FAR Part 10 Market Research Under the Overhaul, and the Plan to Move It to Part 7

The overhaul text puts everything in one section, 10.001, with six paragraphs: describe the legitimate need, do market research before certain actions, exchange information with industry responsibly (a "should", not a "must"), ask sources for no more than the minimum information needed, document results to suit the buy's size and complexity, and buy commercial to the maximum extent practicable.

Market research is required "appropriate to the circumstances" before developing new requirements documents, before soliciting offers over the simplified acquisition threshold, and before awarding a task or delivery order over that threshold. FAR 2.101 sets the threshold at $350,000, with higher figures for contingency and certain emergency buys.

The model deviation text for Part 10 was issued May 22, 2025 and updated March 16, 2026, according to acquisition.gov's deviation guide. It governs at an agency only once that agency issues its own class deviation, so the version in force can differ from one office to the next. Our post on where the FAR overhaul stands covers how the deviations, proposed rules and FAR Companion fit together.

The biggest new element is paragraph (f). Using the results of market research, the agency determines, in order, whether:

1. A commercial product or commercial service on an existing governmentwide contract can meet the requirement.
2. The requirement could be modified so the agency could use an existing governmentwide contract.
3. A commercial product or commercial service is available from another source.
4. A commercial product or commercial service could be modified to meet the requirement.
5. The requirement can only be satisfied by a nondevelopmental item.

The old Part 10 asked whether commercial or nondevelopmental items could meet the need, and whether the need could be modified "to a reasonable extent." Beyond preferring commercial items, it did not rank the options or name existing governmentwide contracts as the first place to look. The new text asks the agency to determine steps one and two before looking at other sources, and the paragraph (d) limit on asking sources for information is tied to "the determinations required in paragraph (f)."

Most of the old procedure. The legacy FAR 10.001(a)(3) listed nine things market research had to determine, from customary commercial terms and component-level use to small business programs, sustainable products and accessibility standards. FAR 10.002(b)(2) listed nine techniques, including contacting knowledgeable people, publishing requests for information, querying the contract directory and reviewing the System for Award Management (SAM) and the Federal Procurement Data System.

None of that is in the rewritten section. The June 2026 proposed rule explains the choice directly: "The FAR no longer lists specific market research considerations or techniques that must be used. Agencies will have the flexibility to choose the market research method that best fits their needs." It adds that acquisition professionals must still comply with the Competition in Contracting Act, "which may necessitate market research."

The deviation text also drops several old triggers: market research below the threshold when information is lacking, before consolidation or bundling, and the ongoing research into small businesses and new entrants for contingency and disaster needs in the old 10.001(a)(2)(vi). Some of those topics live elsewhere under the proposed rule. The proposed FAR 7.107-1 requires market research before an acquisition that consolidates or bundles requirements, and set-aside decisions sit in Part 19. None of the eight proposed rules published so far covers Part 19, so its rewritten text exists only in agency deviations.

They agree on the core and differ on a few details that matter in a file review.

The two differences to watch are the order trigger, where the deviation text reads more broadly than either the old FAR or the proposed rule, and reuse, where the proposed rule would accept 18-month-old research for any award rather than only orders. Which reading applies to a given buy is for the contracting officer and agency counsel to decide under the agency's deviation.

The proposed rule, FAR Case 2026-002, says market research "is fundamentally an integral component of acquisition planning," so it belongs in the part devoted to planning. It would remove and reserve Part 10 and add subpart 7.2 with the same requirements, a narrower order trigger and the 18-month sentence. The industry engagement rules from FAR 15.201 would move to a new FAR 7.105, Early exchanges with industry.

That section encourages draft requests for proposal and industry conferences before competitive solicitations, and requests for information (RFIs) when the government does not intend to award but wants price, delivery, market or capability information. RFIs have no required format, but they must say the government does not intend to award a contract on the basis of the RFI and that responses are information only.

The comment period closed July 23, 2026. As of November 8, 2026, the Federal Register lists no final rule for FAR Case 2026-002, so agency deviations still use the Part 10 numbering.

The subcontract clause survives. FAR 52.210-1 has applied to noncommercial contracts over $7.5 million, and the proposed rule keeps it as 52.207-7, Market Research, noting that it is not required by statute for civilian agencies but was retained as essential. Before awarding subcontracts over the simplified acquisition threshold for other than commercial products and services, the contractor would determine, in order, whether a commercial product or service can meet the requirement, whether the requirement could be modified to use one, whether one could be modified, or whether only a nondevelopmental item will do.

Responses to sources sought notices and RFIs now feed a decision that ranks existing governmentwide contracts first. A company on a governmentwide vehicle can name it in its response, with the contract number.

From our delivery teams: Write the market research report as a walk down the five priority steps, with the evidence and the reason each one did or did not fit. Expect reviewers to start with step one; a report built that way answers them before they ask.

Start by confirming which text applies: the date of your agency's Part 10 class deviation, and whether it picked up the March 16, 2026 update. Then build the file around the minimum requirements:

1. State the need in terms that let industry respond, as 10.001(a) requires.
2. Record which trigger applies and the estimated value against the $350,000 threshold.
3. Work through the five priority steps in order and note the evidence for each.
4. Keep information requests to what those determinations need, and note any RFI or industry exchange with its date.
5. Size the write-up to the buy, as 10.001(e) allows, and say whether you relied on earlier research and why it is still current.

Market research happens before the procurement administrative lead time (PALT) clock starts, as our post on PALT explains, and it is one of the first places AIR-Quire, Pyramid's AI-native system of intelligence for the federal acquisition lifecycle, helps: it drafts the FAR-required acquisition documents, checks every step against the agency's rules and compiles a complete, reviewable record, with a person in charge of every decision.