recommendation here is to read the actual text of every clause cited in a solicitation, regardless of the clause number, and to confirm against the source document that the clause being read is the one in force on the date of award.

Independent information, not legal advice. Confirm status and rules on sam.gov and the current FAR text.