TIP OF THE SPEAR / THE CALL / ISSUE 002 · OCTOBER 22, 2026 · POLICY
Good morning. The FAR Council has published eight of the 12 proposed rules it plans to use to rewrite the entire FAR. By my count, the last four would cover Part 31, the cost principles that decide what a contractor can bill the government, and Part 19, which runs the small business programs. No one has said when they're coming. Today's call says they show up before New Year's.
New look here too. Each Thursday now carries a single forecast with a probability and a resolution date. It goes on the public scoreboard, and when we get one wrong, the miss is graded in this email. There's one of those below, and it's about the FAR Council too.
THE CALL
60% that the FAR Council publishes at least one more FAR overhaul proposed rule by December 31 · Moderate confidence
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01 / THE CALL
WHAT HAPPENED
The overhaul moved into formal rulemaking on June 23, when the FAR Council published four proposed rules covering 20 parts of the FAR. Four more rules, covering another 16 parts, came out on September 18. Comments on those closed Monday night.
The council has said it will issue 12 proposed rules in all, which leaves four. FAR Cases 2026-004, 2026-008, 2026-009 and 2026-012 are the numbers in the series that haven't been used yet, and nothing public puts a date on any of them.
I lined up the parts covered so far against the full regulation. The unpublished ones include Part 19 (small business), Part 22 (labor laws), Part 25 (foreign acquisition and Buy American), Part 30 (cost accounting standards), Part 31 (cost principles), Part 32 (contract financing) and Part 42 (contract administration).
WHAT THE RECORD SHOWS
The first two batches followed the same pattern. Four rules dropped on one day, and industry got about a month to comment. Eighty-seven days separated them. The same gap from September 18 lands on December 14, which is three days after the continuing resolution runs out.
Batch 1 | Batch 2 | Batch 3 | Pace |
|---|---|---|---|
June 23 | Sept 18 | Not yet | 87 days |
4 rules, 20 parts, comments closed July 23 | 4 rules, 16 parts, comments closed Oct 19 | 4 rules, the remaining parts | Same gap again puts batch 3 at Dec 14 |
OUR READ · OPINION
I think the last four arrive before New Year's, and I put it at 60%. The council has surprised me once already this fall. In August we gave 73% odds that no rule implementing the fixed-price executive order would appear this year, and the council put one in the September batch. Wiley's overhaul tracker also expects the final four notices to come out in 2026.
I stop at 60% for two reasons. Small business and cost rules draw comments from more agencies and trade groups than most of what's already out, and I'd expect them to take longer to clear review. The other reason is the budget calendar. If appropriations lapse after December 11, the people writing these rules would likely stop working, and a two-week slip is all it takes to push publication into January.
If any of the four cases shows up under OIRA review on reginfo.gov, I'll move to 75%.
FORECAST #27 · GRADED IN PUBLIC
The FAR Council will publish at least one more Revolutionary FAR Overhaul proposed rule in the Federal Register by December 31, 2026.
Probability | Confidence | Resolves |
|---|---|---|
60% | Moderate | Dec 31, 2026 |
Base rate: Two batches so far, 87 days apart. The same gap from September 18 lands on December 14, inside the window with 17 days to spare.
Signposts to watch
Any week · One of the four remaining cases appears under OIRA review on reginfo.gov. Up.
December 11 · The CR expires. A lapse in appropriations pushes this down hard.
December 21 · No new batch a week past the 87-day mark, and I drop below 50%.
Resolution criteria: Yes if a proposed or interim rule in the Revolutionary FAR Overhaul series that was not published before October 22, 2026 (for example FAR Case 2026-004, 2026-008, 2026-009 or 2026-012) appears in the Federal Register with a publication date on or before December 31, 2026. Public inspection filings, corrections, comment period extensions and class deviations do not count. Source of record is federalregister.gov.
Sources: Proposed rule, Parts 8, 12, 13, 15, 38, 44 and 51 · Proposed rule, Parts 16, 17 and 35 · Sheppard on batch two · Washington Technology on batch one · Wiley overhaul tracker
FROM TIP OF THE SPEAR
The Year-End Defense Calendar is free for readers. If the last FAR batch lands in December, it will compete for attention with the CR deadline on December 11. The calendar lists the dates that matter through December 31, each with a source and a tag that says whether it's firm or just hoped for. Get the calendar
02 / PEOPLE & POSTURE
EMERGING TECH
Adam Telle, Acting Secretary of the Army · Orders a new autonomy command
Telle signed an October 1 memo directing the Army to stand up Army Futures and Autonomous Systems Command and a Portfolio Acquisition Executive for Autonomy, with fielding targeted for fiscal 2028. As of October 17, neither had a named leader or an activation date. Until someone is named, autonomy vendors don't know whose budget they're pitching. Our open call #15 gives the Army a 70% chance of naming that PAE by December 31. Source
FUNDING
Brent Ingraham, Army acquisition chief · Brings back night court
The Army brought back "night court," the top-to-bottom spending review Mark Esper and Mark Milley started in 2018. Ingraham said the first round, on science and technology programs, found "a little over $100 million" that could move toward the new portfolio acquisition executives. The review has since gone through foreign military sales and is now on sustainment, where the PAEs are estimating what it costs to keep current programs running. If your work is funded from Army S&T lines, ask your program office whether it came up. Source
EMERGING TECH
Owen West and Bonnie Evangelista · Reported at the Pentagon drone office
West has reportedly stepped away from running the Defense Innovation Unit to steer DRPM-UxS, the new office that consolidates unmanned systems buying. Travis Metz is filling in at DIU, and Evangelista is reported to be running acquisition at the new office. The Pentagon hasn't announced any of it. Evangelista co-founded the Tradewinds marketplace, where companies pitch with short videos instead of long written proposals, and drone vendors could see that format come with her. Source
TUESDAY'S NUMBER: THE ANSWER
The answer is 100,000. That's how many APKWS kits BAE had delivered by February 2026. Monday's framework allows up to 25,000 a year, so one year at the cap equals a quarter of everything BAE built before it. Suppliers on that line should be checking their own capacity before the multiyear contract is signed. Source
03 / PREDICTIONS
4–2 Record · 21 open · Full scoreboard
#11 · The 15-business-day commerciality standard is public by October 29 · 30%
OPEN
#27 · New today. Another FAR overhaul proposed rule by December 31 · 60%
OPEN
#23 · The FY2027 CR carries no new-start or rate-increase anomaly for a major program · graded October 17
HIT
#25 · No FAR rule implementing EO 14402 by December 31 · graded October 17
MISS
We missed this one. Call #25 said the FAR Council would not publish a rule implementing EO 14402, the fixed-price preference order, before the end of the year. It published one on September 18. FAR Case 2026-006 rewrites Parts 16, 17 and 35 and adds a justification and approval requirement for contracts that aren't fixed-price, which meets our criteria. Our October report still listed the call as open. That was a second error, and the scoreboard now shows the miss. We underrated how readily the council folds an executive order into its overhaul batches, and today's call leans on that lesson.
#23 was a hit. The CR signed September 2 bars new production starts and rate increases. Its carve-out for 20 prior-year shipbuilding programs only covers cost-to-complete, so it doesn't count. #11 resolves next Thursday, October 29.
THE CROWD'S CALL
Will the FAR Council publish another FAR overhaul proposed rule by December 31?
Tip of the Spear calls yes at 60%. Results next Thursday.
TIP OF THE SPEAR PRO
The drone office: why we expect no Autonomous Warfare Command nominee this year
The October report, The drone office, makes several calls on DRPM-UxS and the planned Autonomous Warfare Command, and each one is on the public scoreboard. One says no nomination for a commander of that command reaches the Senate by December 31. Another says current major defense acquisition programs stay outside the DRPM-UxS portfolio through March 31, 2027. Pro members get the evidence behind both.
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04 / THE LAST WORD
This is the first Call in the new format. If 60% looks wrong to you, reply with your own number and one reason, and with your permission I'll quote the best argument against me next Thursday.
If you work on small business or cost accounting rules and have heard anything about timing for Parts 19 or 31, I'd like to hear it. I won't name anyone.
Semper Fi,
Justin
Reading this as a team? Team 5 and Team 10 plans put Pro on everyone's desk on one invoice, and we accept purchase orders. See team plans
Disclosure: Sponsors and clients have no input on editorial content or forecasts. Justin's affiliations and our corrections policy are on the Standards and Disclosures page.
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