This guide explains FAR Part 22 of the Federal Acquisition Regulation (FAR), with practical examples for federal contractors.
Watch the FAR Part 22 video
FAR Part 22: labor-law coverage
FAR Part 22 addresses the application of labor laws to government acquisitions. Its coverage begins at FAR 22.000. It covers general labor relations policy, the procedures for applying the pertinent labor laws, and the contract clauses tied to those laws. Think of it as a map, not a single rule. Different subparts cover different kinds of work and different workers. Not every labor law covers every worker on every contract.
FAR Subpart 22.1 sets out basic labor policies. These are the general ground rules that frame the rest of the part. Two regimes matter most here. Construction labor standards sit in FAR Subpart 22.4, and service contract labor standards sit in FAR Subpart 22.10. They are distinct, and each has its own test. First, start with construction. FAR 22.402 applies construction labor standards to laborers and mechanics who work at the site of the work.
Construction wages and service-contract labor standards
That coverage has exceptions, so read the section itself rather than assuming everyone on the job is covered. Two common misconceptions. Work done off site, such as manufacturing materials in a factory, is not automatically covered. Neither is a contractor's home office staff. Now services. FAR 22.1003-1 applies to contracts whose principal purpose is providing services in the United States using service employees. Exemptions and subcontract rules apply too.
Principal purpose is the key test. A contract that includes some incidental service, but is mainly for something else, is not automatically covered. And the label on the contract does not decide it. The actual work does. Both regimes work through wage determinations. A wage determination lists the wage rates and fringe benefits that apply to particular kinds of work. The base wage is the hourly pay.
Fringe obligations may be satisfied through qualifying benefit contributions or cash equivalents as permitted by the applicable requirements. Both belong in your price. The obligations travel through contract clauses. Payroll and records requirements, and flowdowns to subcontractors, come from the clauses in your contract. Next, read which ones are included and what each requires. An omitted requirement is not a safe harbor. FAR 22.404-9 requires correction after award when a required wage determination was left out of a construction contract.
Resolve coverage before pricing
FAR Part 22 also touches other issues. For example, Subpart 22.17 addresses combating trafficking in persons, while Subpart 22.18 covers employment eligibility. In addition, Subparts 22.13 and 22.14 cover veterans and workers with disabilities, respectively. One caution about what you are reading. The codified text in Federal Acquisition Circular 2026-01 is the baseline. Some provisions trace to executive orders, and agencies may issue deviations that change how a part applies.
The FAR overhaul deviation guide shows the current picture. However, do not assume an older executive order requirement is still mandatory. A clause listed in a solicitation does not prove a revoked order still applies. Then, check current applicable law and your agency's deviations. For example, consider Ridgeline Facilities bidding on one solicitation. In addition, it includes renovating a loading dock, plus nightly cleaning and grounds care at the same building.
Question one, for the renovation. Is this construction work at the site? Laborers and mechanics doing the dock work on site point toward the construction rules in FAR Subpart 22.4. Question two, for the cleaning and grounds care. Are these recurring services using service employees in the United States? Is that the principal purpose, or is it incidental to the construction? Does the solicitation treat them as separate requirements?
Apply the rules to a mixed-work solicitation
However, do not decide from the title of the opportunity. Also, read which clauses and wage determinations the solicitation actually attaches. If it is unclear, ask the contracting officer in writing. Now, what to price. Apply each regime only after confirming actual coverage, and resolve mixed work, separability, and exemptions with the contracting officer. One solicitation does not automatically bring both. Fringe obligations can be met with bona fide benefit contributions or cash equivalents, as permitted, not necessarily a separate cash add-on.
In addition, include payroll records and flowdowns where they apply. If no wage determination is attached to work that looks covered, ask before you bid.
FAR Part 22 action checklist
- First, list each task and where the work will be performed.
- Next, find the labor clauses and wage determinations in the solicitation, and note any subcontracts that need flowdowns.
- Then, check your agency's deviations in the deviation guide.
- Finally, send unclear questions to the contracting officer in writing, and keep the answers with your proposal.
To learn more, visit govsuccess.com. This is an educational overview, not legal advice. For decisions, rely on the official text on acquisition.gov, your solicitation, and qualified counsel.
Official sources
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