Federal Acquisition Registration Rule Update
Summary
This document summarizes the Federal Acquisition Regulation (FAR) rules agreed to by OFPP, DoD, GSA, and NASA (collectively referred to as the Federal Acquisition Regulatory Council) in this Federal Acquisition Circular (FAC) 2025-05. A companion document, the Small Entity Compliance Guide (SECG), follows this FAC.
Compliance Requirements
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Offerors are required to be registered at the time of proposal submission and at time of award, rather than continuously in between.; Administrative changes are made at FAR 32.907, 43.101, and 52.247-60.
Market Impacts
The change in System for Award Management preaward registration requirements from continuous registration to registration at the time of proposal submission and at time of award is expected to have a positive impact on small businesses who have a minor lapse in registration.; Offerors are required to be registered in the System for Award Management at the time of proposal submission and at time of award.
Validated Company Impacts
AECOM
AECOM's Americas segment provides planning, advisory, consulting, architectural and engineering design, construction management and program management services to public clients in the United States, making it a direct participant in federal procurement markets subject to FAR requirements. The company's business model involves submitting proposals for federal contracts, which directly aligns with the rule's requirements for System for Award Management registration at proposal submission and award. The rule directly addresses the company's identified 'Government Contract Regulations' risk by modifying federal procurement registration requirements, which could impact compliance costs and contract eligibility. This aligns perfectly with the company's regulatory compliance risk category and could materially affect their government contracting operations.
ASGN Inc
ASGN Inc has a Federal Government Segment that delivers IT solutions to government agencies, directly participating in federal procurement markets where this FAR rule applies. The company's operations as an offeror in government contracting would be subject to the System for Award Management registration requirements specified in the rule. The rule focuses on federal procurement registration requirements, which does not align with any of the company's disclosed risk factors. The company's risks center on goodwill impairment, segment dependence, competition, cybersecurity, and revenue fluctuations, none of which relate to federal contracting compliance or registration processes.
CACI INTERNATIONAL INC /DE/
CACI operates extensively in federal procurement markets as a government contractor, providing technology and expertise to domestic agencies, which directly aligns with the FAR requirements for offeror registration in the System for Award Management at proposal submission and award times. The rule addresses federal procurement registration requirements which does not align with any of the company's disclosed risk factors. The company's risks focus on financial constraints, economic conditions, credit utilization, cybersecurity, and contract variability, none of which relate to federal contracting registration processes.
Leidos Holdings, Inc.
Leidos Holdings operates extensively in federal government contracting, specifically providing defense and technology solutions to agencies like DoD and NASA, which are directly governed by the Federal Acquisition Regulation. The rule's requirements for System for Award Management registration at proposal and award times directly apply to Leidos as a frequent offeror in federal procurement markets. The rule addresses federal procurement registration requirements, which could potentially mitigate contract cancellation risk by reducing administrative burdens, but this is an indirect and minor connection. The company's primary risks (cybersecurity, debt, budget cuts, goodwill) show no meaningful overlap with the rule's focus on registration timing in government contracting.
PARSONS CORP
Parsons Corp is a major federal government contractor that derives significant revenue from federal procurement contracts, particularly in defense, intelligence, and infrastructure sectors. The company's core business operations involve submitting proposals and receiving awards through the System for Award Management, directly aligning with the rule's registration requirements for offerors in federal procurement. The rule directly addresses the company's third-highest risk factor 'Compliance with procurement rules' by modifying System for Award Management registration requirements, which could reduce compliance burdens and penalties. This aligns perfectly with the company's operational and regulatory compliance risk categories, as changes to federal acquisition procedures directly impact their government contract operations and compliance obligations.
Science Applications International Corp
SAIC operates exclusively as a government contractor and subcontractor for U.S. federal agencies, primarily through long-term contracts that require proposal submissions and awards subject to FAR regulations. The company's entire business model revolves around federal procurement processes directly governed by the Federal Acquisition Regulation system. The rule directly addresses the company's 'Dependence on Government Contracts' risk by modifying federal procurement registration requirements, which could reduce administrative burdens and registration-related performance fluctuations. This aligns with both market and operational risk categories that the company has identified as significant.
WillScot Holdings Corp
WillScot Holdings Corp operates in government and institutional markets, but its business model focuses on leasing and selling modular space and storage solutions rather than being an offeror in federal procurement processes. The company's operations do not involve submitting proposals or awards under the Federal Acquisition Regulation system. The rule directly addresses the company's second-highest risk factor 'US Government Contract Laws' by modifying federal acquisition registration requirements, which could reduce compliance costs and liability exposure for government contractors. This aligns with the company's regulatory compliance risk profile and specifically impacts their government contracting operations.
MAXIMUS, INC.
MAXIMUS operates extensively in federal procurement through its U.S. Federal Services Segment, which delivers solutions to U.S. federal government agencies and would be directly subject to FAR requirements as an offeror. The company's business model involves submitting proposals and receiving awards from federal agencies, making it clearly affected by the System for Award Management registration requirements. The rule's focus on federal procurement registration requirements has minimal alignment with the company's identified risk factors. While the company mentions federal government shutdown as a market risk, this rule addresses administrative registration timing rather than contract disruption or revenue realization concerns.