Contracts & Legal

Procuring Contracting Officer (PCO)

Procuring Contracting Officers (PCO) are warranted by their respective agencies to issue legal contracts between the US Government and the contracting entity. All programmatic, technical, and other contractual requirements established by the Program Manager (PM) for the contractor (or proposed contractor) must be issued by the PCO. Any changes that the contractor implements as a result of improper Government direction (e.g., constructive changes) could make the Government liable.

The relationship between the PM and the PCO varies. In most instances, the PCO is assigned by the Systems Command to support a program. The PCO does not report administratively to the PM; however, the PCO must still respond to the Program Manager’s programmatic and technical requirements.

Procuring Contracting Officer (PCO) Responsibilities:

The PCO has the following responsibility to:

  • Ensure all requirements of law, executive orders, regulations, and all other applicable procedures including clearances and approvals, have been satisfied
  • Ensure sufficient funds are available for obligation
  • Guide the Contracting Officer Representative (COR)
  • Ensure contractors receive fair and equitable treatment
  • Request and consider the advice of specialists in audit, law, engineering, transportation, and other fields as appropriate
  • A document that the proposed contract is in the best interest of the Government
  • Issue timely contracts and contract changes

The authority and requirements for the PCO are issued to the requirements specified in Federal Acquisition Regulations (FAR Subpart 1.6). Subsection 414(4) of Title 41, United States Code, requires agency heads to establish and maintain a procurement career management program and a system for the selection, appointment, and termination of the appointment of contracting officers.

CO shall be appointed in writing on an Standard Form (SF) 1402 – Certificate of Appointment, which shall state any limitations on the scope of authority to be exercised, other than limitations contained in applicable law or regulation. Appointing officials shall maintain files containing copies of all appointments that have not been terminated.


  • Sometimes called Program Contracting Officer (PCO)

AcqLinks and References:

Updated: 6/18/2021

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