The fourth quarter (Q4) of Fiscal Year 2026 (FY2026) begins July 1st and ends September 30th—are you ready? Q4 is most notably the time when federal agencies look to spend their remaining budgets. Increased activity means greater opportunities for GSA Multiple Award Schedule (MAS) contract holders, and it’s important to make sure your contract is fully compliant so you don’t miss out on opportunities as the end of the fiscal year approaches.
In this blog, we’ll review 5 steps to make sure your GSA Schedule is fully compliant as we head into FY2026 Q4.
1. Accept Mass Modification, Refresh #32
GSA released Refresh 32 on June 4th and it is due July 4th, which is only 30 days after the release date compared to the usual 90 days contractors are given to accept mass modifications. If you haven’t done so already, you’ll need to log into the mass modification portal and accept Refresh #32. In addition to specific Large Category changes, this Refresh incorporates several significant Schedule-wide changes, so you should review them all before you accept the mass mod. Your contract will remain non-compliant until Refresh #32 is accepted, and Contracting Officers will not let you take any actions on your contract while it is pending.
The FAS Catalog Platform (FCP) allows contractors to manage their GSA Schedules and contract data in a more streamlined process. FCP is integrated with eMod, which allows contractors to link catalog actions to contract modifications. When submitting modifications in FCP, services and products are auto-published to eLibrary and GSA Advantage respectively, removing the need to update Terms and Conditions files with each awarded modification. Contractors with newly awarded contracts use FCP immediately after contract award.
If your contract is eligible for the FCP (which most contractors should be by now), you’ll need to register your contract with the Vendor Support Center (VSC) so it appears on GSA eBuy. After that, you’ll need to complete your seller profile and submit the baseline catalog modification in eMod. If you offer both products and services, you’ll need to complete the baseline modification for each.
GSA has recently expanded Transactional Data Reporting (TDR) to all MAS contracts, and starting on July 1st all contractors must report their sales monthly. TDR reports are due within 30 days after the end of the reporting period. If you have zero sales for a certain month, you’ll still need to submit a report. If you do have sales to report, the Industrial Funding Fee (IFF) is due 30 days after the end of the quarter. If you do not log into SRP and report zero sales, your contract risks being marked delinquent. If you are new to TDR and want to learn more about how to file your first TDR sales report, check out our recent webinar.
When reporting your monthly sales, it is important to make sure that your data is completely accurate, and your sales reporting must match your approved MAS catalog exactly. Accurate sales data starts with comprehensive internal sales tracking, so it’s important to make sure you have an internal system in place that allows you to easily pull sales data and invoices when needed. Below is the data you’ll need to pull and submit.
Starting on July 1st, the last 4 data fields will also be required for submission if you transitioned to TDR prior to 10/1/2025:
Submitting accurate sales reporting is important because your reported sales determine the IFF. It’s essential that you pay the correct IFF amount each quarter, since overpaying means paying more than required to the government, and underpaying can lead to noncompliance risks.
GSA recently announced a grace period for both new TDR contractors and for seasoned TDR users who are new to the 4 data fields above.
With the federal government spending the rest of their budget in Q4, it’s very important to make sure that your contract’s pricing and terms and conditions are all in compliance with what was awarded to your contract. You cannot add or delete items, or raise prices without an awarded modification, and tariffs are not allowed as an additional surcharge.
If you have products on your contract, ensure that you have the correct shipping/freight charges as they were awarded. As a reminder, FOB Origin means that the contractor charges shipping for an item, while FOB Destination means that shipping is included in the price. Other aspects to keep in mind are making sure that your items are Trade Agreements Act (TAA) compliant, meaning that your items must come from a TAA compliant country.
If you are unsure of the terms and conditions awarded to your contract, it’s a good idea to take a look at the SF-30s of your complete modifications in eMod to know what terms and conditions have been awarded to your contract. If you are selling items not in line with what’s been awarded, your contract is at risk of being noncompliant and being subject to a long line of assessments by GSA.
Lastly, it’s important your team has at least one dedicated person to track upcoming opportunities daily for your GSA Schedule. You can use your Special Item Numbers (SINs) and other relevant criteria to search opportunities in SAM.gov, and monitor GSA eBuy. GSA eBuy will automatically pull Requests for Quotes (RFQs) and Requests for Proposals (RFPs) that match the SINs on your contract, and you may even get a direct request from an agency to respond to a solicitation, so it’s important someone is logging into this system daily during Q4. Your team can also use paid subscriptions to track upcoming opportunities and build a pipeline for Q4 and beyond.
As federal agencies ramp up spending, it’s imperative that you review your GSA Schedule contract and make sure that your contract is fully up to date and compliant. Ensure that you understand the functions of FCP and have a sound internal system in place for TDR. It’s also smart to do a quick pass-through of your awarded terms and conditions to make sure that you’re selling products and/or services in a way that is compliant.
Non-compliant contracts can cause delays and unnecessary disruptions during one of the busiest procurement seasons of the year. If you have questions about your GSA Schedule compliance or need help with any aspect of getting your GSA Schedule into compliance, Winvale is here to help.