Breaking Down the New FAR Part 10 Rewrite: What Market Research Means for Government Contractors

If you’ve been around federal contracting for a while, you know that sometimes the most important work happens before the RFP ever hits SAM.gov.

And with the 2025 overhaul of FAR Part 10, that’s truer than ever.

The revised Part 10 doesn’t just update how agencies conduct market research—it reframes it as a strategic imperative. The goal? Make smarter buys, faster, using commercial solutions whenever possible. And that shift has major implications for small and mid-sized businesses in the government space.

So, what’s changed—and what should you be doing right now to get ahead?

Let’s break it down.

What is FAR Part 10?

FAR Part 10 lays out the minimum requirements for market research before an agency procures goods or services. It’s the section of the FAR that says, in plain terms: “Do your homework before you buy.”

Market research in this context means gathering and analyzing information about market capabilities, products, trends, suppliers, and pricing—so agencies can make well-informed decisions about how to meet their mission needs.

The 2025 rewrite of Part 10 reinforces that mandate, providing agencies with more structured guidance while placing a premium on commercial solutions and competitive access.

Key Highlights of the New FAR Part 10

Here’s what’s new—and why it matters:

1. Market Research Is Now Mandatory Before Almost All Key Steps

Agencies are now required to conduct market research before:

• Developing new requirements documents
• Soliciting offers for any acquisition over the Simplified Acquisition Threshold (SAT)
• Awarding task or delivery orders over the SAT

That means if you’re a vendor who wants to influence what gets bought and how—your best shot is before the solicitation goes live. And the FAR now codifies that opportunity more clearly than ever.

This is exactly where FedBiz365 shines.

Our AI-driven market research tool for government contractors gives you instant access to:

• Upcoming opportunities not yet posted in SAM.gov
• Expiring contracts and agency buying patterns
• Deep insights into your competitors and federal buyers

FedBiz365 puts you in a position to engage early—so you’re part of the conversation before an RFP is written.

2. Agencies Must Describe Their “Legitimate Needs”

Before they can even issue a solicitation, agencies must clearly define the legitimate needs they’re trying to meet. That includes determining:

• Whether a commercial solution already exists
• If an existing contract can be used
• Whether the requirement can be modified to match commercial offerings

This is a huge win for contractors who sell ready-made, off-the-shelf, or slightly-modified commercial products and services.

If you can prove that your solution meets a need—and you make that known early—you have a real chance of shaping the acquisition.

3. New Priorities for How Agencies Use Market Research

The rewrite introduces a new order of priority for how agencies should evaluate their needs:

1. Can a commercial product or service on an existing governmentwide contract meet the need?
2. Can the requirement be adjusted to match something already under contract?
3. Can it be sourced commercially elsewhere?
4. Could a commercial product or service be modified to meet the need?
5. Can it only be fulfilled by a nondevelopmental (custom-built) item?

This flips the old default on its head. Instead of building something from scratch, agencies are now encouraged to first exhaust every commercial path available.

For contractors, that means:

• Get on existing contract vehicles (like GSA Schedules, GWACs, or IDIQs)
• Highlight how little customization your solution needs
• Document how your offering aligns with mission-ready needs

4. Minimum Burden, Maximum Clarity

Agencies are now prohibited from asking potential vendors for more than the minimum necessary information when conducting market research.

This is designed to prevent overreach, reduce compliance burden for vendors, and ensure that companies—especially small businesses—aren’t forced to provide in-depth technical data just to be considered.

This is great news for contractors because it makes the barrier to entry lower during the research phase. If your Capability Statement or DSBS profile is clear, optimized, and accessible, that might be all they need.

5. Industry Engagement Is Encouraged

While the FAR still prohibits agencies from giving any company an unfair advantage, the rewrite explicitly encourages constructive exchanges with industry.

Agencies are empowered to:

• Use RFIs, Sources Sought, and Industry Days
• Conduct capability briefings
• Have one-on-one conversations (within ethical limits)

That means contractors who are proactive, informed, and positioned well before the RFP stage have a much better shot at winning.

6. Results Must Be Documented and Scaled to Complexity

No more vague notes. Agencies must now formally document the results of their market research in a manner that reflects the size and complexity of the acquisition.

That means your early-stage engagement with contracting officers—your emails, capability briefings, or RFI responses—might become part of the official file.

So make sure you’re:

• Speaking the agency’s language
• Clearly showing how your solution meets their needs
• Backing up your claims with past performance or proven results

7. New Market Research Clause for Larger Contracts

The new clause FAR 52.210-1 will now be inserted into all noncommercial contracts over $6 million.

This clause reinforces that:

• Market research must have been conducted
• The government considered commercial options
• The acquisition file includes documented findings

It’s another signal that the government is trying to become more intentional and efficient in how it spends—especially on big-ticket buys.

What This Means for Government Contractors

1. It’s Not Just About Responding to RFPs Anymore

If you’re waiting until an opportunity is posted to SAM.gov, you’re already too late. The most important decisions—about requirements, acquisition strategy, and vendor pool—are being made during the market research phase.

This is where FedBiz365 delivers an edge.
Our platform doesn’t just show you what’s available now—it shows you:

• What’s expiring soon
• Who’s winning what
• What’s coming next

With FedBiz365, you can identify future opportunities before they’re public—and reach out to contracting officers at the right time.

2. Your DSBS and Capability Statement Matter More Than Ever

Contracting officers are using tools like SAM.gov, DSBS, and market intelligence platforms to gather data and identify vendors.

That means your Small Business Profile, SAM registration, and Capability Statement need to:

• Be clear and complete
• Highlight commercial offerings
• Showcase how your solution reduces development time, risk, or cost

3. Engage Early, Often, and Strategically

Industry engagement isn’t just allowed—it’s encouraged. But to do it well, you need more than just contact info.

At FedBiz Access, we offer:

• FedBiz365, our AI-driven market research tool that helps you find the right opportunities before they go public
• Direct marketing to contracting officers through our Federal Connections Package and MatchMaker Services
• Engagement coaching to help you speak the language of procurement and position your business effectively during the market research phase

When you know how to enter the conversation—and how to deliver the right message—you can influence the outcome before the solicitation is even written.

Key Takeaways

The 2025 rewrite of FAR Part 10 is all about smarter acquisitions and earlier engagement.

Here’s your cheat sheet:

💡 How FedBiz Access Can Help

We’ve spent over 24 years helping small and mid-sized businesses win in the government marketplace.

Here’s how we can help you align with the new FAR Part 10:

• FedBiz365 – Our AI-powered market research tool that uncovers upcoming opportunities, expiring contracts, agency trends, and buyer contact details—all before anything is posted to SAM.gov
• SAM & DSBS Optimization – Make sure you show up when buyers are searching
• Capability Statement Development – Government-formatted, impact-driven marketing
• GSA Schedule Proposal Assistance – Get on the contract vehicles agencies are prioritizing
• Direct Outreach – Targeted engagement through our Federal Connections and MatchMaker services
• Engagement Coaching – Learn how to speak the contracting officer’s language and lead with value

👉🏼 Schedule a complimentary consultation with a FedBiz Specialist today.

Let’s get your business aligned with the new rules—so you can compete earlier, smarter, and with confidence.

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