GSA Refresh 31 Release Date
GSA is expected to release Refresh 31 of the GSA Multiple Award Schedule (MAS) solicitation in February.
Refresh 31 Changes
The first refresh of 2026 will mark a significant milestone for the GSA MAS Program. Refresh 31 will expand Transactional Data Reporting (TDR) to all GSA MAS Special Item Numbers (SINs) and become mandatory for all GSA MAS Contractors.
Below are the main highlights expected in Refresh 31. Stay tuned for an update once Refresh 31 is officially released.
- TDR Mandatory for All GSA MAS Contracts
- Eligibility Limitations on Startup Springboard
- Clause Updates
- Other Changes
- 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 expands TDR to all GSA MAS Contract SINs and makes participation mandatory.
Nearly a decade after the pilot was introduced as an optional program to select SINs, TDR will become the standard for GSA MAS contracts. This is especially significant because it means the end of the Basis of Award, customer sales tracking, and the 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?
According to currently available Refresh 31 documentation:
- 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 may need to redo your proposal under TDR guidelines and withdraw your offer if it has already been submitted.
- 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 was rolled out in 2016 to provide 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 Startup Springboard 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.
Added Clauses
| Clause | Clause Title |
| 552.238-80 | INDUSTRIAL FUNDING FEE AND SALES REPORTING (DEC 2025)(GSAR DEVIATION) |
| 552.238-81 | PRICE REDUCTIONS (DEC 2025)(GSAR DEVIATION) |
| 552.238-82 | MODIFICATIONS (FEDERAL SUPPLY SCHEDULES) (DEC 2025)(GSAR DEVIATION) |
| 52.223-11 | OZONE-DEPLETING SUBSTANCES (MAY 2024) (DEVIATION NOV 2025) |
Deleted Clauses
The clauses listed in the chart below will no longer be incorporated in the GSA MAS Solicitation.
| Clause | Title |
|---|---|
| 552.238-80 | INDUSTRIAL FUNDING FEE AND SALES REPORTING (JUL 2020) |
| 552.238-80 | INDUSTRIAL FUNDING FEE AND SALES REPORTING (JUL 2020) ALTERNATE I (MAY 2024) (DEVIATION) |
| 552.238-81 | PRICE REDUCTIONS (MAY 2019) |
| 552.238-81 | PRICE REDUCTIONS (MAY 2019) (ALTERNATE I – APR 2014) |
| 552.238-81 | PRICE REDUCTIONS (DEC 2021) (DEVIATION) |
| 552.238-82 | MODIFICATIONS (FEDERAL SUPPLY SCHEDULE) (JAN 2022) (ALTERNATE I MAR 2020) |
| 552.238-82 | MODIFICATIONS (FEDERAL SUPPLY SCHEDULE) (JAN 2022) (ALTERNATE II MAY 2019) |
| 52.204-27 | PROHIBITION ON A BYTEDANCE COVERED APPLICATION (JUN 2023) |
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.
| Clause | Clause Title |
| 52.222-1 | NOTICE TO THE GOVERNMENT OF LABOR DISPUTES (FEB 1997) (DEVIATION NOV 2025) |
| 52.222-10 | COMPLIANCE WITH COPELAND ACT REQUIREMENTS (FEB 1988) (DEVIATION NOV 2025) |
| 52.222-14 | DISPUTES CONCERNING LABOR STANDARDS (FEB 1988) (DEVIATION NOV 2025) |
| 52.222-3 | CONVICT LABOR (JUN 2003) (DEVIATION NOV 2025) |
| 52.222-32 | CONSTRUCTION WAGE RATE REQUIREMENTS-PRICE ADJUSTMENT (ACTUAL METHOD) (AUG 2018) (DEVIATION NOV 2025) |
| 52.222-40 | NOTIFICATION OF EMPLOYEE RIGHTS UNDER THE NATIONAL LABOR RELATIONS ACT (DEC 2010) (DEVIATION NOV 2025) |
| 52.222-41 | SERVICE CONTRACT LABOR STANDARDS (AUG 2018) (DEVIATION NOV 2025) |
| 52.222-43 | FAIR LABOR STANDARDS ACT AND SERVICE CONTRACT LABOR STANDARDS-PRICE ADJUSTMENT (MULTIPLE YEAR AND OPTION CONTRACTS) (AUG 2018) (DEVIATION NOV 2025) |
| 52.222-49 | SERVICE CONTRACT LABOR STANDARDS-PLACE OF PERFORMANCE UNKNOWN (MAY 2014) (DEVIATION NOV 2025) |
| 52.222-5 | CONSTRUCTION WAGE RATE REQUIREMENTS-SECONDARY SITE OF THE WORK (MAY 2014) (DEVIATION NOV 2025) |
| 52.222-51 | EXEMPTION FROM APPLICATION OF THE SERVICE CONTRACT LABOR STANDARDS TO CONTRACTS FOR MAINTENANCE, CALIBRATION, OR REPAIR OF CERTAIN EQUIPMENT-REQUIREMENTS (MAY 2014) (DEVIATION NOV 2025) |
| 52.222-55 | MINIMUM WAGES FOR CONTRACTOR WORKERS UNDER EXECUTIVE ORDER 14026 (JAN 2022) (DEVIATION NOV 2025) |
| 52.222-56 | CERTIFICATION REGARDING TRAFFICKING IN PERSONS COMPLIANCE PLAN (NOV 2025) (DEVIATION NOV 2025) |
| 52.222-62 | PAID SICK LEAVE UNDER EXECUTIVE ORDER 13706 (JAN 2022) (DEVIATION NOV 2025) |
| 52.222-7 | WITHHOLDING OF FUNDS (MAY 2014) (DEVIATION NOV 2025) |
| 52.222-8 | PAYROLLS AND BASIC RECORDS (JUL 2021) (DEVIATION NOV 2025) |
| 52.222-9 | APPRENTICES AND TRAINEES (JUL 2005) (DEVIATION NOV 2025) |
Other Changes
- Subcontracting templates will be updated to align with FAR Overhaul changes.
- The General Information section of each Large Category attachment will be updated to incorporate language related to recent Executive Orders on AI.
- The Firearms and Ammunition note in each Large Category attachment will be updated to exclude “foreign replica weapons and inert ordnance”.
SIN Specific Changes
Office Management
- Revise 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
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
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 61 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 will have a one-time opportunity to add the OLM SIN.
Professional Services
- SIN 541211 Auditing Services
- Revise SIN instructions.
- 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
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