Counsel Commentary: The FAR Part 19 Overhaul and Small Business Government Contractors

The much-anticipated update to FAR Part 19 presented a mixed bag for small business government contractors when announced earlier this year.

The most significant revisions pertain to the Rule of Two, the recertification rules for task and delivery orders under multiple-award contracts, and the competition requirements for contracts awarded under the Small Business Administration’s (SBA) 8(a) Business Development Program.   

In his monthly Contract Management magazine column, “The FAR Part 19 Overhaul,” Rogers Joseph O’Donnell shareholder Stephen L. Bacon writes that some changes will increase opportunities for small business government contractors, while others are likely to reduce the number of set-aside procurements.  

“The FAR Part 19 overhaul represents a significant shift in small business contracting policy, but the real-world impact remains uncertain,” Bacon writes. “While the updated FAR is being formally codified through the rulemaking process, the new provisions are already taking effect through agency class deviations.”

This article was published in the December 2025 issue of Contract Management magazine by the National Contract Management Association (NCMA). Access to the full article in NCMA’s online content library is subject to NCMA’s article access policies.

View a PDF of the article here.