Beginner’s Guide to the GSA Contract Get the Guide Now

Transactional Data Reporting (TDR)

Transactional Data Reporting transforms the way GSA Multiple Award Schedule (MAS) Contracts are negotiated and managed. For contractors, TDR provides the option of holding a GSA Contract without the burden of the infamous Price Reductions Clause (PRC). For GSA, TDR provides critical insight into what the federal government is buying to help fuel smarter purchasing.

What is TDR?
📢As of Refresh 31, issued April 2, 2026, TDR is now Mandatory for all GSA MAS Contractors!

Get expert help to navigate the new reporting requirements and understand how TDR changes your contract.

What is Transactional Data Reporting?

Transactional Data Reporting is a pilot program that was introduced in August of 2016 under select GSA Schedule Contract Special Item Numbers (SINs).

TDR requires participating GSA contractors to submit monthly reports of the prices paid for GSA products and services, along with other transactional data, on a line-item basis.

In exchange for this additional data, contractors are exempt from:

  • Disclosing Commercial Sales Practices
  • Establishing a Most Favored Customer (MFC)/Basis of Award (BOA)
  • Tracking and Maintaining the Relationship Between GSA Pricing and MFC/BOA Customer Pricing
  • Complying With the Price Reductions Clause (PRC)

Some might describe the traditional method of negotiating GSA Contract pricing as antiquated and cumbersome. Transactional Data Reporting provides an alternative that allows for a modern, market-based approach to pricing negotiations.

By eliminating Commercial Sales Practices disclosures and the responsibilities associated with the Price Reductions Clause, TDR reduces the barrier of entry for all businesses, and for small businesses in particular.

The program took a significant step forward in August of 2024, when 67 SINs were made TDR-eligible. On June 26, 2025, TDR reached another significant milestone when GSA expanded the program to an additional 62 SINs and made TDR participation mandatory for GSA Contracts that include a TDR SIN.

TDR and Category Management

GSA Contractors view Transactional Data Reporting as a way to avoid the Price Reductions Clause and tracking pricing relationships. However, GSA originally introduced TDR, in part, to support Category Management.

Category Management is a government-wide initiative to approach federal buying as a single enterprise. Transactional level data on federal purchases provides the government with market intelligence to make smarter acquisitions and achieve taxpayer savings, which are key Category Management goals.

Category Management goals also include driving federal spend through contract vehicles that meet certain criteria, and away from open market procurements and duplicative contracts. Agencies are tasked with increasing their “Spend Under Management” each year, which means spending through contract vehicles classified as Tier 1, 2, or 3 solutions.

As a whole, the GSA MAS Contract is a Tier 2 solution, but certain SINs are considered the highest level, Tier 3, Best-in-Class solutions. Transactional data is not only a crucial component of evaluating the effectiveness of government-wide Category Management, it’s a requirement for any Best-in-Class (BIC) solutions. Opening all GSA MAS Contract SINs to Transactional Data Reporting, provides the possibility of additional SINs receiving a future BIC classification.

Transactional Data Reporting Highlights

  • TDR allows companies to hold a GSA MAS Contract without the burden of legacy pricing restrictions.
  • It requires companies to submit monthly reports on GSA Contract sales with specific data points, including prices paid.
  • As of Refresh 31, participation in the program is mandatory.
  • TDR will not expand to VA Schedule Contracts.
  • Transactional data is an eligibility requirement for Best-in-Class solutions.

6 Benefits of a TDR vs Non-TDR GSA MAS Contract

A GSA MAS Contract provides contractors with a broad range of benefits. However, it has traditionally come with a tradeoff – disclosing commercial sales practices, tracking sales to a Basis of Award Class of Customer, and continuous adherence to the infamous PRC.

Prior to Refresh 31, without TDR, companies were required to disclose their commercial sales policies and practices. They were also forced to offer pricing that reflects equal to or better than the most favorable pricing granted to a customer or class of customers that most resembles the buying habits of the federal government. This was known as the Most Favored Customer (MFC) or Basis of Award (BOA). Following the award of a GSA Contract, companies were required to track pricing to their MFC/BOA, report any price reductions, and depending on the circumstances, reduce their GSA pricing. TDR eliminates all of these burdensome responsibilities for companies.

1

Eliminates the Need to Disclose Commercial Sales Practices

Prior to mandatory TDR, companies were required to disclose Commercial Sales Practices as the first step in a complicated process of negotiating pricing. Whether your company was submitting an offer to obtain a GSA MAS Contract or a modification to make certain types of contract updates, non-TDR contracts were required to disclose Commercial Sales Practices (CSP) to GSA. At least that was the case prior to TDR.

In order to evaluate pricing under TDR, GSA uses internally available information on prices paid, as well as contractor provided pricing for same or similar items. This eliminates the need for companies to disclose their commercial sales practices.

2

Removes the Most Favored Customer/Basis of Award Requirement

This ties back to the traditional, non-TDR process for negotiating pricing. Without TDR, contractors were required to determine the customer or type of customer that not only received their best pricing, but also most closely resembled the buying practices of the federal government. This customer or class of customer was then established as a Most Favored Customer (MFC) or Basis of Award (BOA). TDR removes this requirement altogether.

3

Eliminates the Need to Track GSA and BOA/MFC Pricing Relationship

Under the previous traditional, non-TDR contract, pricing was negotiated based upon the pricing and discounts offered to a company’s MFC/BOA customer. Any change in pricing offered to the MFC/BOA necessitated a change in GSA MAS Contract pricing. This was due to the Price Reductions Clause, which we’ll cover next. This is why, absent TDR, companies were saddled with the burdensome requirement of tracking and maintaining the relationship between their GSA pricing and MFC/BOA pricing.

GSA estimates that TDR saves contractors an average of 22 labor hours per contract annually.

4

Exempts Contractors from Complying with the Price Reductions Clause

Holding a GSA MAS Contract comes with a host of benefits. However, the Price Reductions Clause (PRC) is not one of them. Prior to Refresh 31, if a non-TDR contractor provided a price reduction to their BOA customer, the PRC required that contractor to make applicable adjustments to GSA pricing and/or terms and conditions, based upon the discount relationship between the BOA customer and GSA pricing.

While tracking and maintaining your GSA/BOA pricing relationship was one of the most onerous responsibilities associated with holding a GSA MAS Contract, the PRC was arguably the most consequential obligation of non-TDR contracts.

Once again, the PRC was a by-product of how GSA has traditionally negotiated contract pricing. As of Refresh 31, Contractors are required to participate in GSA Transactional Data Reporting, which frees them from the Price Reductions Clause and are concerns that accompany it.

5

Reduces the Scope of a Potential OIG Audit

GSA Office of Inspector General (OIG) audits are intended to determine if any non-compliance should result in refunds, retroactive price reductions, permanent price reductions, and/or a change in the Basis of Award customer.

Traditionally, OIG audits focus primarily on non-compliance with Commercial Sales Practices, Basis of Award, and the Price Reductions Clause. With TDR no mandatory, all of these factors are eliminated.

While the OIG can still audit compliance with other requirements, including prompt payment discounts, TAA, and labor category qualifications, TDR significantly reduces the scope of an audit.

6

Supports Category Management & Allows Potential for a Best-in-Class Designation

Collecting transactional data is a key component of Category Management. A simplified explanation of Category Management is that it is a business practice employed governmentwide that helps federal buyers make more effective purchasing decisions. It directs federal buyers away from open market contracts and towards specific contracts that meet Category Management principles.

To select top tier and Best-in-Class contract solutions, Category Management relies heavily on data elements, including prices paid. All GSA MAS Contracts are considered a Tier 2 solution under Category Management; however, some GSA SINs receive the highest designation of Best-in-Class Tier 3 solutions. Opening TDR to all GSA MAS SINs increases the potential for additional SIN offerings to rise to the level of Best-in-Class solutions.

Requirements for Transactional Data Reporting

TDR requires that all GSA MAS Contractors report transactional level data. This includes the price paid by federal buyers for products and services purchased through the contractor’s GSA Contract. The transactional level data provides the government with market intelligence to make smarter acquisitions and achieve taxpayer savings, which are key Category Management goals.

What Data Do You Have to Submit as Part of TDR?

  • Contract or BPA Number
  • Delivery/Task Order Number/Procurement Instrument Identifier (PIID)
  • Non Federal Entity
  • Description of Deliverable
  • Manufacturer Name
  • Manufacturer Part Number
  • Unit Measure
  • Universal Product Code
  • Quantity of Item Sold
  • Price Paid per Unit
  • Total Price
  • Special Item Number (SIN)
  • Agency Name (Required for OS4 SINs only)
  • Tier 3 Agency Name (Required for OS4 SINs only)

Additional TDR Data Reporting Requirements as of Refresh 31

The new reporting elements listed below will become mandatory when GSA incorporates them into the Sales Reporting Portal.

  • Ship Date
  • Order Date
  • Shipping Zip Code
  • Federal Customer Treasury Agency Code
  • Cloud Service Type, as applicable
  • Unique Catalog Identifier (UCID), as applicable
  • Order Type
  • Order Discount, as applicable
  • Worksite, as applicable

Additionally, contractors must conduct a one-time upload of their PWS, SOO, or SOW upon the initial task order award of a Professional and SCA or SCLS firm fixed price service contract order above $1 million.

Is Your Contract Required to Participate in TDR?

As of Refresh 31, issued April 2, 2026, TDR is mandatory for all GSA MAS Contract holders.

Get Expert Help With TDR

Whether you need help understanding TDR reporting requirements or submitting a proposal under TDR, we can help.

© Copyright 2026 Federal Schedules, Inc