Government Procurement & Defense Regulations
Mandatory flowdown clauses across FAR and DFARS
Simplified Acquisition Threshold (SAT) as of August 2025
Maximum civil penalty per False Claims Act violation
Regulation Overview
https://www.acquisition.gov/
The FAR is the principal regulatory framework governing how the U.S. federal government purchases goods and services. For supply chain teams, FAR compliance means managing clause-level obligations across every prime contract, subcontract, and purchase order touching federal procurement dollars. FAR prescribes over 150 mandatory flowdown clauses covering cost accounting, cybersecurity, domestic sourcing, labor standards, small business subcontracting, and contractor ethics. The Revolutionary FAR Overhaul—initiated by Executive Order 14275 in April 2025—is rewriting the FAR in plain language and removing non-statutory rules, with revised Parts rolling out through 2026. NDAA FY2026 raised the TINA threshold to $10 million and full CAS coverage to $100 million effective mid-2026. FAR compliance requires clause-specific evidence from every contractor and subcontractor in your chain. When FAR Parts are revised or thresholds change, your entire subcontract library requires reassessment.
Key Components / Sub-Frameworks
Prime contractors awarded federal government contracts\nSubcontractors at all tiers receiving mandatory FAR flowdown clauses\nSmall business subcontractors subject to set-aside and reporting obligations\nCommercial product and service suppliers selling to the federal government\nImporters and manufacturers subject to Buy American / Trade Agreements Act clauses\nDefense contractors subject to DFARS cybersecurity and domestic sourcing clauses
Key Thresholds
Your prime contract contains 85 FAR clauses and 40 DFARS clauses. Which ones must flow down to each subcontract? The answer depends on contract type, dollar value, commerciality, and whether the subcontractor handles CUI. Your contracts team spends days building clause matrices manually—and still misses mandatory flowdowns that surface during CPSR.
The SAT jumped from $250K to $350K. The TINA threshold moves to $10M in July 2026. Full CAS coverage now starts at $100M. Every threshold change cascades across your subcontract library—triggering clause additions, removals, and renegotiations. Without centralized threshold tracking, you cannot confirm which subcontracts remain compliant.
The Revolutionary FAR Overhaul is rewriting Parts at pace—with agency deviations layered on top. FAR Companion v2, new buying guides, and 31 DFARS deviations create a moving compliance target. Your subcontract templates reference clause versions that may be superseded. Manual regulatory intelligence at this velocity is unsustainable.
DCAA requests cost or pricing data supporting a $6M subcontract modification. You need the original proposal, negotiation memorandum, subcontractor certifications, and flowdown evidence across three tiers. The records are spread across email, a shared drive, and your ERP. Compiling the audit package takes three weeks—and the auditor found a gap.
Certivo In Action
Certivo in Action — FAR Workflow
From Manual Clause Research to Automated Flowdown Management
CORA maps applicable clauses automatically based on contract type, value, and commerciality. Your contracts team focuses on negotiation strategy—not building clause matrices by hand.
CPSR and DCAA Response Acceleration
Generate complete, audit-ready flowdown evidence and certification packages in hours—not the 4-6 weeks of manual compilation across subcontractor files.
Proactive FAR Compliance Assurance
When Federal Acquisition Circulars are published or thresholds change, Certivo reassesses your subcontract portfolio instantly. Know which subcontracts need updates before the next audit cycle.
Key Statistics
Frequently Asked Questions
What companies and contracts are subject to FAR requirements?
Any company that sells goods or services to the U.S. federal government—or subcontracts under a federal prime contract—is subject to FAR obligations. This includes prime contractors, subcontractors at all tiers, and commercial suppliers receiving mandatory flowdown clauses. The FAR applies to all civilian agencies and DoD, with DFARS adding defense-specific requirements. Certivo tracks FAR applicability across your entire subcontract portfolio.
What are the penalties for FAR non-compliance?
FAR non-compliance exposes contractors to suspension, debarment, contract termination, and False Claims Act liability with penalties up to $15 million per violation plus treble damages. CPSR disapproval can result in contracting officer consent requirements on every subcontract. DCAA audit findings can trigger cost disallowances, rate adjustments, and referrals to the Inspector General. Certivo maintains continuous audit-ready documentation to reduce enforcement exposure.
How does Certivo track FAR regulatory changes and threshold updates?
Certivo syncs with Federal Acquisition Circulars, DFARS deviations, and agency FAR supplement updates as they are published. When thresholds change—such as the TINA increase to $10M or CAS full coverage to $100M—CORA reassesses your subcontract portfolio and flags affected contracts, triggering clause update workflows before the next audit cycle.
What formats does Certivo accept from subcontractors?
Certivo accepts any format: PDF certifications, signed representations, SAM.gov exports, spreadsheets, government-standard forms, and freeform responses. CORA extracts clause references, certification data, and compliance attestations regardless of format, eliminating the need to standardize inputs across your subcontractor base.
Does Certivo support FAR alongside DFARS, CMMC, and other related frameworks?
Yes. Certivo validates subcontractor evidence against FAR, DFARS, CMMC, Buy American/TAA, CAS, and export control requirements simultaneously. The same subcontractor submission is validated across all applicable frameworks—eliminating duplicate compliance campaigns and providing a centralized compliance data backbone across government contract obligations.