Four Revolutionary FAR Overhaul proposed rules published in the Federal Register on September 18, 2026, with comments due October 19. The one that matters most to Schedule holders is FAR Case 2026-003, which rewrites FAR Part 8 and FAR Part 38 — the parts that govern required sources and Federal Supply Schedule contracting. This is the last structured chance to influence the rules before they are finalized.
Which FAR cases are actually open for comment right now?
FAR Cases 2026-003, 2026-006, 2026-010, and 2026-011. All four published September 18, 2026 and close October 19, 2026. If you have read that 2026-001, 002, 005, and 007 are the open ones, that is out of date — those four published June 23 and closed July 23.
I am being blunt about this because I have already seen the wrong case numbers circulating in industry write-ups this week. Commenting on a closed docket accomplishes nothing. Check the case number before you spend an afternoon writing.
| Case | FAR Parts | What it governs |
|---|---|---|
| 2026-003 | 8, 12, 13, 15, 38, 44, 51, 52 | Required sources, commercial items, simplified acquisition, negotiation, Federal Supply Schedule contracting, subcontracting |
| 2026-006 | 16, 17, 35, 52 | Contract types, special contracting methods, research and development |
| 2026-010 | 14, 28, 36, 52 | Sealed bidding, bonds and insurance, construction |
| 2026-011 | 9, 27, 47, 52 | Contractor qualifications and responsibility, patents and data rights, transportation |
The authoritative list lives on acquisition.gov's Federal Register publications requesting comments page. It shows what is open, what recently closed, and links straight to the comment form for each case. Bookmark that page rather than relying on a summary.
Why does FAR Case 2026-003 matter more than the others if you hold a Schedule?
Because Part 8 and Part 38 are the Schedules program's own furniture. Part 8 sets the required-sources hierarchy that tells ordering activities when to buy from a Schedule. Part 38 governs Federal Supply Schedule contracting itself. Rewriting both at once touches how your contract is awarded, administered, and ordered against.
Bundled into the same case are Part 12 (commercial products and services), Part 13 (simplified acquisition), and Part 15 (contracting by negotiation) — the three parts that shape how a Contracting Officer structures a buy in the first place. Then Part 44 (subcontracting policies) and Part 51 (contractor use of government sources).
If you sell through a Schedule, that single case covers the path a dollar takes from an agency requirement to your invoice.
I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy, and I sat in rule-making working groups on the government side. The parts that get the least industry comment are usually the procedural ones — and procedural text is exactly what determines whether your order gets placed against your Schedule or competed somewhere else.
What is the "You Said, We Did" resource, and why should you read it first?
It is acquisition.gov's published record of how Phase 1 stakeholder feedback changed the rules between the model deviations and these proposed rules. Read it before drafting, because it shows you empirically which kinds of comments moved the text and which did not.
This is the closest thing to a scoring rubric you will ever get for a regulatory comment. The FAR Council is telling you, in writing, what it found persuasive.
What that record consistently rewards:
- A specific provision cited by number, not a general objection to the direction of the rule.
- A concrete operational consequence — what breaks, for whom, at what point in the process.
- Proposed replacement language. A rule-writer facing a deadline will take usable text over a complaint.
- Evidence. A number, a timeline, a documented case.
How do you write a comment a rule-writer will actually use?
Write it the way the person on the other side needs to receive it: one provision per comment, the operational problem stated plainly, and replacement language they can paste. Comments that read as position statements get logged. Comments that hand over usable text get adopted.
From the government side of the table, I can tell you what the pile looks like. Hundreds of submissions arrive. Most are three paragraphs of general concern with no citation and no proposed fix. Those get counted and summarized. The handful that say "Section X, paragraph (b)(2) creates this specific problem, and here is language that solves it" get worked.
- Identify the exact provision. Part, section, paragraph. If you cannot cite it, you are not ready to comment on it.
- State the operational consequence in one or two sentences. Not "this is burdensome" — rather, what task becomes impossible, or what cost appears, and at which step.
- Quantify it. Hours, dollars, days of delay, number of contracts affected. A rule-writer needs something to put in the regulatory impact discussion.
- Propose replacement text. Write the sentence you want to see in the FAR.
- Explain why your language still achieves the government's objective. This is the step most commenters skip, and it is the one that makes adoption defensible.
- Submit one comment per issue through the Federal eRulemaking Portal rather than one long document covering six unrelated concerns.
The Short Version
Four cases are open — 2026-003, 2026-006, 2026-010, 2026-011 — not the June batch. Comments close October 19, 2026. Case 2026-003 rewrites FAR Parts 8 and 38, the Schedules program's own parts. Read the "You Said, We Did" record first, then comment provision by provision with replacement language. Cite, quantify, propose.
Does a single contractor's comment actually change anything?
Yes, more often than contractors assume — but only on narrow, well-evidenced points. Nobody talks the FAR Council out of the overhaul. People do routinely get a threshold adjusted, a definition clarified, or an implementation date moved, because they showed a specific unworkable consequence.
Set your expectations at the right altitude. The strategic direction of the Revolutionary FAR Overhaul is settled policy and your comment will not reverse it. The implementation details are genuinely open, and those details are where your contract administration burden actually lives.
The realistic wins available to you:
- Definitional clarity where ambiguous text would produce inconsistent treatment across contracting offices.
- Threshold adjustments where a dollar figure produces an absurd result at the margin.
- Transition and implementation timing where compliance requires system or process changes you cannot make overnight.
- Internal inconsistency — one part saying something another part contradicts. Rule-writers want these found.
That last category is the most reliably successful, and the least glamorous. When eight FAR parts are rewritten in one case, cross-references break. Finding a broken one and naming it is a genuine service, and it gets fixed.
What should a GSA Schedule holder do between now and October 19?
Read Case 2026-003 against your own contract administration reality, not in the abstract. You already know where the current process hurts. Check whether the proposed text fixes it, worsens it, or leaves it alone.
Across our 70+ proven GSA contract awards, the friction points that come up most are ordering procedures under Part 8, scope determinations, and how commercial-item treatment under Part 12 interacts with Schedule pricing. All three sit inside this one case. If you have ever lost an order to a scope argument you thought was wrong, the language that produced that argument is on the table right now.
For the mechanics of what the earlier FAR cases changed — the Part 10 merger into Part 7, the service-contract definition, the pre-solicitation thresholds — I covered those in the FAR Rewrite 2026 breakdown. Those four cases are closed to comment, but their final text will interact with what is proposed now.
What Is the Bottom Line?
- Verify the case number before you write. The open cases are 2026-003, 2026-006, 2026-010, and 2026-011. The June batch closed July 23.
- Comments are due October 19, 2026, submitted through the Federal eRulemaking Portal at regulations.gov.
- Prioritize Case 2026-003 if you hold a Schedule. It rewrites FAR Parts 8 and 38 along with Parts 12, 13, and 15.
- Read the "You Said, We Did" record first. It is a published account of which comment styles actually changed the text.
- Cite the provision, quantify the consequence, propose the replacement language. One issue per comment.
- Hunt for broken cross-references. Eight parts rewritten in one case guarantees some, and reporting them is the highest-success-rate comment you can file.
I hold FAC-C Level III certification and a Master of Liberal Arts from Harvard University, and I read these rules the way the Contracting Officer who will apply them reads them. If you want help working out how the proposed Part 8 and Part 38 text lands on your specific contract — or you would rather have your Schedule managed by someone tracking these changes as they finalize — that is what the GSA Maintenance program is for.
Frequently Asked Questions
Which FAR Overhaul cases are open for comment right now?
FAR Cases 2026-003, 2026-006, 2026-010, and 2026-011, all published September 18, 2026 with comments due October 19, 2026. Cases 2026-001, 2026-002, 2026-005, and 2026-007 published June 23 and closed July 23, so comments on those are no longer accepted.
When is the FAR Overhaul comment deadline?
October 19, 2026 for all four currently open cases. Comments go through the Federal eRulemaking Portal at regulations.gov, and acquisition.gov links directly to the comment form for each case.
Which case affects GSA Schedule holders most?
FAR Case 2026-003. It covers FAR Part 8 (required sources) and Part 38 (Federal Supply Schedule contracting), which govern the Schedules program itself, plus Parts 12, 13, and 15 on commercial items, simplified acquisition, and negotiation.
Can one contractor's comment really change a FAR rule?
On narrow, well-evidenced points, yes. Comments do not reverse the overhaul's direction, but they regularly move thresholds, clarify definitions, adjust implementation timing, and fix internal inconsistencies. The determining factor is specificity, not volume.
What makes a FAR comment more likely to be adopted?
Citing the exact provision, stating the operational consequence concretely, quantifying it, and proposing replacement language that still achieves the government's objective. Comments that read as general position statements get logged and summarized; comments that hand a rule-writer usable text get worked.
What is the "You Said, We Did" resource?
It is acquisition.gov's published record of how Phase 1 stakeholder feedback changed the rules between the model deviations and these proposed rules. Reading it before you draft shows you which kinds of comments actually moved the text.
Should I submit one comment covering everything, or several?
Several — one issue per comment. A single long document covering six unrelated concerns is harder to route to the right rule-writer, and individual points are more likely to be lost inside it.