Summary
The Trump administration's second term has ushered in a dynamic shift in federal procurement, marked by an aggressive push to streamline processes, reduce waste, and align government purchasing with fiscal and policy priorities. In just four months, the Trump Administration issued over 200 executive orders (EOs), directives, and proclamations, many of which targeted federal government procurement and the spending of taxpayer money. While several orders address what the government buys, a series of pivotal executive orders (EOs) focus on how it buys goods and services, setting the stage for transformative reforms in federal acquisition. This article explores four key executive orders—EO 14275, EO 14271, EO 14265, and EO 14240—and their implications for government contractors, agencies, and the broader procurement ecosystem.
The Trump administration’s second term has ushered in a dynamic shift in federal procurement, marked by an aggressive push to streamline processes, reduce waste, and align government purchasing with fiscal and policy priorities. In just four months, the Trump Administration issued over 200 executive orders (EOs), directives, and proclamations, many of which targeted federal government procurement and the spending of taxpayer money. While several orders address what the government buys, a series of pivotal executive orders (EOs) focus on how it buys goods and services, setting the stage for transformative reforms in federal acquisition. This article explores four key executive orders—EO 14275, EO 14271, EO 14265, and EO 14240—and their implications for government contractors, agencies, and the broader procurement ecosystem.
Executive Order 14275: Restoring Common Sense to Federal Procurement
Overview
Dubbed the Revolutionary FAR Overhaul (RFO) or “FAR 2.0,” Executive Order 14275 aims to create the most agile, effective, and efficient procurement system in decades by revising the Federal Acquisition Regulation (FAR) for the first time in over 40 years. The RFO seeks to eliminate unnecessary regulations, simplify procurement processes, and expand the national and defense industrial bases. The guiding principle is that the FAR should include only provisions mandated by statute or essential to sound procurement, with non-essential provisions removed.
Key elements include:
- Reforming the FAR: Streamlining regulations to focus on statutory requirements and simplicity.
- Aligning agency supplements: Ensuring that supplements, such as the Defense Federal Acquisition Regulation Supplement (DFARS), adhere to the revised FAR.
- Sunsetting non-statutory provisions: Introducing a four-year expiration for non-statutory FAR requirements.
Implementation and Expectations
Trump tasked the Office of Federal Procurement Policy (OFPP) with amending the FAR to prioritize simplicity, usability, and economic or national security interests. Agencies must align their supplements with the FAR, adhering to the “ten-to-one” deregulation rule from EO 14192, which mandates removing ten regulations for every new one added. Accordingly, the OMB (Office of Management and Budget) provided guidance on May 2, 2025, that emphasized “plain language” deviations starting with FAR Part 1. Therefore, the FAR Council is expected to issue “class deviations” to temporarily exempt specific requirements under the FAR.
The General Services Administration (GSA) has already issued model deviation text for FAR Parts 1, 10, 34, and 52, targeting exceptions for contract categories misaligned with administration priorities. The OMB is also developing OFPP-endorsed buying guides to replace non-statutory regulations, collectively forming the Strategic Acquisition Guidance (SAG).
Contractor Implications
Contractors should:
- Monitor SAG development and assess impacts on internal policies and contract portfolios.
- Engage in public comment opportunities during formal rulemaking to shape regulations and buying guides.
- Maintain communication with agency program offices and contracting officers to stay informed about evolving requirements.
While immediate shifts are premature, contractors must prepare for a more streamlined FAR that emphasizes compliance with statutory mandates and cost-effective procurement.
Executive Order 14271: Ensuring Commercial, Cost-Effective Solutions
Overview
EO 14271 emphasizes the maximization of commercially available products and services to eliminate wasteful spending on custom-developed solutions. It reinforces the Federal Acquisition Streamlining Act of 1994 (FASA), which encourages leveraging the competitive marketplace and private-sector innovation to deliver cost-effective services.
Implementation and Expectations
Agencies are reviewing open solicitations, pre-solicitation notices, and award notices for non-commercial products or services. By mid-July 2025, agency approval authorities must assess these solicitations for FASA compliance and recommend commercial alternatives where feasible. By mid-August 2025, agencies will submit annual reports to the OMB detailing their adherence to FASA.
Additionally, procurements of non-commercial solutions will require agency approval. These procurements may also be subject to OMB review, with contracting officers conducting thorough market research to identify commercial options.
Contractor Implications
Contractors offering commercial products, especially those adaptable to agency needs, are well-positioned to benefit from this opportunity. Key actions include:
- Engaging early in acquisition planning to influence requirements toward commercial solutions.
- Demonstrating how products meet agency needs cost-effectively.
- Monitoring solicitation notices for opportunities to propose commercial alternatives.
EO 14271 is likely to increase scrutiny during the pre-award phase, with a greater emphasis on market research and commercial viability.
Executive Order 14265: Modernizing Defense Acquisitions
Overview
EO 14265 addresses the need for a faster, more flexible defense acquisition system to maintain military superiority. It targets the Department of Defense’s (DOD) antiquated processes, aiming to deliver state-of-the-art capabilities at speed and scale. The EO covers five areas:
- Reforming defense acquisition processes.
- Reviewing and streamlining regulations, including DFARS.
- Overhauling the requirements generation process.
- Evaluating major defense acquisition programs (MDAPs).
- Reforming the acquisition workforce.
Implementation and Expectations
By mid-June 2025, the Secretary of Defense must submit a reform plan that prioritizes existing authorities, such as the Other Transactions Authority (OTA), and commercial solutions. Then, in mid-July 2025, a comprehensive review of MDAPs will identify programs that exceed cost or schedule by 15%, fail to meet performance parameters, or are misaligned with mission priorities, potentially leading to cancellations. By mid-August 2025, the DOD will propose reforms to train and right-size the acquisition workforce.
The EO also promotes deregulation through the “ten-for-one rule” and streamlined requirements development to accelerate acquisitions.
Contractor Implications
Contractors face risks and opportunities:
- Risks: Underperforming MDAPs risk termination, which can impact contractors with delayed or over-budget programs.
- Opportunities: Reduced regulatory burdens and increased use of OTAs may offer greater flexibility and faster contract award processes.
- Contractors should align offerings with DOD priorities, emphasizing innovation and commercial solutions, and prepare for workforce changes that may affect contract administration.
Executive Order 14240: Consolidating Procurement to Eliminate Waste
Overview
EO 14240 reinvigorates the GSA’s role as the federal government’s centralized procurement authority, reversing decades of fragmented agency-led purchasing. The GSA, established in 1949 to deliver economical and efficient procurement, has a mandate to reduce duplication, cut costs, and allow agencies to focus on their core functions. The EO designates the GSA as the executive agent for government-wide IT acquisition contracts (GWACs).
Implementation and Expectations
By late June 2025, the GSA administrator must submit a plan to the OMB for procuring common goods and services across the government. Agencies are developing proposals for GSA-led procurement of shared categories, guided by the Category Management Leadership Council (CMLC). The GSA’s “OneGov” strategy aims to unify federal purchasing by focusing on common spending categories.
Reports from May 21, 2025, indicate that the GSA may assume oversight of GWACs, such as NASA SEWP and CIO-SP3/4, potentially affecting billions of dollars in spending. Contractors should monitor these transitions, especially as follow-on contract reevaluations.
Contractor Implications
Contractors should:
- Understand category management and align products with CMLC-defined categories.
- Familiarize themselves with GSA contract vehicles, such as schedules and GWACs.
- Demonstrate how solutions deliver value and efficiency, aligning with administration priorities.
As the GSA’s role expands, contractors must adapt to centralized procurement processes and compete in a more unified marketplace.
The Road Ahead
The Trump administration’s procurement reforms signal a seismic shift in federal acquisition, emphasizing efficiency, commercial solutions, and centralized authority. While these changes promise long-term benefits, they introduce near-term uncertainties for contractors. Key recommendations include:
- Stay Informed: Monitor FAR deviations, SAG development, and agency-specific guidance.
- Engage Proactively: Participate in rulemaking, engage with contracting officers, and influence requirements during the acquisition planning process.
- Adapt Strategically: Align offerings with commercial and category management priorities and prepare for streamlined regulations and centralized procurement.
Compliance with core accounting processes and contract performance requirements remains critical, even as regulations evolve. Contractors should leverage industry expertise, such as that offered by Baker Tilly’s government contractor solutions professionals, to navigate this complex landscape.
The road to reform will be gradual, with agencies tasked with assessing their contract landscapes and implementing deviations before formal rulemaking concludes. By maintaining open communication with government counterparts and staying agile, contractors can position themselves to thrive in this transformative era of federal procurement.
Next Steps
If you are a government contractor (or considering becoming one), now is the time to review your contracts and assess how they may be affected by the changes discussed above. If you’re considering government procurement as a new opportunity, now is also a great time to get started. For new and existing acquisition participants, your success depends heavily on your ability to not only provide the government with commercial (and customized) products but also to do so as a US source, offering the best price and having the capability to deliver the quantities sought consistently.
It’s time for you to get strategic and consider ways to expand your offerings, position yourself to win, and utilize systems that give you a competitive advantage. The greater your ability to adapt and pivot in response to government procurement changes and needs, the more likely you are to have continued success.
Stay alert! Continue to monitor the changes and develop a plan to keep your business procurement ready.
