If your business holds a General Services Administration (GSA) Multiple Award Schedule (MAS) contract—or if you are in the process of submitting a new offer—the landscape is actively shifting.
Earlier this year, the GSA announced significant updates under MAS Solicitation 47QSMD20R0001 – Refresh #31. With the industry feedback window officially closed as of March 20, 2026, the GSA is moving forward with these massive changes.
Refresh #31 is not just a routine update; it introduces sweeping mandates regarding Artificial Intelligence (AI) compliance and a massive expansion of the Transactional Data Reporting (TDR) program. Here is exactly what you need to know and how your business should prepare to respond.
What is GSA MAS Refresh #31 and Why It Matters
GSA MAS Refresh #31 represents a major shift in compliance requirements and reporting expectations for contractors. It is designed to improve transparency, pricing accuracy, and oversight across federal procurement.
TDR is Expanding (And Becoming Mandatory for New Offers)
For years, the Transactional Data Reporting (TDR) pilot program has been a tool for the GSA to collect granular data points on the exact prices paid for products and services. This data is the backbone of the government’s push to root out fraud, waste, and abuse by ensuring all offers remain “fair and reasonable.”
Under Refresh #31, the GSA is taking the training wheels off the TDR program:
- The Expansion: TDR is being expanded to the remaining 112 Services Special Item Numbers (SINs).
- The Mandate: GSA intends to make TDR mandatory for all SINs under the MAS solicitation for any new MAS offers submitted after Refresh #31 takes effect
What this means for you: If you are preparing a new offer, you must structure your pricing and internal accounting systems to handle the TDR format. You will no longer have the option to opt out of this detailed reporting.
Strict New AI Compliance Rules in GSA MAS Refresh #31
It is no surprise that the federal government is moving aggressively to regulate Artificial Intelligence. If your business offers any AI products or services through your GSA Schedule, your compliance burden is about to get much heavier.
Refresh #31 incorporates new terms and conditions specifically for AI systems, directly implementing the policy directives outlined in OMB Memorandum M-25-22: Driving Efficient Acquisition of Artificial Intelligence in Government.
What this means for you: Contractors selling AI solutions must meticulously review the new draft AI terms. You need to pay special attention to the newly proposed language at GSAR 552.239-7001(e), which explicitly details your ongoing contractor obligations, reporting requirements, and compliance measures.
Targeted Category Updates
Beyond TDR and AI, Refresh #31 includes targeted updates that will affect several specific Large Categories. If you operate within any of the following spaces, you need to review the specific modifications to your SINs:
- Travel
- Office Management
- Human Capital
- Information Technology
- Professional Services
- Transportation and Logistics Services
Your Action Plan: What You Need to Do Next
With the release of Refresh #31 underway, passive compliance is a recipe for disaster. Here is your immediate action plan:
- Watch the Clock on the Mass Mod: As the GSA officially pushes Refresh #31 to your eOffer/eMod portal, you will be issued a Mass Modification. You have exactly 60 days to accept this Mass Mod once it is issued. Failure to accept it in a timely manner can result in your catalog being hidden from GSA Advantage or other administrative penalties.
- Evaluate Your AI Offerings: Bring your legal and compliance teams together to review GSAR 552.239-7001(e). Ensure your current AI products meet the new OMB M-25-22 standards before the government audits your offerings.
- Upgrade Your Reporting Systems: If you are submitting a new offer or modifying an existing one to include TDR, ensure your back-office software can accurately track and report the specific prices paid by government buyers.
Need Help Navigating Your GSA Schedule?
Keeping up with the GSA’s constantly evolving compliance landscape can feel like a full-time job. Whether you need help accepting your Mass Mod, understanding how TDR impacts your pricing strategy, or getting your initial MAS offer across the finish line, EZ8a is here to help. Contact us today to ensure your government contracts stay profitable and compliant.
