Where things stand (checked October 31, 2026)
Three versions of the FAR are in play at once:
- The FAR as codified. The text at acquisition.gov/far, at FAC 2026-01 (effective March 13, 2026).
- Class deviations. Agencies adopted the Overhaul's model text by deviation, part by part, and the model text keeps being updated. New awards may carry these clauses before any rule is final.
- Proposed rules. The formal rulemaking. The first set, including Part 40, was published June 23, 2026 with comments due July 23. The second, FAR Case 2026-011 covering Parts 9, 27 and 47, was published September 18, 2026 with comments due October 19, 2026. We found no final rule for either when this guide was checked.
This is general information, not legal advice, and this area is moving. The clause in your contract is the one that binds you.
What the Part 9 proposed rule does for subcontracting
| Topic | FAR today | Proposed (FAR Case 2026-011) |
|---|---|---|
| Subcontract limit | FAR 9.405-2(b): over $45,000, COTS excepted | Kept: same section, same figure, same COTS exception |
| Who it covers | Debarred, suspended, proposed for debarment, voluntarily excluded | Kept |
| Clause | 52.209-6, prescribed at 9.409 | Kept as 52.209-6, prescribed at 9.408, with an Alternate I for commercial products |
| Compelling reason and notice | Written notice to the contracting officer first | Kept |
| Purchasing system reviews | 9.405-2(c): compliance reviewed in CPSRs | Kept |
| FAPIIS | The name appears throughout | Replaced by "integrity records": GSA retired FAPIIS; records are read in SAM.gov and reported in CPARS.gov |
| Clause numbers overall | 52.2xx | The Council asks for comment on a new subpart that would renumber them, for example 52.4 in place of 52.2 |
Read together, the obligations a prime carries in Part 9 survive this draft nearly intact, so the near-term risk is a stale template rather than a new duty.
Three things a prime can act on
1. Check the renumbering that has already happened. Part 9 keeps its number, but the security clauses don't: Section 889 now goes by 52.204-25 or 52.240-91, depending on the contract, with a different reporting window. Basic safeguarding (52.204-21) has a deviation counterpart too, 52.240-93.
2. Build your flow-down from the prime contract, not last year's list. A flow-down exhibit keyed to a fixed set of clause numbers will drift. Map each prime clause to its subcontract wording, and note which version of the FAR each prime contract is under.
3. Stop saying FAPIIS, gradually. The records haven't gone anywhere, but the name is on its way out, and your procedures and vendor forms should say what you actually check: integrity records in SAM.gov.
What doesn't change
Nothing in the proposed Part 9 text removes the need for what a good screening file already holds:
- The right company, identified by UEI or CAGE
- A dated exclusions check close to award
- The sub's written disclosure, covering its principals
- A record of each decision
The pre-award checklist is written so it holds under any of the three versions. Watch's checks read the public records rather than a clause number, so they carry on unchanged. Its questionnaires and templates cite today's clause numbers, so compare them with your contract.