Your DFARS deviation may already be superseded

Two terms before the numbers

Class deviation

A signed DPCAP memo that tells contracting officers to use attached text "in lieu of the text codified at 48 CFR chapter 2". It "remains in effect until rescinded or incorporated into the FAR, DFARS, and DFARS PGI". Under the RFO there is one per DFARS part.

Revision

A new memo under the same tracking number. Its first sentence says it revises and supersedes the earlier memo, and names the date that memo was issued. From that day, the earlier memo is history.

01Two waves: the first issues, then the revisions

The Department's RFO class deviations arrived in a rush. Of the 46 memos issued as a first issue, 45 came between December 2025 and March 2026, and 29 of those in December alone. For most of the spring, the set was quiet.

Then the second wave began. DPCAP issued eight revisions in July and eight in August, one per part, each replacing the memo before it. September added three more: DFARS Part 207 on September 2, 2026, DFARS Part 240 on September 3, 2026 and DFARS Part 245 on September 9, 2026.

What it means for you: the memo you read at proposal time and the memo in effect at award can be different documents. When a solicitation, an award or a modification carries a deviation clause, set the date on it against the revision dates on DPCAP's index, and keep a note of which revision you relied on.

02What the sixteen revisions change for a contractor

Most of the revisions do more than renumber. Each memo says in its own words what it implements, and below is that sentence for every one, grouped by the part of a contractor's business it reaches. Each tracking number links to the signed memo on DPCAP's site, checked byte for byte against the copy this piece quotes.

The thread that runs through the first group is the nontraditional defense contractor. Section 1826 of the National Defense Authorization Act for Fiscal Year 2026 reached four of these parts: DFARS 215 (contracting by negotiation), DFARS 231 (contract cost principles and procedures), DFARS 234 (major system acquisition) and DFARS 244 (subcontracting policies and procedures). A company that qualifies as nontraditional, and has read only the winter memos, is preparing for requirements the current memos exempt it from unless the requirement is waived.

For everyone else, the cost accounting revision matters on its own. Class Deviation 2026-O0006, Revision 1 raises the thresholds for disclosing cost accounting practices and for waiving the standards, so a business unit that read the winter memo may have been preparing a Disclosure Statement it no longer owes.

03One part, three memos: DFARS Part 240

DFARS Part 240, information security and supply chain security, shows how fast a single deviation can move. Revision 1 is dated June 29, 2026 by the memo that replaced it. On July 5, 2026, a federal court in the Northern District of California ordered a temporary carve-out for Alibaba from the prohibitions tied to the Department's list of Chinese military companies. On July 13, 2026, the Department of War Chief Information Officer suspended the move to Phase 2 of the Cybersecurity Maturity Model Certification (CMMC) program.

Revision 2, issued July 16, 2026, put both into the DFARS. Its opening instruction to contracting officers reads:

"Contracting officers must collaborate with requiring activities to remove or revise the Cybersecurity Maturity Model Certification (CMMC) requirements in new and existing solicitations and contracts"

Revision 3, issued September 3, 2026, kept both instructions and added three prohibitions that appear nowhere in Revision 2:

Semiconductors

"which prohibits procurement of any covered semiconductor products and services"

Unmanned aircraft

"Section 817 of the NDAA for FY 2023, which prohibits the use and procurement of certain unmanned aircraft systems"

Department employee data

"prohibit contractors from selling, licensing, or otherwise transferring covered individually identifiable DoD employee data"

What it means for you: a contractor who read Revision 2 in August saw the CMMC instruction and none of those three prohibitions. And Revision 2 is still easy to find. The memo is served at its July address, byte for byte what it was when signed, while DPCAP's index no longer links it. Nothing in the document itself can tell you it has been replaced.

04How to check the version you hold

Four habits cover it, and none of them takes a subscription:

1. Start at the index, not at a saved copy. DPCAP's DFARS RFO class deviation page is the authoritative list. As served on September 28, 2026, it is byte for byte the copy every count in this piece was taken from.
2. Read the memo's first sentence. A revision names the memo it supersedes and the date that memo was issued. If the memo you hold is the one named there, it is out of date.
3. Read the FAR part the memo points to. Each DoW memo tells contracting officers to use the FAR Council's rewritten part on acquisition.gov, for example FAR Overhaul Part 31 for the cost principles, alongside the attached DFARS text.
4. Write down which revision you relied on. Put the tracking number, the revision and its date in the proposal file or the subcontract file.

05Where GovConDash fits: the FAR Overhaul sub-tab

The FAR Overhaul sub-tab sits under Research / Regulations & Policy. It holds every Department of War RFO class deviation as its own row, revisions included, with the signed memo in full. A weekly check of DPCAP's index, every Sunday, adds a new revision as it appears. It opens on a free account.

1See what is in effect and what was replaced

The header counts both: 48 memos in effect and 20 superseded revisions kept on file. The superseded rows stay because the memo that governed a contract on a given day is the one to read about that day.

2Follow one deviation through every revision

Search a tracking number and the whole chain comes back in order. The revision in effect is marked, each row says which memo it replaces and when that memo was issued, and each superseded row says what replaced it.

3Search every memo for the term that reaches you

The search reads the text of every memo and its attachments, not only the titles. Type the phrase that describes your company and see every deviation that uses it, with the passage, before opening a hundred-page document.

4Read the memo, starting with the sentence that dates it

The reader opens the signed memo in full, with the authorities it cites and a search of its own. The first paragraph is the one to read for currency: this memo supersedes the one issued December 19, 2025.

Documents and data used in this piece

The publisher

Disclaimer. This piece is commentary on published class deviations. It is not legal advice, and it is not a determination about any contractor, solicitation or contract. Confirm which revision governs a contract action with the contracting officer, counsel or a government contracts professional.

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