Your Horizon
7 changes touch you. Checked Oct 29, 2026; each links its source.
PausedPaused by DoD Jul 13, 2026
CMMC Phase 2: third-party Level 2 assessments
Phase 2 was to start November 10, 2026, requiring a C3PAO Level 2 certification to win contracts that involve CUI. DoD put it and later milestones in abeyance on July 13, 2026, pending a review, with no new date. Phase 1 self-assessments and DFARS 252.204-7012 still apply.
What to do: Keep your NIST SP 800-171 self-assessment and SPRS score current, and ask your prime whether it still requires certification; some do.
It applies because you work with DoD and you handle CUI. DoD CIO, CMMCDFARS 252.204-7021
ProposedComments closed on the re-proposed rule Jul 23, 2026
Government-wide rule for controlled unclassified information (CUI)
Re-proposed June 23, 2026 inside the FAR Overhaul (new FAR Part 40), it would set one framework for safeguarding CUI on civilian contracts too, built on NIST SP 800-171, with incident reporting. Obligations start only when a final rule issues and the clause is in your contract.
What to do: If you handle CUI for civilian agencies, gap-assess against NIST SP 800-171 now; it is the baseline either way.
It applies because you handle CUI. FAR Case 2026-001, Federal RegisterNIST SP 800-171
ProposedComments closed on the first four proposed rules Jul 23, 2026
Revolutionary FAR Overhaul: final rules
The FAR Council is rewriting the whole FAR (E.O. 14275) in twelve proposed rules. The first four, covering 20 FAR parts including SAM registration, protests, and CUI, were proposed June 23, 2026; final rules come next, and until then agencies work from class deviations, so both rulebooks apply.
What to do: Read each solicitation for which FAR it uses (deviation or legacy), and check that your SAM representations still match what the overhauled parts ask.
It applies across federal contracting. FAR Overhaul, acquisition.govFAR Case 2026-001, Federal Register
In EffectIn effect since Nov 10, 2025
CMMC Phase 1: self-assessments in DoD solicitations
DoD solicitations can require a current CMMC Level 1 or Level 2 self-assessment in SPRS, with an annual affirmation by a senior official, as a condition of award.
What to do: Post your self-assessment in SPRS before you bid, and name the official who affirms it each year.
It applies because you work with DoD. DoD CIO, CMMCDFARS 252.204-7021
ProposedComments closed Oct 19, 2026
FAR Overhaul: contract types and special methods (Parts 16, 17, 35)
FAR Case 2026-006, proposed September 18, 2026, rewrites the rules on types of contracts, special contracting methods such as multiyear and options, and R&D contracting, with their clauses in Part 52.
What to do: If you hold or bid IDIQs, multiyear or cost-type work, track the final rule; pricing and option terms may change at the next award.
It applies across federal contracting. FAR Case 2026-006, Federal Register (91 FR 59476)
In EffectExecutive order signed Apr 30, 2026
Fixed-price contracts become the default
An April 30, 2026 executive order makes fixed-price contracting the default across the executive branch, has agencies review their largest cost-type contracts for conversion, and calls for FAR changes; agencies use deviations until then.
What to do: Price your next proposal as if fixed price is the default, and be ready to justify cost-type terms where the risk truly can’t be priced.
It applies across federal contracting. Federal Register, executive ordersFAR Part 16, contract types
In EffectIn effect since Oct 1, 2025
Micro-purchase and simplified acquisition thresholds raised
The micro-purchase threshold is $15,000 and the simplified acquisition threshold $350,000, adjusted for inflation; buys between the two are generally set aside for small business.
What to do: Small businesses: more work now sits under the simplified threshold, where set-asides are the norm.
It applies across federal contracting. FAR 2.101
A first read of public sources, not legal advice. Rules move, so confirm the source before you rely on a date.
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Sources
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Questions
When does CMMC Level 2 certification become required?
It was set for November 10, 2026 (Phase 2), but DoD paused Phase 2 on July 13, 2026 pending a review, with no new date. Self-assessments under Phase 1 and DFARS 252.204-7012 still apply.
What is the Revolutionary FAR Overhaul?
A rewrite of the whole FAR under Executive Order 14275. Agencies adopted streamlined parts by class deviation in 2025; the FAR Council is now making them permanent in twelve proposed rules, the first published June 23, 2026.
What is the TINA threshold now?
For DoD, NASA and Coast Guard contracts entered into after June 30, 2026, certified cost or pricing data are required above $10 million, up from $2.5 million, under the FY2026 NDAA.
When does the Buy American threshold go to 75 percent?
For items delivered from January 1, 2029. Deliveries from 2024 through 2028 need 65 percent domestic content (FAR 25.101).
How current is this?
Every entry was checked against its source on 2026-10-29, and links to it. Rules move, so confirm the source before you rely on a date.
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