GSA Refresh 30 Release Date
GSA released Refresh 30 of the GSA Multiple Award Schedule (MAS) solicitation on November 24, 2025.
Refresh 30 Changes
The main highlight of Refresh 30 is the incorporation of a slew of class deviations resulting from the FAR Overhaul. Also prominent was what was not included. While Refresh 30 did not include any further expansion of Transactional Data Reporting (TDR), it is still expected in a future refresh.
In addition to the changes below, GSA released an updated modification guide.
- FAR Overhaul Clause Updates
- Letter of Supply Clause Update
- Updated Note on Drones/Unmanned Aircraft Systems
- Ordering Procedures Note
- Price Proposal Templates (PPTs)
- Subcategory/SIN Specific Changes
- Other Changes
FAR Overhaul Clause Updates
We have gone through all the Refresh 30 clause changes and grouped them into the following three categories:
Added Clauses
The solicitation document includes a long list of added clauses. However, the majority of those clauses are not true additions. They were previously listed in the Incorporated by Reference Document, and were moved to the solicitation in Refresh 30. A change in location is more of an administrative, formatting change that has no impact on the clause.
The chart below includes clauses that are truly new additions.
| Clause | Clause Title |
| 52.204-27 | Prohibition on a ByteDance Covered Application |
| 52.208-90 | Government Supply Sources (FAR Overhaul) |
| 52.222-30 | Construction Wage Rate Requirements-Price Adjustment (None or Separately Specified Method). |
| 52.240-90 | Security Prohibitions and Exclusions Representations and Certifications. (FAR Overhaul) |
| 52.240-91 | Security Prohibitions and Exclusions (FAR Overhaul) |
| 52.240-93 | Basic Safeguarding of Covered Contractor Information Systems (FAR Overhaul) |
Deleted Clauses
The clauses listed in the chart below are no longer incorporated in the GSA MAS Solicitation.
| Clause | Title |
|---|---|
| 52.204-17 | Ownership or Control of Offeror |
| 52.204-18 | Commercial and Government Entity Code Maintenance |
| 52.204-2 | Security Requirements |
| 52.204-20 | Predecessor of Offeror |
| 52.204-21 | Basic Safeguarding of Covered Contractor Information Systems |
| 52.204-23 | Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky Lab Covered Entities |
| 52.204-24 | Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment |
| 52.204-25 | Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment |
| 52.204-29 | Federal Acquisition Supply Chain Security Act Orders—Representation and Disclosures |
| 52.204-30 | Federal Acquisition Supply Chain Security Act Orders—Prohibition |
| 52.208-4 | Vehicle Lease Payments |
| 52.208-5 | Condition of Leased Vehicles |
| 52.208-6 | Marking of Leased Vehicles |
| 52.208-7 | Tagging of Leased Vehicles |
| 52.212-3 | Offeror Representations and Certifications—Commercial Products and Commercial Services |
| 52.212-5 | Contract Terms and Conditions Required To Implement Statutes or Executive Orders—Commercial Products and Commercial Services |
| 52.222-46 | Evaluation of Compensation for Professional Employees |
| 52.223-10 | Waste Reduction Program |
| 52.223-11 | Ozone-Depleting Substances and High Global Warming Potential Hydrofluorocarbons |
| 52.223-20 | Aerosols |
| 52.223-21 | Foams |
| 52.225-1 | Buy American—Supplies |
| 52.225-13 | Restrictions on Certain Foreign Purchases |
| 52.225-25 | Prohibition on Contracting with Entities Engaging in Certain Activities or Transactions Relating to Iran—Representation and Certifications |
| 52.240-1 | Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act-Covered Foreign Entities |
| 52.247-65 | Not listed in standard FAR Part 52 table of clauses; may be a supplement or agency-specific clause. (No title found in the publicly available general FAR clause index.) |
| 52.251-1 | Government Supply Sources |
Updated Clauses
The following clauses have been updated to incorporate the FAR Overhaul deviation which can be found here: https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-52.
| Clause | Clause Title |
| 22.1002-3 | Wage Determinations Based on Collective Bargaining Agreements |
| 52.204-10 | Reporting Executive Compensation and First-Tier Subcontract Awards. |
| 52.204-13 | System for Award Management—Maintenance. |
| 52.204-15 | Service Contract Reporting Requirements for Indefinite-Delivery Contracts. |
| 52.204-7 | System for Award Management. |
| 52.208-9 | Contractor Use of Mandatory Sources of Supply or Services |
| 52.209-10 | Prohibition on Contracting with Inverted Domestic Corporations |
| 52.209-2 | Prohibition on Contracting with Inverted Domestic Corporations-Representation |
| 52.209-5 | Certification Regarding Responsibility Matters |
| 52.209-6 | Protecting the Government’s Interest When Subcontracting With Contractors Debarred, Suspended, Proposed for Debarment, or Voluntarily Excluded |
| 52.209-7 | Information Regarding Responsibility Matters |
| 52.209-9 | Updates of Publicly Available Information Regarding Responsibility Matters |
| 52.212-1 | Instructions to Offerors — Commercial Items. |
| 52.215-20 | Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data—Modifications. |
| 52.215-21 | Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data—Sealed Bidding. |
| 52.215-6 | Place of Performance. |
| 52.216-1 | Type of Contract. |
| 52.216-22 | Indefinite Quantity. |
| 52.219-1 | Small Business Program Representations. |
| 52.219-14 | Limitations on Subcontracting. |
| 52.219-16 | Liquidated Damages — Subcontracting Plan. |
| 52.219-27 | Notice of Service-Disabled Veteran-Owned Small Business Status. |
| 52.219-28 | Post-Award Small Business Program Rerepresentation. |
| 52.219-29 | Notice of Set-Aside of Orders. |
| 52.219-3 | Notice of HUBZone Set-Aside or Sole Source. |
| 52.219-30 | Notice of Set-Aside — Small Business. |
| 52.219-33 | Small Business Subcontracting Plan (Alternate I). |
| 52.219-6 | Notice of Total Small Business Set-Aside. |
| 52.219-8 | Utilization of Small Business Concerns. |
| 52.219-9 | Small Business Subcontracting Plan. |
| 52.222-11 | Subcontracts (Labor Standards). |
| 52.222-19 | Child Labor—Cooperation with Authorities and Remedies. |
| 52.222-35 | Equal Opportunity for Special Disabled Veterans, Veterans of the Vietnam Era, and Other Eligible Veterans. |
| 52.222-36 | Affirmative Action for Workers with Disabilities. |
| 52.222-37 | Employment Reports on Veterans. |
| 52.222-42 | Statement of Equivalent Rates for Federal Hires. |
| 52.222-43 | Fair Labor Standards Act and Service Contract Labor Standards-Price Adjustment |
| 52.222-48 | Exemption from Application of the Service Contract Act to Contracts for Maintenance, Calibration, or Repair of Certain Equipment—Requirements. |
| 52.222-49 | Service Contract Labor Standards-Place of Performance Unknown |
| 52.222-50 | Combating Trafficking in Persons. |
| 52.222-52 | Exemption from Application of the Service Contract Act to Contracts for Certain Services—Requirements. |
| 52.222-53 | Exemption from Application of the Service Contract Act to Contracts for Certain Services—Identification of Exempt Services and Notice. |
| 52.222-54 | Employment Eligibility Verification. |
| 52.222-5 | Minimum Wages for Contractor Workers Under Executive Order 14026 |
| 52.222-6 | Contract Work Hours and Safety Standards Act—Overtime Compensation. |
| 52.223-12 | Refrigeration Equipment and Air Conditioners. |
| 52.223-3 | Hazardous Material Identification and Material Safety Data. |
| 52.223-7 | Notice of Radioactive Materials. |
| 52.232-36 | Payment by Third Party—Contractor Addresses. |
| 52.233-1 | Disputes. |
| 52.233-2 | Service of Protest. |
| 52.233-3 | Protest after Award. |
| 52.233-4 | Applicable Law for Breach of Contract Claim. |
| 52.237-10 | Identification of Uncompensated Overtime |
| 52.247-64 | Preference for Privately Owned U.S.-Flag Commercial Vessels. |
| I-FSS-644 | Products Offered and Sold by Vendors Other than the Manufacturer |
Letter of Supply Clause Update
Earlier this year, Refresh 27 removed the requirement to provide Letter of Supply documentation, with the exception of products under the IT Large Category or Printing and Photographic Equipment Subcategory. As a follow on to that, GSA has now updated I-FSS-644, Products Offered and Sold by Vendors Other than the Manufacturer, to remove references to the requirement to provide evidence of an uninterrupted source of supply. Please note, contractors must still be authorized by the manufacturer to sell any products under the GSA Schedule.
Updated Note on Drones/Unmanned Aircraft Systems
The note included in all Large Category regarding Drones/Unmanned Aircraft Systems has been updated to: 1) include reference to the related FAR Overhaul clause, 52.240-91(c), and 2) add the language below that is already stated within the referenced clause. It appears the only significant change between the previously cited FAR Clause and the FAR Overhaul clause is the removal of the requirement to include the clause in subcontracts.
“On or after December 22, 2025, Contractors are prohibited from operating or using Federal fund to procure or operate a FASC-prohibited unmanned aircraft system.”
Ordering Procedures Note
Refresh 30 now includes the note below within Section III. Terms and Conditions Related to the Performance of an Order. You can review the newly created 538.71 clause here.
“Note: Ordering activities must follow procedures outlined in GSAR Subpart 538.71 (GSA Class Deviation RFO-2025-FSS-GSAR 538 and RFO-2025-08) Federal Supply Schedule Ordering Procedures for placing orders and establishing blanket purchase agreements (BPAs) against Federal Supply Schedule (FSS) contracts. Additional guidance can be found at http://www.gsa.gov/schedules.”
Price Proposal Templates (PPTs)
Price Proposal Template changes may be slowing down. This refresh, the PPT for SIN 492210, Local Courier Delivery Services, was updated to remove all expedited freight shipment line items. This was done to align the PPT with SIN 492110, Package Delivery and Freight Trucking, Statement of Work.
Other Changes
- The requirement to provide a Professional Compensation Plan for services was removed.
- Under Section III, Price Proposal, reference to available “Commercial Price List” was replaced with “established pricing (e.g., commercial price list, commercial catalog, or other standard market pricing)”
- Language was removed that stated Joint Ventures offering services were required to identify the partner providing the labor category within the “Labor Category/Service Title” column of the Services PPT.
Category/SIN Changes
Miscellaneous
- SIN OLM – Order-Level Materials (OLM)
- Some restrictions related to the Order-Level Material SIN have been removed.
- OLM’s cannot be the primary purpose of the order and still require fair and reasonable price determination by the customer, but OLM’s are no longer restricted to a total of 33.33% of an order or less.
- OLM’s must continue to be identified clearly in a GSA order as items that are not on the FSS contract.
- While the OLM SIN is still limited to 60 GSA Subcategories, GSA intends to remove that restriction in a future refresh.
Transportation and Logistics Services
- SIN 492210 – Local Courier Delivery Services
- The SIN’s PPT was updated.
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