Organizational Conflict of Interest Guide 2025: OCI Types & Mitigation

Quick Answer: What is OCI?

An Organizational Conflict of Interest (OCI) exists when a contractor's work creates an unfair competitive advantage or when the contractor cannot provide objective advice due to conflicting interests. OCI rules (FAR 9.5) protect the integrity of the procurement process.

OCI Types

FAR 9.5

Governing Rule

Waiver

Possible

What is an Organizational Conflict of Interest?

An OCI arises when a contractor's relationship with the government or other parties creates a situation where their objectivity or competitive position is compromised.

OCI Concerns

→Unfair competitive advantage
→Impaired objectivity in advice
→Biased ground rules for competition

Three Types of OCI

1. Unequal Access to Information

Contractor has access to non-public information that gives competitive advantage:

→Access to competitor proposals
→Inside knowledge of requirements
→Early access to procurement info

2. Biased Ground Rules

Contractor helped create the requirements they're competing on:

→Wrote specifications
→Developed SOW/PWS
→Created evaluation criteria

3. Impaired Objectivity

Contractor's judgment may be influenced by self-interest:

→Evaluating own products
→Advising on follow-on work
→Financial interest in outcome

Identifying OCI

OCI Risk Factors

High Risk Work

SETA, advisory, acquisition support

Related Work

Work on same program or system

Follow-On

Competing for work you helped create

Affiliations

Subcontractors, teaming partners, affiliates

OCI Mitigation Strategies

Common Mitigation Approaches

Firewalls

Prevent information sharing between conflicted groups

Recusal

Exclude conflicted individuals from work

Divestiture

Give up conflicting work or interests

Non-Disclosure Agreements

Contractual protections for information

OCI Waivers

In some cases, agency heads can waive OCI requirements if mitigation is adequate and the conflict is not significant. Waivers are rare and require strong justification.

Frequently Asked Questions

Do I have to disclose potential OCIs?

Yes. FAR requires contractors to disclose actual or potential OCIs. Failure to disclose can result in contract termination and debarment.

Can OCI prevent me from winning work?

Yes. Unmitigated OCIs can result in disqualification from competition. However, many OCIs can be mitigated, allowing you to compete.

How do I know if I have an OCI?

Review your current contracts, teaming arrangements, and corporate affiliations. Consider whether any give you unfair advantage or bias your judgment on new work.

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FAR Overview Guide

Understanding FAR 9.5

Contract Protests Guide

OCI as protest ground