Trump overhaul slashes FAR Part 34

The Trump administration’s “Revolutionary FAR Overhaul” has released a model deviation that rewrites FAR Part 34, Major System Acquisition. The new text—issued 2 May 2025 and already available for agency adoption—shrinks the part from 32 sections to just 11, excising most front-end program-management rules in the name of “plain-language streamlining.”

What was deleted

• Entire Subpart 34.0 (34.000-34.005-6). Gone are mandatory requirements for acquisition strategies, competition planning, and phased contracting (concept exploration, demonstration, full-scale development, and production). Those topics are expected to migrate to non-binding “buying guides,” leaving FAR silent on how agencies should structure major‐system life-cycles.
• Definitions and responsibilities. The definition of “effective competition” and detailed program-manager duties (§34.001-34.003) disappear, eliminating language protest attorneys have long used to challenge restrictive solicitations.
• Mission-oriented solicitation rules. Detailed instructions for presolicitation notices, conferences, and data-sharing with potential offerors (§34.005-2) are struck, reducing statutory cross-references to Part 6 competition requirements only.
• Clause architecture. Pre- and postaward Integrated Baseline Review provisions (FAR 52.234-2 and -3) are no longer invoked; only the basic Earned Value Management System (EVMS) clause (52.234-4) remains.

What survives—and gets renumbered

• Title III industrial resources. Testing and qualification procedures under the Defense Production Act move from “Subpart 34.1—Testing” to a new Subpart 34.1—Post-award (§34.100-34.105). Language is tightened but policy remains: the Government foots the bill for testing and may consult the Title III program office at Wright-Patterson AFB.
• EVMS policy. The rewrite keeps an EVMS requirement (§34.201-34.203) but condenses it to four short paragraphs: monthly reporting, coverage of major subcontracts, agency-determined plan adequacy, and a single sentence on Integrated Baseline Reviews. The detailed objectives and risk-assessment checklists formerly in §34.202 vanish.

Practical effects for federal contracting

• Speed vs. certainty. By stripping prescriptive planning steps, agencies can jump directly to solicitation without drafting the exhaustive “mission-oriented” packages Part 34 once required. Expect shorter lead times—but also wider variation in how programs handle market research, alternative analyses, and competitive down-selects.
• Protest posture. GAO case law often cites deleted §§34.003-34.004 when deciding whether an agency adequately documented its acquisition strategy. Contractors will have fewer regulatory hooks for challenging a procurement, shifting arguments to statute or executive orders.
• EVMS dilution. Without mandatory pre-award and post-award IBR clauses, oversight of cost/schedule baselines may rely on agency discretion. That could lighten compliance costs for small primes but raise performance-risk exposure for multi-billion-dollar programs.
• Policy gaps to “buying guides.” OFPP says excised material will reappear in non-regulatory guides. Until those are published, program managers must navigate with only high-level OMB Circular A-11 references and agency supplements. Contractors should track each agency’s class deviation to understand local ground rules.

What’s next

The FAR Council is taking informal comments on the draft through Sept. 30 and plans to issue additional rewritten parts on a rolling basis.