Civilian Agency Acquisition Council (CAAC)

The Civilian Agency Acquisition Council (CAAC) is an interagency body composed of senior acquisition officials from civilian federal agencies that is responsible, together with the Defense Acquisition Regulations Council (DARC), for the ongoing development and maintenance of the Federal Acquisition Regulation (FAR). The CAAC represents the civilian agency perspective in all FAR rulemaking and policy development, ensuring that the uniform procurement framework reflects the operational realities of non-defense agencies.

What is the Civilian Agency Acquisition Council?

The CAAC was established pursuant to the Office of Federal Procurement Policy Act (41 U.S.C. 1302) and operates under the oversight of OFPP. Its membership includes designated senior procurement officials from major civilian departments and agencies such as the General Services Administration, the Department of Health and Human Services, the Department of Transportation, the Department of Homeland Security, and others.

The CAAC and DARC jointly constitute the FAR Council. When a regulatory change to the FAR is proposed -- whether in response to a statutory mandate, an executive order, a public comment, or an agency request -- the two councils work jointly to draft, circulate for interagency review, publish in the Federal Register as a proposed rule, consider public comments, and finalize the amendment. This process governs all additions, deletions, and modifications to the FAR's parts, subparts, and clauses.

The CAAC's specific function is to ensure that FAR amendments are workable for civilian agencies, which often have procurement environments that differ substantially from the defense acquisition context. Civilian agencies purchase a broader range of commercial products and services, operate under different statutory frameworks (for example, the Federal Property and Administrative Services Act for GSA), and serve different mission sets. The CAAC advocates for rules that function well across this diversity.

Individual civilian agencies may also issue agency-specific supplements to the FAR (such as the HHSAR, DOLAR, or DOLAR), but those supplements must be consistent with the FAR and are developed by agency acquisition policy offices rather than the CAAC itself.

Why it matters for contractors

Understanding that the FAR is maintained by a dual-council structure explains why FAR changes are deliberate and slow. A proposed FAR amendment typically moves through an interagency review, a public comment period of at least 60 days, and a final rule process that can take years. Contractors who track FAR rulemaking -- through the Unified Regulatory Agenda, the Federal Register, and OFPP notifications -- can anticipate clause changes before they appear in new solicitations.

When an agency signals it is pursuing a deviation from a standard FAR clause, it is working outside the CAAC/DARC joint process, which requires OFPP approval for significant deviations. Understanding this structure helps contractors recognize when an unusual solicitation clause represents a legitimate agency deviation versus a drafting error.

Example

Congress passes a statute requiring all federal contractors above a certain threshold to certify compliance with a new data security standard. OFPP directs the FAR Council -- the CAAC and DARC acting jointly -- to develop a implementing FAR clause. The CAAC drafts the clause language from the civilian agency perspective, the DARC reviews it for defense applicability, and the joint council publishes a proposed rule. Contractors who comment during the public comment period can shape the final clause language -- a legitimate and frequently underutilized avenue for influencing how legal requirements translate into contract obligations.