Get Ready for Federal Past Performance 2.0: Revised FAR and FY26 NDAA Past Performance Provisions Magnify and Expand Performance Record Relevance
December 12, 2025
Federal contractor past performance is entering a fundamentally new phase. Two recent developments— the Revolutionary FAR Overhaul (RFO) revisions to FAR Part 42.11 and Section 824 of the FY26 National Defense Authorization Act (NDAA) conference bill —together send a strong signal that CPARS is not only here to stay but your past performance information in CPARS (and almost anywhere now) is wide open for evaluation and scrutiny by all Federal Agencies.
The FAR Part 42.11 rewrite removes the long‑standing limitation that tied the use of past performance information exclusively to “source selection” and authorizes its use for ANY future acquisition purpose for contracts awarded on or after April 1, 2026.
Under Section 824 of the NDAA, Congress directs the Department of Defense (DoD) to expand what qualifies as relevant past performance, including commercial and non‑government work, and to reduce barriers that disproportionately affect small and nontraditional contractors.
For federal contractors, the takeaway is clear: your CPARS and past performance records now follow you earlier, more broadly, and evaluated for more decisions than ever before.
Past Performance 2.0 Key Driving Factors
I. FAR Part 42.11: CPARS Past Performance From “Source Selection” to “Future Purposes”
A. The Key Textual Change in Revised FAR 42.1101
Subsection 42.1101 removes a single phrase limiting past performance information to future “source selection” purposes—but with outsized consequences.
Prior language:
“Past performance information … is relevant information, for future source selection purposes …”
Revised language (effective April 1, 2026):
“Past performance information … is relevant information, for future purposes …”
That tiny deletion of “source selection” is actually a huge conceptual move:
Before: CPARS past performance was officially framed as something you use when picking the winner (source selection), i.e., primarily in competitive evaluations.
After: CPARS Past performance becomes fair game for any future purpose before, during and after source selection!
B. What “Future Purposes” Can Include
Post‑April 1, 2026, agencies may lawfully consider past performance information in a wide range of contexts, including:
Market research and acquisition planning
Responsibility determinations
Option exercise decisions
Contract administration, performance management and remedies
Vendor portfolio management
Strategic sourcing and long‑term supplier assessments
Post-award contract management at both contract and Agency levels
This change forces a major expansion in how and when past performance matters. The Government has now confirmed CPARS past performance data will be more visible, accessible, and utilized more throughout the acquisition lifecycle. Your CPARS file becomes a living performance record — not a static past-performance snapshot – and sharply raises the stakes for continuous performance management, not just “cleaning up CPARS before a recompete.”
II. Section 824 of the FY26 NDAA: Expanding the Scope of Past Performance
A. Broader Definition of Relevant Past Performance
Section 824 (“Increasing Competition in Defense Contracting”) directs DoD to issue guidance on when contracting activities should accept a wider range of past performance, particularly where requirements are novel or have limited government precedent. Importantly, this guidance is to include commercial and non‑government projects as relevant evidence of capability and performance.
B. Supplements (Not Replaces) CPARS/Existing Past Performance Options
It is important to note that Section 824 explicitly states that the guidance issued “shall supplement existing Department of Defense policy and procedures for consideration of past performance and other evaluation factors and methods”, i.e., CPARS. However, keep in mind that while there may be more avenues used to review past performance information, once a contract is awarded, your contractor past performance records will be entered into, reside in, and accessible to all federal agencies through CPARS for at least 3 years.
III. Past Performance 2.0: The Combined Impact
When read together, FAR 42.11 and NDAA Section 824 create a new operating reality:
Expanded visibility and access: Your past performance information is an open book - whether in CPARS or elsewhere - for Agencies to use at any time for any purpose.
Expanded timing: CPARS performance information can influence decisions well before and after proposal evaluations.
Expanded consequences: Poor performance can affect responsibility findings, option exercises, and future market access—not just evaluation scores.
Expanded inputs: Federal, commercial, and non‑government past performance all matter.
Bottom line – Your performance matters (even more now)! It better stay positive (with no negative marks) to survive in the future federal marketplace. And your performance ratings will need to be better than “Satisfactory” to retain a competitive advantage and win more federal contracts in the new Past Performance 2.0 environment.
Conclusion
The combination of FAR Part 42.11 and FY26 NDAA Section 824 substantially broadens when federal agencies can use past performance and what past performance they can consider. We’re entering a Past Performance 2.0 era - broader in scope, earlier in impact, and more consequential across the acquisition lifecycle.
For contracts post-award, CPARS is now truly the contractor performance credit score of federal procurement. If your CPARS record isn’t accurate, complete, and consistently high-quality (i.e., above “Satisfactory”), it will now affect more than just your next proposal — it can impact your entire business pipeline. Managing CPARS and related performance evidence can no longer be a periodic compliance exercise—it must become a continuous business discipline and an enterprise-wide corporate strategy.
Are you ready for Past Performance 2.0? Contractors that adapt early will be better positioned to compete, grow, and manage risk in this new environment. For those that do not, past performance may quietly become the decisive pass/fail factor long before any future opportunity proposals are ever submitted.
Let our trusted (and discreet) CPARS experts and respected former federal contracting officials help keep your CPARS past performance ratings at the highest levels you deserve. We offer unique customized CPARS ratings management solutions through CPARSradar (Enterprise CPARS Ratings Management) and GovConRx (CPARS Ratings Urgent Care). Contact us for more info or Schedule a free CPARS Review Session here.
Reference Links:
FAR Part 42.11:
FY26 NDAA Conference Bill: https://armedservices.house.gov/uploadedfiles/rcp_text_of_house_amendment_to_s._1071.pdf
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