Federal procurement is undergoing a period of significant transformation, driven by a broader government-wide push for modernization, efficiency, and strategic realignment. Three major initiatives stand at the center of this effort. First, an Executive Order (“EO”) is advancing procurement consolidation in the General Services Administration (“GSA”) by requiring the agency to come up with a plan to unify contract vehicles and streamline how agencies acquire common goods and services. This move is designed to eliminate duplicative contracts and reduce administrative costs across agencies.

At the same time, the Office of Federal Procurement Policy (“OFPP”) has launched a sweeping overhaul of the Federal Acquisition Regulation (“FAR”), which is the primary regulatory framework governing federal acquisitions. While the FAR largely has remained unchanged in structure for decades, this initiative represents a potentially historic revamp aimed at simplifying complex regulations and enhancing usability of federal procurement rules for both agencies and contractors.

And most recently, a new EO is accelerating defense innovation and reducing bureaucratic friction by directing the Department of Defense (“DoD”), the largest federal buyer, to revamp its acquisition framework.

Together, these initiatives, if implemented, would mark a major shift in how the federal government buys products and services from contractors.

EO Signals Major Procurement Shift to GSA

On March 20, 2025, President Trump issued EO 14240, “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” requiring GSA to submit a plan, within 90 days, to centralize the procurement of “common goods and services” and government-wide acquisition contracts (“GWACs”) for information technology (“IT”). 90 Fed. Reg. 13,671 (Mar. 25, 2025). EO 14240 and the accompanying Fact Sheet characterize the move as restoring GSA to its “original purpose” of carrying out “an economical and efficient system” for federal procurement.

Established on July 1, 1949 by President Harry S. Truman through the Federal Property and Administrative Services Act, 40 U.S.C. § 101, et seq., GSA is responsible for managing the government’s centralized procurement of goods, services, real estate, and technology. GSA’s goal is to simplify acquisitions, reduce redundancy, and promote cost savings. It currently manages multiple contract vehicles, including GSA Schedules and GWACs for IT. While GSA manages multiple centralized contracts vehicles, many agencies nevertheless maintain their own procurement vehicles and conduct independent acquisitions tailored to their mission-specific needs.

As part of this effort, EO 14240 defines “common goods and services” by reference to the 10 government-wide categories established by the Category Management Leadership Council. Agencies must submit proposals to GSA by May 19, 2025, proposing how GSA should procure these goods and services on their behalf. These categories include:

1. Facilities and construction;
2. Professional services;
3. IT;
4. Medical;
5. Transportation and logistics;
6. Industrial products and services;
7. Travel
8. Security and protection;
9. Human capital; and
10. Office management.

EO 14240 further directs GSA to eliminate duplicative and inefficient indefinite-delivery vehicles for IT. This may impact major non-GSA IT GWACs, such as NASA’s Solutions for Enterprise-Wide Procurement (SEWP) contracts and the NIH’s Chief Information Officer-Solutions and Partners (CIO-SP) contracts, though GSA’s Administrator is permitted to decline via executive agent authority “when necessary to ensure continuity of service.” The Office of Management and Budget (“OMB”) also must designate GSA’s Administrator as the executive agent for all government-wide IT acquisition by April 19, 2025, with preliminary guidance due by April 3, 2025.

GSA must submit its own comprehensive plan to OMB by June 18, 2025, outlining how it will carry out the consolidated procurement functions across all “domestic components of the Government.” EO 14240 does not define this phrase, leaving room for interpretation as to which federal entities are subject to the consolidation mandates.

Moreover, EO 14240 grants broad discretion to GSA and OMB to determine how and when to consolidate procurements, and assumes GSA will absorb substantial new responsibilities, despite ongoing hiring freezes and existing contracting pauses. EO 14240 is unfortunately silent on the continued role of agencies with long-standing procurement authority, such as the Department of Veteran Affairs, which has historically administered medical procurements under delegation from the GSA.

In line with EO 14240, the GSA Acting Administrator, Stephen Ehikian, emphasized in a blog post that his goal is for GSA to return “to [its] founding mission of streamlining federal operations, consolidating resources, and efficiently providing essential services.” He announced that GSA has already launched centralized procurement efforts with four agencies and committed to “maximize the negotiation power of volume buying.” Ehikian also acknowledged the burden of federal procurement bureaucracy and committed to reform, by working with the FAR Council and other stakeholders to “restore merit-based opportunity and ensure contracts are awarded to those best positioned to fulfil government needs effectively and efficiently.” Finally, he outlined plans to modernize GSA’s internal systems, increase vendor competition, and “reduce the compliance burden” for both large and small businesses, including expanding tools for the federal contracting workforce.

EO 14240 represents a substantial shift in federal acquisition policy. Contractors with agency-specific contracts in affected categories may face delays, terminations, consolidations, or re-competes under GSA-led vehicles. Contractors should:

• Assess their exposure to consolidation by reviewing current agency contracts;
• Monitor GSA’s updates on implementation and new procurement opportunities;
• Engage with GSA early to ensure alignment with contract vehicles, like the GSA Schedules; and
• Prepare for increased scrutiny of cost-effectiveness.

Further developments and implementing guidance will shape the full impact of this shift. For now, contractors should anticipate adjustments in procurement pipelines and increased competition under centralized contract structures.

"Revolutionary" Overhaul of the Federal Acquisition Regulation

On April 2, 2025, President Trump issued a draft EO (“April 2 EO”), directing OFPP to manage an “overhauling” of the FAR. The stated goal of the April 2 Order is to “eliminate burdensome and outdated requirements, remove non-statutory rules, and replace them with practical buying guides and plain-language regulations,” and ultimately provide “faster acquisitions, greater competition, and better results.” 

Established in 1974, the OFPP is in the OMB, and is pivotal in developing the policies and practices that federal agencies follow to procure the goods and services necessary for the federal government.

OFPP and the FAR Council have already begun issuing revised FAR parts as model deviation guidance. These simplified regulations are designed to eliminate purportedly outdated and burdensome requirements, allowing agencies to adopt them immediately until formal rulemaking is completed. The project will take place over two phases. Phase One will involve a revision of each FAR part, published with a corresponding deviation guide to provide model language that agencies can immediately adopt until formal rule making is completed. This will take place between April 2025 and October 2025. The revised FAR parts and Agency Deviation Guidance can be accessed on the main FAR Overhaul website. Phase Two will follow the completion of Phase One, and will involve formal rulemaking to finalize the FAR, which likely will take some significant period of time.

Notably, the revision of FAR Part 1 has already been completed and is available for review. The “lined out” version provides a clear comparison between the previous and updated texts, highlighting the specific changes made. This can be reviewed on the FAR Overhaul Part 1 page. As the project progresses, contractors can access the buying guides posts on the website, which will provide practical advice and interactive tools for contractors to reference when applying the new FAR.

The FAR overhaul has the potential to bring a host of benefits to federal government contractors, particularly be reducing the complexity and administrative burden that has long been associated with the federal procurement system. The use of simplified language is expected to make the FAR easier to navigate, especially for small businesses. However, the overhaul also introduces uncertainty and potential risks that contractors need to navigate carefully. During the transition period, contractors will be navigating a procurement landscape in which existing contracts remain subject to legacy FAR provisions, while new awards begin incorporating revised language, creating the potential for inconsistent obligations and compliance requirements. This inconsistency could complicate compliance efforts, especially for contractors working across multiple agencies. Even though regulations seemingly will be simplified, the transition may put substantial costs on contractors who will need to retain staff, revise internal compliance policies, and update systems to align with the new structure.

While the intent of the overhaul is to modernize and improve the acquisition process, its success will depend on careful implantation and the ability of contractors to quickly adapt. There is still much to be seen as the OFPP and FAR Council continue to roll out new revisions and line-outs.

EO Promotes Speed and Innovation in DoD Procurement

On April 9, 2025, President Trump issued an EO, “Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base (“April 9 EO”),” signaling the administration’s intent to fundamentally reform how the DoD approaches procurement. The April 9 EO requires DoD to immediately prioritize streamlined procurement pathways, including Other Transactions Authority, Rapid Capabilities Office policies, and the Adaptive Acquisition Framework. These changes are meant to favor speed, commercial adaptability, and scalable solutions. This marks a potentially decisive policy shift away from slower, traditional FAR/Defense FAR Supplement (“DFARS”)-based non-commercial procurements in favor of agile, non-traditional and more commercial-industry solutions oriented methods that seek to reduce administrative burden. While DoD is the principal audience, the move may foreshadow similar reforms across other departments with large procurement portfolios, such as the Department of Energy. 

The April 9 EO calls for comprehensive “reform, right-size, and train[ing]” for DoD’s procurement professionals, including new performance metrics that reward officials who demonstrate “first consideration of commercial solutions” and who “take measured and calculated risks” to deliver capabilities at speed. As the April 9 EO frames it, “the factory floor can be just as significant as the battlefield.” To this end, DoD must submit a plan within 120 days to revise performance metrics for acquisition personnel, increase the use of commercial solutions, and deploy field training teams to help contracting staff implement innovative authorities. Contractors likely can expect an increased openness to novel proposals and ideas and a renewed emphasis on collaboration and end-user outcomes.

At the same time, DoD is undertaking a top-down review of all Major Defense Acquisition Programs (“MDAPs”) to identify those that are behind schedule, over cost, or misaligned with mission priorities. Within 90 days of the April 9 EO, the Secretary of Defense must evaluate any programs that are “more than 15 percent behind schedule,” “15 percent over cost,” or “unable to meet any key performance parameters” for cancellation.” More generally, the Secretary must also review DoD’s internal acquisition regulations to eliminate duplicative or outdated guidance and implement a “ten-for-one” deregulatory rule for new policies. Finally, within 180 days of the April 9 EO, the Secretary and his staff must complete a comprehensive review of the Joint Capabilities Integration and Development System, with the goal of streamlining the acquisition process.

For contractors, this initiative raises key strategic considerations. Companies positioned to offer commercial, dual-use, or rapid-deployment technologies may find new opportunities. Conversely, those supporting legacy MDAPs should evaluate exposure to re-scoping or termination, depending on the state of their programs. While the long-term impacts will depend on implementation details, the April 9 EO represents the beginning of a potentially far-reaching shift in the FAR/DFARS acquisition hierarchy.