Recompeted
August 25, 20264 min readFree

Your Saved Search Still Says 6.302

The FAR overhaul renumbered the seven exceptions to full and open competition, and DoD contracting officers started using the new numbers in March. Ten awards on the daily boards now cite 6.103-x instead of 6.302-x, including a $3.31 billion Navy direct award, and the share is running at 18.5% of this quarter's exception citations.

If you keep a keyword alert on the Pentagon's daily contract announcements for 6.302, it has been quietly dropping awards since March.

Here is the one from yesterday.

Avox System, Lancaster, New York, a maximum $37,583,889 five-year contract for demand oxygen regulators, SPE4A7-26-D-0417 out of DLA Weapons Support. The competition sentence reads: "This was a sole-source acquisition using justification 10 U.S. Code 3204 (a)(1), as stated in the Federal Acquisition Regulation 6.103-1."

We logged that sentence as an oddity when the board posted. It is not an oddity.

Open the FAR at acquisition.gov and there is no 6.103-1. Subpart 6.1 runs 6.100, 6.101, 6.102, and stops.

We Counted Every One

We pulled every daily contract board the war.gov feed carries and parsed it: 497 boards, 6,642 announcements, from July 5, 2024 through Monday.

386 of those announcements cite a FAR Part 6 exception number when they explain why the work was not competed. 376 use the codified numbering, 6.302-1 through 6.302-7. Ten use 6.103-x, and all ten of them landed in 2026 (chart below).

The first was March 20: a $414,000,000 ceiling increase for Utah State University's Space Dynamics Laboratory at MDA, citing "10 U.S. Code 3204(a)(3)(B) as implemented in Federal Acquisition Regulation 6.103-3(b)(2)."

Then it kept happening. Six quarters of the corpus sit at exactly zero.

2026 Q1 has one, Q2 has four, and Q3 through Monday has five, which is 18.5% of the quarter's exception citations.

The face value on the ten comes to $4.36B, though one award carries most of it: Oracle's $3,311,000,000 DOW Enterprise Software Initiative award on July 23, N66001-26-D-0020, where the Navy wrote that the Secretary "has authorized a non-competitive direct award under 10 U.S. Code 3204(a)(7) and Federal Acquisition Regulation 6.103-7 (Class Deviation 2026-00017 Rev. 1)."

That parenthetical is the whole explanation.

The Overhaul Moved the Furniture

The Revolutionary FAR Overhaul rewrote Part 6, and the rewrite is short enough that the exceptions had to go somewhere else. All seven circumstances permitting other than full and open competition kept their order and their titles and changed their address. The ones you quote most often:

  • 6.302-1 only one responsible source, now 6.103-1
  • 6.302-2 unusual and compelling urgency, now 6.103-2
  • 6.302-3 industrial mobilization, engineering, developmental or research capability, or expert services, now 6.103-3
  • 6.302-7 public interest, now 6.103-7

The rest of the part moved too:

  • Justifications and approvals, old 6.303 and 6.304, land at 6.104
  • Availability of the justification, old 6.305, lands at 6.201 in a new postaward subpart
  • Advocates for competition, the entire old subpart 6.5, collapses into 6.003

The FAR Council's own reasoning is that the old section padded each authority with application paragraphs that "generally expound on the underlying authorities with duplicative, nonstatutory, or non-exhaustive example listings that are better left to agency discretion."

Now, here is the catch. That text is a proposed rule, published June 23 as FAR Case 2026-002, comments closed July 23.

The codified FAR at acquisition.gov still says 6.302-1, and it will until a final rule says otherwise. DoD contracting officers are already writing the new number because they work from the deviation text.

So the public record is running on two numbering systems at once. The announcement tells you which one the contracting office had open that morning.

Filter on the Statute Instead

The transition is going to be messy in exactly the way transitions are. One Navy modification in May cited "Federal Acquisition Regulation (FAR) 6.10302, unusual and compelling urgency," which is 6.103-2 with the hyphen dropped, on an $84,020,164 ceiling increase for Navy Recruiting Command advertising.

The stable key is the statute.

Across the same 497 boards, 658 announcements cite 10 U.S. Code 3204(a) or (c), or the legacy 2304(c), against 386 that cite either FAR section number. Congress did not renumber Title 10, and the overhaul does not touch it.

An award that cites the exception at all is more likely to give you the statute than the regulation.

Two things worth doing before your next pipeline review:

  • Widen every board, SAM, and FPDS keyword monitor to catch 6.103, the unhyphenated 6.1030x forms, and 3204(a) alongside 6.302.
  • Check the boilerplate in your own protest-watch and J&A-tracking templates. If a template tells an analyst to look for the posted justification under FAR 6.305, the office they are calling may be working from 6.201.

Final Thoughts

Ten announcements out of 6,642 is not a wave, and we would not call the trend line established off three quarters. The direction is not really in question though, because the department stopped waiting for the final rule.

What it costs you is small and dumb: a sole-source award that never shows up in a monitor you set up correctly two years ago. The number moved, the authority did not, and the boards will keep printing whichever one the contracting officer has open.

Thanks for reading.