CPARS still uses the five-point adjectival scale. The negative-events-only model that circulated widely in late 2025 was proposed in both chambers of the FY2026 defense authorization but was dropped before the bill was signed on December 18, 2025. What did change is where past performance gets used. Under the FAR overhaul, evaluations on contracts awarded on or after April 1, 2026 can inform decisions across the full contract lifecycle, not just source selection.
A proposal that never became law has been circulating as though it did. During 2025, the House and Senate versions of the FY2026 National Defense Authorization Act both contained a plan to strip adjectival ratings out of the Contractor Performance Assessment Reporting System (CPARS) for Department of Defense contracts and replace them with a record of defined negative events plus an automatically calculated score. Trade publications, law firms, and contractor blogs covered it heavily in October and November 2025, when it looked likely to pass.
It did not pass. The bicameral agreement dropped the provision, and the President signed the bill as Public Law 119-60 on December 18, 2025, without it. Industry pushback is the reported reason. Contractors wanted the government to keep recording strong performance, not just failures.
The problem for readers is that most of the coverage was written before enactment and was never corrected. If you search CPARS changes today, you will still find confident articles describing a system that does not exist. Acting on that information means neglecting the adjectival record that source selection officials are still reading.
Section 824 of the enacted law works in the contractor's favor rather than against it. It directs the Secretary of Defense to issue guidance, with examples and templates where appropriate, within one year of enactment, which puts the deadline at December 18, 2026. The guidance has to address three things.
Section 824 also directs the Secretary to convene the Defense Acquisition Regulations Council to identify and remove procedural barriers that fall disproportionately on small businesses and nontraditional defense contractors.
For a business with strong commercial work and a thin federal record, this is the provision worth tracking. As of September 2026, the guidance has not been issued, so nobody can tell you yet what documentation DoD will accept. What you can do now is make sure your commercial references are documented in a form that survives a validation requirement, with a named official who can attest and current contact information on file.
Past performance evaluations are no longer walled off inside source selection. The Revolutionary FAR Overhaul rewrote Part 42, and the model deviation text removes the language confining contractor performance information to source selection use. The operative line sets a date. Evaluations developed on contracts awarded before April 1, 2026 should still be marked "Source Selection Information." Evaluations tied to awards on or after that date can be used during any part of the acquisition lifecycle.
That means a mediocre rating can now surface when a contracting officer is deciding whether to exercise your option year or how much award fee to pay, not only when you are competing for the next contract.
Two practical details matter here. First, this is running through agency class deviations rather than a final FAR rule, so adoption varies. DoD issued Class Deviation 2026-O0050 on March 6, 2026, effective March 16, 2026, and GSA, DHS, Energy, and others have their own. Second, the same deviation renumbers contractor performance information from Subpart 42.15 to Subpart 42.11. Both citations are currently correct depending on which agency you are dealing with, because the codified FAR on acquisition.gov still shows 42.15 while deviation agencies operate under 42.11. If a contracting officer cites 42.11 and your compliance documentation references 42.15, you are looking at the same rule.
The mechanics most contractors actually get hurt by are untouched. Evaluations are required at least annually and at completion for contracts and orders above the simplified acquisition threshold, which rose to $350,000 effective October 1, 2025, with separate thresholds of $900,000 for construction and $45,000 for architect-engineer services. Past performance information stays in use for three years after completion, and six years for construction and architect-engineer work.
The 14-day comment window under FAR 42.1503(d) also still applies, and this is where the record gets quietly decided. The evaluation becomes available to source selection officials on day 15, whether or not you responded, marked "Pending" if you said nothing. Your CPARS access does not close on day 14, though. The system keeps the contractor representative's ability to comment open for a total of 60 days, and locks you out permanently on day 61. So a missed 14-day window is a lost opportunity to shape what evaluators see first, but it is not the end of your ability to put a response in the permanent record.
Three failure points account for most of the damage.
One more thing worth knowing if you have no federal record at all. Under FAR 15.305(a)(2)(iv) an offeror without relevant past performance may not be evaluated favorably or unfavorably, and GAO has treated exclusion from a competitive range based solely on that neutral rating as improper. A neutral rating is often a better position than a weak Satisfactory earned on a poorly matched reference.
Did the FY2026 NDAA eliminate CPARS adjectival ratings?
No. The proposal to replace them with a negative-events-only record appeared in both the House and Senate versions but was dropped before the bill was signed on December 18, 2025. Exceptional through Unsatisfactory remain in effect under FAR 42.1503(b). Articles stating otherwise were almost all published before enactment and never updated.
Should I cite FAR 42.15 or FAR 42.11 for CPARS requirements?
Both are currently correct, depending on the agency. The codified FAR still contains Subpart 42.15. Agencies operating under a FAR overhaul class deviation, including DoD, use the renumbered Subpart 42.11. Match the citation to the agency you are dealing with, and expect this to consolidate when the overhaul is finalized in the FAR itself.
Can a bad CPARS rating affect my current contract, not just future bids?
Yes, for awards dated on or after April 1, 2026 at agencies operating under the FAR overhaul deviation. Past performance information can now inform decisions across the acquisition lifecycle, including option exercises and award fee determinations. Evaluations on earlier awards stay marked as source selection information.
How long do I actually have to respond to an evaluation?
Fourteen days to have your comments considered before the evaluation goes to source selection officials, and 60 days total before your access closes. Responding inside the 14 days is the version evaluators see immediately. After day 60 the record is fixed.
Will DoD start accepting my commercial work as past performance?
Section 824 requires DoD to issue guidance on that by December 18, 2026, aimed at requirements without much precedent. The guidance will likely require validation of non-government references, including attestation from an official of the referencing organization. Until it is published, the specific documentation standard is unknown.
Start by confirming the designated contractor representative in CPARS is a current employee who monitors notifications, because everything else depends on seeing the evaluation in time. Then check the award dates on your active contracts against April 1, 2026 to identify which evaluations can now follow you into option and award fee decisions. Build the documentation habit that a lifecycle-wide record rewards, meaning acceptance records, delivery confirmations, and closed corrective actions captured as performance happens rather than reconstructed under a 14-day clock. If you plan to pursue DoD work on the strength of commercial experience, get your non-government references into a format with a named attesting official and verified contact information before the December 2026 guidance lands. For businesses that want a second set of eyes on how their past performance record reads to an evaluator, USFCR's Federal Contract Consulting supports documentation review and past performance positioning.