GSA Refresh 31 *Updated* TDR Mandatory for All

GSA Refresh 31 Release Date

After a short delay from the original expected date in February, GSA released Refresh 31 of the GSA Multiple Award Schedule (MAS) solicitation on April 2, 2026.

Refresh 31 Changes

The first refresh of 2026 marks a significant milestone for the GSA MAS Program. Refresh 31 expanded Transactional Data Reporting (TDR) to all GSA MAS Special Item Numbers (SINs) and made the program mandatory for all GSA MAS Contractors.

Several updates were made between the original Refresh 31 announcement in January and its release last week. We’ve revised this post to capture those updates and highlight Refresh 31 changes, which include:

• TDR Mandatory for All GSA MAS Contracts
• Eligibility Limitations on Startup Springboard
• Clause Updates
• Other Schedule-Wide Changes
  • Newly Required TDR Reporting Elements
  • OLM Changes to Minimize Need for Open Market Items
  • Delayed Implementation of Newly Proposed AI Clause
• SIN Specific Changes

TDR Mandatory for All GSA MAS Contracts

The long awaited expansion of Transactional Data Reporting (TDR) to all GSA MAS Contract SINs has finally arrived. Refresh 31 expanded TDR to all GSA MAS Contract SINs and made participation mandatory.

Nearly a decade after the pilot was introduced as an optional program to select SINs, TDR is now the standard for all GSA MAS Contracts. This is especially significant because it means the end of the Basis of Award, customer sales tracking, and the infamous Price Reductions Clause. Learn more about TDR and what it means for your GSA MAS Contract here.

Please note, TDR does not impact the VA Federal Supply Schedule (FSS) Contracts.

What Does Mandatory TDR Mean for Prospective & Existing GSA MAS Contractors?

Prospective GSA MAS Contractors will not be able to move forward with a non-TDR proposal. GSA noted, all non-TDR proposals will be rejected. This means you will need to redo your proposal under TDR guidelines and withdraw your offer if it had been submitted prior to Refresh 31 and not yet awarded.

Existing GSA MAS Contractors who are not yet participating in TDR must accept the “Participate in TDR” mass modification that will be issued.

Contractors will no longer be subject to the Price Reductions Clause and should begin capturing transactional-level data on the first day of the next sales reporting quarter following acceptance of the “Participate in TDR” modification.

Eligibility Limitations on Startup Springboard

To qualify for a GSA MAS contract, companies must have at least two years in business. GSA’s Startup Springboard, which was rolled out in 2016, provided an exception to this requirement for the information technology industry, paving a path to award for IT startups. In 2022, the program was expanded to allow startups from any industry. Refresh 31 not only reverses course on that expansion, but will restrict the Startup Springboard program even further.

As of Refresh 31, GSA’s Startup Springboard will be limited to companies qualifying under the FASt Lane program.

Clause Updates

While the majority of added/deleted clauses are due to TDR becoming mandatory for all GSA MAS contractors, the updated clauses also include spillover items from the Refresh 30 FAR Overhaul Clause updates. In addition to those detailed below, Refresh 31 will incorporate clause/provision updates through Federal Acquisition Circular (FAC) 2025-06, as necessary.

1. Added Clauses
2. Deleted Clauses
3. Updated Clauses

Added Clauses

Deleted Clauses

The clauses listed in the chart below will no longer be incorporated in the GSA MAS Solicitation.

Updated Clauses

The following clauses will be 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.

Other Schedule-Wide Changes

• Contractors will be required to submit additional TDR reporting elements, some of which were previously optional. The updated reporting requirements will go into effect when they are incorporated into the Sales Reporting Portal, which is to be determined.
• While technically a SIN-specific change, updates to the Order-Level Materials (OLM) SIN are intended to significantly reduce the need for open market items, which impacts all GSA MAS Contractors.
• Subcontracting templates have been updated to align with FAR Overhaul changes.
• The Firearms and Ammunition note in each Large Category attachment was updated to exclude “foreign replica weapons and inert ordnance”.

Delayed Schedule-Wide Change

• Implementation of the newly proposed AI clause, GSAR 552.239-7001, will be delayed (possibly until Refresh 32) to allow additional time for feedback.

SIN Specific Changes

Human Capital

• SIN 524292 – Separation and Retirement
  • Add SIN instructions
• Revise SIN descriptions/instructions for the following SINs:
  • SIN 54161 – Agency Human Capital Evaluation
  • SIN 541612 – EPM Employee Performance Management
  • SIN 541612ER – Employee Relations
  • SIN 541612HC – Agency Human Capital Strategy Policy and Operations
  • SIN 56131 – Talent Acquisition
  • SIN 611430TD – Talent Development

IT

• New Large Category Note
  • “Each ITC SIN has its own special requirements. All proposed ITC labor categories (LCATs) must include differentiation in both the title and the  description to comply with the specific ITC SIN under which it is proposed.”
• SIN 561422 – Automated Contact Center Solutions (ACCS):
  • SIN description is being revised to state, “Any labor categories offered must be in support of the total solution and cannot be a stand alone offering.”

Facilities

• SIN 311423 – Non Perishable Foods
  • SIN 311423 is permanently closed to new offers as of April 2, 2026.
  • The SIN will be retired in Refresh 32, meaning non-perishable foods will no longer be sold under the GSA MAS Contract.

Miscellaneous

• SIN OLM – Order-Level Materials (OLM)
  • Following the changes implemented with Refresh 30, the OLM SIN will be open to all GSA MAS Contractors, as opposed to just those who held one or more of the OLM-eligible Subcategories.
  • OLM SIN changes are intended to limit open market items to rare/exceptional cases.
  • Contractors who do not currently hold the OLM SIN (whether they were previously not eligible or previously declined to add the OLM SIN) will have a one-time opportunity to add the OLM SIN by accepting the mass mod that will be issued to them.

Office Management

• Revised Office Supplies Subcategory instructions, as well as the SIN descriptions, notes, and required templates, as applicable, for the following SINs:
  • SIN 339940OS4 – OS4 Office Products and Supplies
  • SIN 339940 – Office Products
  • SIN 339940SVC – Office Supply Support Services
• SIN 3332493D – Printing Solutions and Additive Manufacturing Solutions
  • Revise SIN instructions

Professional Services

•  SIN 541211 Auditing Services
  • Revises SIN instructions to remove CPA and Peer Review requirements.
• SIN 611TRAINAW – Defense Acquisition Workforce Improvement Act (DAWIA) and Federal Acquisition Certification in Contracting (FAC-C) Professional Development Training for Acquisition Workforce Personnel
  • Revise SIN description and instructions.
• SIN 611430 – Professional and Management Development Training
  • Revise SIN description.

Transportation and Logistics Services

• SIN SIN 488190 Aircraft Components, Maintenance, Repair Services, Extended Warranties, And Maintenance Agreements
  • Revise SIN instructions.
• The SIN-Specific templates will be revised for the following SINs:
  • SINs 492110 – Package Delivery and Freight Trucking
  • SIN 492210 – Local Courier Delivery Services
  • SIN 485 – Ground Transportation
  • SIN 532111 – Automotive equipment rental and leasing, Rental Supplemental Vehicle Program (RSVP)

Travel

• The SIN-Specific templates will be revised for the following SINs, as well as the SOW for SIN 561510.
  • SIN 531 – Employee Relocation
  • SIN 531110 – Long Term Lodging
  • SIN 561510 – Travel Agent Services

Need Help Navigating Changes and Contract Updates?

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