What Changed in CPARS for 2026, and What Did Not

The CPARS overhaul most people heard about in 2026 did not happen. The proposal to strip positive and neutral ratings out of CPARS and record only material negative events passed both chambers in the FY2026 NDAA drafts and then did not survive into the enacted law. What did change sits somewhere less exciting: the subpart governing contractor performance information was renumbered, the limits on how that information may be used were loosened, and the Department of Defense picked up a new obligation on past performance that has nothing to do with ratings.

Updated September 2026. Regulatory citations verified at primary sources on September 23, 2026.

Imperial Construction & Electric is a certified MBE/SBE general contractor with more than 20 years of public work behind it, for the Department of Veterans Affairs, the Department of Defense, federal agencies, K-12 and higher-education owners, and state, county and municipal clients across New Jersey and the Northeast. We sell on performance history, so we read this subpart the way a firm reads something that prices its next bid. We are writing it down here because the version circulating in procurement newsletters through the spring was the version that did not pass.

The Ratings Did Not Change

Start with what an evaluator can still count on, because that is most of it.

Performance evaluations are still prepared at least annually and at the time the work under a contract or order is completed (FAR 42.1502(a)). Construction still has its own threshold: an evaluation is required for each construction contract of $900,000 or more, and for each construction contract terminated for default regardless of value (FAR 42.1502(e)). Architect-engineer services sit at $45,000 (FAR 42.1502(f)). The scale is still five ratings, exceptional through unsatisfactory (FAR 42.1503(b)(4)). The contractor still gets up to 14 calendar days from notification to submit comments, rebutting statements or additional information (FAR 42.1503(d)), and the evaluations still live in CPARS at cpars.gov (FAR 42.1503(f)).

If you build your source selection plan on those numbers, nothing in the last year moved them.

What the FY2026 NDAA Actually Did

The negative-events amendment was real. Both the House and Senate versions of the FY2026 NDAA carried language that would have required DoD contracting officers to record only negative performance events with a material impact, sorted into failure categories, and to exclude positive and neutral assessments.

It is not in the law. The FY2026 National Defense Authorization Act was enacted as Public Law 119-60 on December 18, 2025. We searched the enacted text, all 1,260 pages of it, and the word CPARS does not appear anywhere in it. Neither does "contractor performance assessment." An owner or a prime who heard the overhaul was coming and has been waiting to see it land can stop waiting.

What the law did carry is Section 824, "Increasing Competition in Defense Contracting" (139 Stat. 956, 10 U.S.C. 3301 note). Its first subsection is about past performance, and it runs the other direction from the ratings fight. Within one year of enactment, so by December 18, 2026, the Secretary of Defense owes guidance on when DoD should accept past performance from a wider range of projects, including commercial and non-government work, in order to get more capable firms into a competition. The same section asks for a way to validate those non-government references, including an attestation of authenticity from the referring entity and verifiable contact information, and for alternative evaluation methods where a requirement has little precedent.

That is the 2026 change worth planning around. Not a narrower CPARS record, a wider definition of what counts as past performance beside it.

FAR 42.15 Is Now 42.11

Here is the change that will actually interrupt somebody's afternoon.

Under the Revolutionary FAR Overhaul, launched by Executive Order 14275 on April 15, 2025, the FAR Council issued model deviation text for Part 42 on September 30, 2025. Part 42 went from 17 subparts to 13, and Subpart 42.15, Contractor Performance Information, was renumbered to Subpart 42.11. Policy moved from 42.1502 to 42.1102. Procedures moved from 42.1503 to 42.1103.

Agencies adopted it through their own class deviations. GSA's Class Deviation RFO-2025-42 took effect November 3, 2025. VA's class deviation memorandum carries the same date and instructs its acquisition workforce to follow the model deviation text instead of Part 42 as codified at 48 CFR Chapter 1. So both citations are live right now, depending on whose contract you are holding, and a specification that cites 42.1503 is not wrong so much as it is pointing at the codified FAR while your contracting activity reads from the deviation.

Three substantive changes came with the renumbering:

• Past performance information is no longer limited to source selection. Section 42.1101 dropped "for future source selection purposes" in favor of "for future purposes." The practical effect is that performance information can be used across the acquisition lifecycle rather than being quarantined until the next competition.
• Considerations that were suggested are now required. The old 42.1503(b) offered areas to consider documenting on an evaluation report. The deviated text at 42.1103(b) states they must be documented.
• FAPIIS references became SAM. Section 42.1103(f) now points to the responsibility and qualification reports in the System for Award Management at SAM.gov rather than to FAPIIS by name.

The deviation also removed the old 42.1502(h) prohibition on evaluating AbilityOne contractor performance, which means those firms can now build a rated record like anyone else.

One caution on the parts we did not list. The agency memoranda describe the rewrite as structural, with better headings and numbered lists, and each one enumerates what was removed. None of them lists a change to the evaluation thresholds or the rating scale. That is not the same as a guarantee, and we do not treat it as one. Before we price a bid against a threshold we read the deviation the contracting activity actually adopted, because the model text and thirty agency adoptions of it are not automatically identical documents.

April 1, 2026

One date is worth putting in a calendar. Under the deviated 42.1103(d)(4), evaluations of contractor performance developed on contracts awarded prior to April 1, 2026 should be marked "Source Selection Information." Contracts awarded on or after that date fall outside the marking instruction, which is the mechanical consequence of the policy change above.

For an agency, that is a records-handling question to settle before the date rather than after: who marks what, and where the marked and unmarked evaluations sit in your file. For a contractor, it is a reminder that an evaluation written on your job is now readable in more contexts than it used to be.

What We Would Tell an Evaluator

None of this changes the work that produces a good rating, which is the part we care about. A rating is downstream of a record, and the record is made daily by whoever is running quality control on the job. We staff projects with dedicated Construction Quality Control Managers and Site Safety and Health Officers, with multiple team members holding United States Army Corps of Engineers certifications, and the reason is on the page about how the documentation becomes the deliverable: the daily report and the submittal log are the evidence the evaluation is written from months later.

So the screening question for a bidder did not change either. Ask what their recent evaluations say, ask what they did about the one that went badly, and ask who on their staff owns the quality control system. Our credentials, classifications and prequalifications are posted on our About Us page. To see how we would staff and document a specific solicitation, contact us to prequalify or request our capability statement.