Federal Proposal Rules Changed: What A/E Firms Must Do

What Is the FAR Overhaul?

The Federal Acquisition Regulation (FAR) — the rulebook governing how the federal government buys everything, including architecture and engineering services — is being rewritten. Executive Order 14275, signed April 15, 2025, directed agencies to strip the FAR down to only provisions required by statute or necessary for simplicity, efficacy, and security. The result is the most significant change to federal procurement rules in decades. The threshold changes took effect through 2025 and June 2026; the rewrite of the part that governs A/E work reached proposed-rule stage on September 18, 2026, with comments open until October 19.

For A/E firms that pursue federal work through SF330s and qualifications-based selection, this matters. FAR Part 36 — the section that governs construction and A/E contracts — has been reorganized in the overhaul's deviation text, and several provisions proposal teams relied on for 20 years are absent from it. How much of that reaches you depends on which agencies you pursue, for reasons the next section explains.

Most of the coverage so far has been written for general government contractors and procurement attorneys. This post is for the person who actually assembles SF330 packages and wonders what changed and what to do about it.

What Changed in FAR Part 36

The class deviation for Part 36 was issued July 24, 2025, designated RFO-2025-36. Everything described below is that deviation text.

Status: Part 36 is now a proposed rule, and the comment window is open

This section was updated on September 21, 2026.

On September 18, 2026 the FAR Council published the proposed rule that would write Part 36's rewrite into the FAR itself. The citation is 91 FR 59534, FAR Case 2026-010, RIN 9000-AO83, covering Parts 14, 28, 36, and 52. Comments close October 19, 2026. Until that Friday, Part 36 existed as class-deviation text only, and earlier versions of this article said so. For a section-by-section read of the proposed text, see what the FAR Part 36 proposed rule changes for A/E proposal teams. A second rule in the same batch, FAR Case 2026-003, would limit the 6 percent A/E fee cap to cost-type contracts; see what the fee cap proposed rule changes.

The proposed rule adopts the deviation's structure. Its Part 36 carries the same three lifecycle subparts — 36.1 Pre-Solicitation, 36.2 Evaluation and Award, 36.3 Postaward — and A/E provisions stay distributed across them instead of sitting in a subpart of their own. Everything below about the deviation now describes the proposed FAR text as well, and the specifics are noted section by section. Proposed rule read in full 2026-09-21.

Two things did not change on September 18. FAR Part 36 as published still contains Subpart 36.6, 36.602-1, and 36.603 in full — a proposed rule is not the FAR, and nothing in it takes effect until a final rule issues. And the SF330 itself is untouched: the rule states that its information collection, OMB Control No. 9000-0157, "would remain unchanged." For the fuller answer on the form, see what the FAR Council actually asked about the SF330.

An earlier correction still stands. A previous version of this article said the Part 36 changes were formalized on March 13, 2026 under FAC 2026-01. That was wrong: FAC 2026-01 was a single final rule adjusting World Trade Organization and Free Trade Agreement thresholds (FAR Case 2025-007), with nothing to do with Part 36.

So three texts are now in circulation, and only two of them govern anything today: the FAR as published, which still carries the A/E subpart, and the model deviation text, which agencies adopt individually. The third, the proposed rule, tells you where this is heading and is the one you can still comment on.

The practical instruction is unchanged: ask the contracting officer which text applies, and do not assume either way from the solicitation's appearance. Here is what the deviation does.

The Structure Is Completely Different

Part 36 has seven subparts (36.1 through 36.7), with Subpart 36.6 specifically covering A/E services. The deviation text replaces that with three subparts organized by contract lifecycle:

A/E provisions that live in their own subpart (36.6) under the FAR are distributed across the three lifecycle subparts alongside construction provisions under the deviation.

The American Council of Engineering Companies (ACEC), which represents over 5,500 engineering firms and 600,000 professionals, flagged this as a concern in their September 2025 comments — arguing that mixing A/E and construction subparts "creates confusion and increases the potential for errors and/or misuse."

The Standard A/E Evaluation Criteria Are Absent From the Deviation

This is the biggest operational change for SF330 proposal teams.

FAR 36.602-1 lists specific evaluation criteria that agencies must consider when selecting A/E firms:

• Professional qualifications
• Specialized experience and technical competence
• Capacity to accomplish the work
• Past performance
• Location in the general geographical area of the project and knowledge of the locality
• Acceptability under other appropriate evaluation criteria

These criteria are not just guidelines. They are embedded in the FAR, and most federal A/E solicitations used them as the starting point for evaluation factors. Proposal teams could count on them as a baseline when preparing SF330 submittals.

The deviation text carries no equivalent. At an agency operating under it, contracting officers have broader discretion to define their own evaluation criteria for A/E procurements.

The September 18 proposed rule keeps them out. Its evaluation section for A/E services, proposed 36.202-1, rebuilds the evaluation board machinery — who sits on the board, what it evaluates, the selection report — and lists no selection criteria at all. The six criteria above appear nowhere in the proposed Part 36. If this rule is finalized as written, contracting-officer discretion over A/E evaluation factors stops being a deviation-by-deviation question and becomes the FAR.

The Brooks Act — the statute requiring qualifications-based selection for A/E services — is still law either way. Agencies still cannot select A/E firms on price. What is in play is only which qualifications get weighed and how.

What this means in practice: you can no longer assume a federal SF330 solicitation will evaluate you on the "standard six." Some agencies still owe them to you and some do not, and the solicitation itself will not announce which situation you are in. Read every solicitation's evaluation factors and respond to what that specific document says it will evaluate.

Provisions Absent From the Deviation Text

Several provisions proposal teams and project managers rely on have no counterpart in the deviation. They remain in the FAR, so this table describes what changes at an agency that has adopted the deviation. Each row was checked against the September 18 proposed rule. Most absences survive in it: the proposed Part 36 contains no A/E selection criteria and no qualifications data-file system (it does keep the instruction that agencies encourage firms to submit an updated SF330 Part II annually). The debriefing is the exception — the proposed rule brings one back, in weaker form, as described below.

The 12% rule matters for subconsultant-heavy teams. Under FAR 36.501, prime contractors on construction contracts must self-perform at least 12% of the work. Where the deviation applies, that requirement drops away, which gives primes more flexibility in how they structure teaming arrangements — another reason to confirm which text an agency is working from before building a team around the assumption.

The debriefing deletion is the one on that list a proposal manager experiences personally, and it is the provision ACEC singled out in its September 2025 comments. Under FAR 36.607(b), a debriefing of successful and unsuccessful firms "will be held after final selection has taken place." It happens automatically, with no written request required — unlike the Part 15 process most people know. The deviation's Subpart 36.3 contains a single section on contracting officer responsibilities and no release-of-information provision at all. At an agency working from the deviation, ask early whether a debriefing will be held rather than assuming one is owed. Deviation text read in full 2026-08-31.

The September 18 proposed rule restores a debriefing, but not the entitlement. Proposed 36.202-3(f) reads: "Debriefings of successful and unsuccessful firms may be held after final selection has taken place and will be conducted, to the extent practicable, in accordance with 15.301." Set that beside the current FAR's "will be held." The debriefing comes back as something an agency may offer, run on the Part 15 model where practicable, rather than something every firm receives automatically. There is still no counterpart to the current 36.607's release-of-information limits. If the rule is finalized as written, asking early whether a debriefing will be held stops being a deviation workaround and becomes the standing practice. Proposed rule read in full 2026-09-21.

What a debriefing owes you when one does happen — and the three things FAR 36.607 lets the agency withhold — is covered in federal A/E debriefings: what you get and what you don't.

What Was Retained

Not everything changed. Key provisions that remain:

• Brooks Act / QBS — Still law. A/E firms are still selected on qualifications, not price. This is a statute, not a regulation, so the FAR overhaul cannot change it.
• SF330 form — Still the standard vehicle for A/E qualifications submissions. No changes to the form itself.
• Evaluation boards — Still required to hold discussions and to prepare selection reports recommending at least three firms in preference order. One qualifier did not survive. FAR 36.602-1(c) requires discussions with "at least three of the most highly qualified firms." The deviation's 36.202-1(b)(2) says only "Conduct discussions with at least 3 firms." The count carries over; the standard behind it does not. The September 18 proposed rule uses the deviation's wording verbatim. All three texts read in full, the first two 2026-08-31 and the proposed rule 2026-09-21.
• Two-phase design-build — Maximum five offerors may advance to phase two (relocated from 36.303 to 36.101-2).
• Project Labor Agreements — Mandatory for federal construction projects at or above $35 million.

What Changed Outside Part 36 That Affects Proposal Teams

New Dollar Thresholds

Several acquisition thresholds were raised effective October 1, 2025, with further changes that took effect June 30, 2026:

The raised Simplified Acquisition Threshold ($250K to $350K) means more A/E task orders can be awarded with simplified procedures. For small firms working under IDIQs, this may mean faster awards on smaller task orders — but also less formal evaluation documentation from the agency.

The TINA threshold jump from $2M to $10M is significant. A/E firms on contracts below $10M will no longer need to submit certified cost or pricing data, which reduces proposal preparation burden for most mid-size engineering task orders.

FAR Clause Renumbering

The entire FAR clause numbering system is being overhauled. For example, FAR 52.204-21 is now FAR 52.240-93. This has direct implications for any firm that references specific clause numbers in SF330 Section H narratives, compliance matrices, or teaming agreements.

If your proposal boilerplate references specific FAR clause numbers, those references may already be wrong.

Subcontracting Policy Changes

FAR Part 44 (subcontracting) has been relaxed, with reduced documentation requirements. This affects A/E primes who manage subconsultant teams on federal contracts — particularly the reporting burden for subcontracting plans and Individual Subcontract Reports (ISRs).

SAM.gov Absorbed Two Systems Proposal Teams Used

Separate from the FAR overhaul but happening at the same time, two federal systems that proposal and BD teams relied on have been retired and absorbed into SAM.gov.

Why This Matters for Proposal Teams

FPDS was the competitive research tool. If your BD team used FPDS ezSearch to look up what contracts competitors have won, who the incumbent is on a recompete, or what an agency has been buying — that tool is gone. The data is now in SAM.gov, but even public users need a SAM.gov account to access it.

eSRS affects primes with subcontracting plans. "Other than small" prime contractors that are required to submit subcontracting plans must now file their ISR and SSR reports through SAM.gov instead of eSRS. If your firm is a prime on any federal contract with a subcontracting plan, your compliance team needs to update their workflow.

GSA's CPARS (Contractor Performance Assessment Reporting System) is also transitioning to SAM.gov later in 2026. If you track your past performance ratings — which you should, since they feed into future evaluations — expect that interface to change too.

What Your Firm Should Do Now

1. Read every solicitation's evaluation factors from scratch

Stop assuming the "standard six" A/E criteria apply. At an agency operating under the deviation, each contracting officer can define different evaluation factors. Some will stick with the traditional criteria. Others will emphasize different factors or weight them differently.

Read Section L (instructions to offerors) and Section M (evaluation criteria) of every solicitation as if you have never seen a federal A/E procurement before. Match your SF330 response to exactly what that solicitation says it will evaluate.

2. Audit your proposal boilerplate for stale FAR references

If your SF330 Section H narratives, compliance language, or teaming agreements reference specific FAR section numbers, check them. Clause numbers have changed. And a boilerplate citation to "FAR 36.602-1" is now ambiguous rather than simply correct — it still points to live FAR text, but it means nothing at an agency working from the deviation. Citing the substance instead of the section number avoids the problem entirely.

Go through your:

• Standard Section H narratives
• Teaming agreement templates
• Subconsultant agreements
• Quality management plan language
• Any reusable proposal content that cites FAR provisions

Update every FAR reference to the current numbering.

3. Update your competitive research workflow

If your BD team used FPDS ezSearch to research competitors and past awards, that tool was retired on February 24, 2026. You need a SAM.gov account (even for public searches) and need to learn the new contract data search interface.

Set up SAM.gov accounts for everyone on your BD team who does competitive research. Do it this week — there is a learning curve, and you do not want to figure it out the night before a pursuit decision.

4. Check your subcontracting plan compliance

If your firm is a prime on federal contracts with subcontracting plans, make sure your reporting has transitioned from eSRS to SAM.gov. The eSRS system was permanently retired on February 20, 2026. Missing or late subcontracting reports create past performance problems that affect future evaluations.

5. Brief your project managers on the 12% rule removal

The elimination of the 12% prime contractor self-performance rule changes teaming math. If your firm uses subconsultants heavily on federal construction contracts, you have more flexibility now. But it also means your competitors have that same flexibility — expect to see different teaming structures on upcoming pursuits. Deciding whether to prime or sub is a different calculation than it was two years ago.

6. Review your staff qualifications data

With contracting officers now setting their own evaluation criteria, the information you need to highlight in each person's resume may vary more from solicitation to solicitation. Having staff qualifications stored in a structured system — where you can generate different resume versions emphasizing different skills and experience for each pursuit — matters more when the evaluation criteria are less predictable. This is the case for a reusable qualifications library rather than a folder of past submittals.

RFPM.ai stores staff profiles as structured data so resume sections generate automatically for each pursuit. When evaluation criteria vary between solicitations, generating tailored SF330 Section E resumes from a single source of truth saves hours of reformatting.

7. Comment before October 19

This is the one item on this list with a deadline, and it arrived on September 18. Part 36 spent a year as deviation text with no docket attached to it. It now has one: FAR Case 2026-010, Docket No. FAR-2026-0010, at 91 FR 59534. Comments close October 19, 2026. They go through regulations.gov, and the rule asks that you cite "FAR Case 2026-010" in the comment and on any attachment.

ACEC has been making the A/E case since its September 2025 comments on the deviation, particularly on the absent evaluation criteria, on reduced transparency in awards and debriefs, and on A/E provisions scattered among construction subparts. The proposed rule answers those unevenly: the criteria are still absent, the debriefing returns only as "may be held," and A/E gets its own sections (36.102, 36.202) but they still sit inside the same lifecycle subparts as construction. If either one changes how your firm competes, the window that was "still ahead of you" in every earlier version of this article is the four weeks in front of you now. Your trade association (ACEC, SMPS, SAME) may also be coordinating an industry response.

Timeline of Changes

Who Should Care About This

Proposal managers and coordinators: You need to know that evaluation criteria are no longer standardized and that your FAR boilerplate references may be wrong. These are the people who will catch or miss these changes in live submittals.

BD directors: Your competitive research tool (FPDS) moved. Your subcontracting reporting system (eSRS) moved. And the evaluation landscape for federal A/E work just got less predictable. Adjust your pursuit processes accordingly, and see what to do before FY2027 starts for the positioning calendar.

Principals and firm leaders: The Brooks Act is still intact. The government still buys A/E services on qualifications. But the details of how they evaluate those qualifications are now more variable. Firms that adapt their proposal processes will have an advantage over firms that keep submitting the same way they did in 2024.

Frequently Asked Questions

Does the FAR overhaul change the SF330 form?

No, and the FAR Council said so in terms on September 18, 2026: the proposed rule states that the SF330 information collection, OMB Control No. 9000-0157, "would remain unchanged." The SF330 (Standard Form 330, Parts I and II) remains the primary vehicle for demonstrating A/E qualifications in federal procurements. The form itself has not changed. What changed is how agencies evaluate SF330 submissions: the overhaul's Part 36 deviation text carries no equivalent of the standardized evaluation criteria at FAR 36.602-1, so agencies operating under it set their own.

Is qualifications-based selection still required for A/E contracts?

Yes. The Brooks Act (Public Law 92-582) is a federal statute requiring that architecture and engineering services be procured through qualifications-based selection (QBS). The FAR overhaul cannot change a statute. Agencies still cannot select A/E firms based on price competition. They must evaluate firms on competence, qualifications, and experience — but they now have more discretion in defining exactly which qualifications matter for each procurement.

Do I need to update my SF330 Part II?

Your Part II format stays the same, but review its content. With evaluation criteria varying more between solicitations, agencies may request different information or weight different qualifications. Make sure your Part II reflects current staff, certifications, project experience, and firm data — see what goes in SF330 Part II and how to keep it current. And check that any FAR references in your Part II narrative are updated to the new numbering system.

How do I do competitive research now that FPDS is gone?

The contract award data that was in FPDS is now in SAM.gov, a migration covered in full in what the SAM.gov changes mean for proposal managers. You need a SAM.gov user account to access it — even for public searches. The interface is different from the old FPDS ezSearch tool. GSA has published user guides for the new search. Allow time for your team to learn the new system.

When do these changes become permanent?

Not yet, and Part 36 now has a visible path. Phase 1 changes (class deviations) are in effect at the agencies that adopted them. Phase 2 is formal notice-and-comment rulemaking, and Part 36 entered it on September 18, 2026 with a proposed rule at 91 FR 59534. Comments close October 19, 2026. A final rule follows after the FAR Council works through the comments, and provisions may change between the proposal and that final rule. Non-statutory provisions that survive the overhaul will be subject to automatic four-year sunset clauses unless renewed.