The National Defense Industrial Association (NDIA) supports the Federal Acquisition Regulation (FAR) overhaul, praising efforts to streamline acquisition processes and reduce administrative burdens. However, they provide specific recommendations to maintain certain definitions, clarify CUI requirements, and ensure that new security rules do not impose undue costs or operational risks on the defense industrial base.

The Professional Services Council (PSC), a trade association representing the government contracting industry, supports the proposed "Revolutionary Federal Acquisition Regulation Overhaul" (RFO) to modernize and streamline federal procurement. They provide specific recommendations to ensure the final rule maintains contractor protections, provides clear transition periods for new security standards, and avoids unnecessary administrative burdens like wholesale clause renumbering.

The FIDO Alliance supports the proposed amendments to the FAR but argues that the current language is insufficient to address modern phishing threats. They recommend updating the FAR to explicitly require phishing-resistant authentication (such as FIDO standards) for contractors accessing Federal information systems or CUI, aligning it with OMB M-22-09.

The Net Effect, LLC, an information consulting firm, supports the goals of the proposed FAR overhaul but argues that the rule needs specific language to prevent prime contractors from shifting compliance burdens onto small and medium business subcontractors. They recommend requiring primes to evaluate the applicability of clauses before flowing them down and to provide specific CUI identifications rather than general statements.

The MSP Collective supports the proposed FAR CFR 48 rule but argues that it should include a verification mechanism similar to the CMMC program to ensure contractors are safeguarding CUI. They also advocate for mandatory requirement flow-downs to subcontractors and a time-bound process for contracting officers to respond to inquiries regarding unmarked CUI.

Globe-America Consulting, Inc. supports the creation of a government-wide framework for Controlled Unclassified Information (CUI) and the proposed Standard Form XXX. However, the company argues that the rule needs a clear transition strategy and reciprocity for existing CMMC certifications to avoid dual compliance burdens between DoD and other federal agencies.

Sintavia, LLC, a defense subcontractor, supports the FAR Council's effort to standardize CUI requirements but argues that the proposed rule should be revised to make the flowdown of Standard Form XXX (SF XXX) mandatory rather than discretionary. They contend that making it mandatory ensures subcontractors receive the necessary information to identify CUI categories, apply correct safeguarding controls, and meet incident reporting deadlines.

The commenter, writing as an individual, opposes the proposed rule because it creates an impractical administrative burden for Governmentwide commercial purchase card (GPC) transactions that exceed the Micro-Purchase Threshold. They argue that the requirement for transaction-specific security representations will hinder rapid response and overseas operations, and they propose several exemptions to maintain procurement efficiency.

An anonymous individual with extensive experience in U.S. defense contracting supports the prompt finalization of the Government-wide CUI framework. The commenter recommends four specific clarifications regarding service boundaries, material-change notifications, high-risk access controls, and evidence-backed accountability to ensure the rule functions as intended across complex modern environments.

Kay Wilson of VPM Consulting submits a supplemental amendment proposing specific machine-readable data requirements for FAR Part 40 and NIST SP 800-171 flow-downs. The commenter argues that these requirements will improve clarity, consistency, and scalability for subcontractors while reducing administrative burdens.