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Highlights
- Transactional data reporting (TDR) will be mandatory for all U.S. General Services Administration (GSA) Multiple Award Schedule (MAS) contractors under Refresh 31, which is anticipated to be released in February 2026.
- The existing Price Reduction Clause (PRC) will be eliminated from GSA MAS contracts.
The U.S. General Services Administration (GSA) Federal Acquisition Service (FAS) in June 2025 announced the expansion of transactional data reporting (TDR) to 62 new product and cloud services Special Item Numbers (SINs) and foreshadowed its intention to expand TDR to all SINs in fiscal year 2026. That time has come, as GSA recently published an advance notice of Refresh 31 for the GSA Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 (Advanced Notice).
The most notable change is that TDR will become mandatory for all GSA MAS contractors. Although the TDR pilot program dates back to 2016 and some MAS contractors may have previously elected to utilize it, Refresh 31 will make TDR mandatory for all MAS contracts. With this shift, the existing Price Reduction Clause (PRC) will be eliminated from MAS contracts, and a new version of the PRC with a different liability structure consistent with TDR will be added.
Currently Pending Non-TDR Offers
For offerors with proposals submitted for, but not awarded, a MAS contract, GSA's Advanced Notice recommends withdrawing any pending non-TDR offers and resubmitting them under the TDR requirements; non-TDR proposals likely will be rejected. This change could understandably cause concern among offerors about delaying their award. However, during a webinar on February 10, 2026, GSA committed to make every effort to reinstate resubmitted offers in the review queue based on their original position at the time of withdrawal. Offerors should note, however, that resubmitting TDR offers promptly will be critical for maintaining contract award queue position.
Existing MAS Contract Holders
For existing MAS contract holders, GSA will issue a separate, system-generated Mass Modification (A909) (TDR Modification) on the same day it issues Refresh 31. The TDR Modification will change non-TDR reporting to TDR monthly reporting. GSA advised contractors to first accept Refresh 31 Mass Modification, which incorporates all updated solicitation terms and conditions, and then accept the TDR Modification. Contractors should thoroughly review both documents for all new terms prior to acceptance to ensure a full understanding of all changes. The GSA urged contractors to accept the modifications as soon as possible and no later than 90 days after issuance.
TDR requirements will become effective at the beginning of the next sales reporting quarter after the TDR Modification is accepted. For example, if the TDR Modification is signed and accepted in February 2026, TDR becomes effective on April 1, 2026. However, if the TDR Modification is not signed until after April 1, 2026, then TDR becomes effective on July 1, 2026. The Advanced Notice states that PRC liability under the existing clause ends on the first day of the next sales reporting quarter following execution of the TDR Modification. Additionally, Commercial Sales Practices (CSP-1) disclosures and Most Favored Customer information will no longer be required. TDR is due within 30 calendar days after the end of the previous month.
TDR was designed to "transform price disclosure and related policies ... in order to improve the value taxpayers receive when purchases are made using" various GSA contracts. For more information about the history of TDR and TDR compliance requirements, see Holland & Knight's previous alert, "GSA Expands Transactional Data Reporting Requirements for MAS Contract Holders," June 12, 2025.
The Bottom Line
Contractors should immediately take steps to comply with TDR requirements. GSA anticipates the release of Refresh 31 and TDR Modification in February 2026 and has requested that contractors accept the modifications as soon as possible.
In anticipation of the TDR Modification, MAS holders must consider related changes to their business development and contract pricing functions, including phasing out application of the existing PRC and incorporating TDR requirements.
There is no indication that the GSA is expanding TDR to Federal Supply Schedule contracts administered by the U.S. Department of Veterans Affairs.
If you have any questions about TDR and TDR compliance requirements, contact the authors.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
