Top 12 Compliance Risks that Can Affect Your GSA Schedule

Under the Trump Administration, GSA’s plans to “rightsize” the Multiple Award Schedule (MAS) Program are continuing apace, one of the largest impacts of which has been GSA cancelling non-compliant Schedules or allowing them to expire.

This means that it is now especially important for GSA Schedule contractors to be familiar with the terms and conditions they agreed to with their contract and maintain contract compliance in order to avoid the risk of penalties.

As GSA Schedule consultants, we know meeting compliance standards is the most important step to keeping your GSA Schedule contract in good standing and setting yourself up for success. To accomplish this, let’s learn about 12 common compliance risks for GSA Schedule contractors.

1. Contractor Assessments

As a GSA Schedule contractor, you will at some point be contacted by your Industrial Operations Analyst (IOA) about Contractor Assessments. These assessments can occur annually for some Schedule holders, but all Schedule holders will undergo a more comprehensive End of Term assessment near the fourth year of your five-year contract period.

The End of Term Assessment is especially important, as serious compliance risks uncovered during this assessment may jeopardize the chances of GSA exercising the upcoming option period and extending your Schedule into its next five year period.

These assessments are not audits, but the IOA will examine some of your financial documents to see if the terms and conditions of your contract are being upheld. You should be prepared to discuss some of the topics we cover below with your IOA during the assessment. GSA has published a reference guide to help you with the process.

Especially, though not only, during these Contractor Assessments, GSA has recently been scrutinizing contractors’ physical addresses in SAM.gov to ensure that they do not fall into certain prohibited categories, such as PO Boxes and Virtual Addresses. If your physical address falls into such a category, you will likely need to find an alternative address to use, or you could face penalties such as catalog suspension or contract cancellation.

2. Sales Reporting

As a result of Solicitation Refresh #31, all GSA Schedule holders have transitioned to Transactional Data Reporting (TDR). Contractors are no longer required to disclose their Commercial Sales Practices. In exchange for this benefit, contractors are now required to submit monthly transactional sales data.

All contractors should now report their GSA sales monthly in the Sales Reporting Portal (SRP) with your first reports due August 30^th, 2026 for July sales. You can either use the FAS SRP Excel template or directly enter the reports into the SRP. You should be keeping track of your GSA sales and ensuring your invoices properly mark GSA sales so that you are ready for Contractor Assessments. It is important to ensure that you are able to collect the newly required transactional data elements for your sales reporting, though there is a temporary grace period  through December 31, 2026, to give those new to TDR time to adjust.

3. Trade Agreements Act (TAA) Compliance

End items sold through GSA contracts must meet the standards of the Trade Agreements Act, or TAA. Items from certain countries, including, but not limited to, China, Russia, and India are banned if the final product was wholly manufactured or “substantially transformed” there.

To comply with the TAA, you must make sure your final product was wholly manufactured or “substantially transformed” in the U.S. or one of the designated compliant countries.

Be sure that you have current and accurate information on the Country of Origin (COO) for the products you purchase from your suppliers, as this can help you avoid future headaches.

4. Labor Category Qualifications

Contractors offering services through their GSA Schedule must ensure the minimum qualifications laid out in their contract for the labor category are met, in particular the education and experience requirements.

For example, if a contract specifies that a bachelor’s degree and 3 years of experience is required for a specific labor category, the employee, whether of the contractor or subcontractor, must have a bachelor’s degree and 3 years of experience. Keep in mind that you can specify if you would like education to be substitutable for experience and vice versa.

5. Small Business Subcontracting

GSA Schedule contractors must accurately represent their business size to GSA, which is determined according to their preponderance of work North American Industry Classification System (NAICS) Code. Contractors whose business size changes must submit a modification to re-represent their business size under certain criteria as specified in Federal Acquisition Regulation (FAR) clause 52.219-28. If you are an “other than small” business, you will likely need to submit a small business subcontracting plan and submit regular subcontracting reports as required by the type of plan chosen. Please be aware that these reports are now submitted through SAM.gov, and you should ensure you have access in advance of the next reporting deadline.

6. Scope Compliance

Contractors can normally only provide products and services through their GSA Schedule that have been approved by GSA. If you would like to sell a product or service through GSA, you will need to add it to your Schedule. If this product or service does not fit within any of the Special Item Numbers (SINs) that you currently have on your contract, you are required to submit a modification to add the relevant SIN to your contract.

There is an exception in that you can order products and services not currently under your Schedule through the Order Level Material Special Item Number (SIN OLM). However, there are certain requirements to use this SIN, such as that OLM items must be clearly identified and cannot be the primary purpose of the order.

In addition, contractors can only sell products that they are authorized to sell. While Letter of Supply requirements have changed, contractors should be aware that GSA can still see who manufacturers have authorized to sell their products in the Verified Products Portal, if the manufacturer chooses to participate.

7. Pricing and Discounts

While contractors no longer need to fret over how their commercial pricing affects GSA pricing, they are still bound to offer GSA Schedule customers pricing at or below the price awarded on their GSA Schedule. In particular, contractors should double check whether they have an awarded Quantity/Volume or Prompt Payment discount. These are frequently overlooked and will likely cause pain at your next Contractor Assessment if your team has not been educated on when to apply them.

8. The Minimum Sales Requirement

One of the most important areas of compliance is making sure you are meeting the minimum sales requirement. You are required to sell at least $100,000 within your first 60 months of having a GSA Schedule contract, known as the base period. After that, you need to meet $125,000 in each of the subsequent 60-month option periods.

If you do not meet this sales amount, your contract will not be renewed into the next option period. GSA is cracking down on Schedule holders who have not achieved this sales figure, as maintaining GSA Schedules costs them time, money, and effort, meaning it is not worth it from their perspective to keep contracts that aren’t performing. To help achieve this requirement, you should make sure your company knows how to find government customers and is putting energy into marketing your products and services to government agencies.

9. Keeping Up with Human Resources Forms and Requirements

Another aspect of contract compliance that can often be overlooked is ensuring that you are filing and keeping track of Human Resources related forms and requirements. These forms and requirements include VETS 100, EEO – 1, Affirmative Action Program, Disability Employment, E-Verify, Service Contract Labor Standards, and Davis-Bacon Act depending on the specifics of your contract.

10. Mass Mod Acceptance

GSA expects contractors to be on top of accepting Mass Modifications in the Mass Mod Portal. These Mass Mods generally incorporate changes from the most recent refresh to the MAS Solicitation.

For Solicitation Refresh 32, GSA shortened the time period to accept the Mass Mod from the usual 90 days to only 30 days. There is no guarantee that this will become the norm, but it demonstrates that GSA is committed to ensuring a prompt response from contractors.

Be aware that you should not just sign the Mass Mod but also understand what it is saying, otherwise, you may find yourself out of compliance with changed requirements. Winvale’s newsletter will help keep you up to date with summaries of the changes that each Solicitation refresh and associated Mass Mod contain.

11. FAS Catalog Platform Transition

The process of transitioning Schedule holders from the SIP program and EDI into the FAS Catalog Platform (FCP) is well underway, with most contractors already in FCP. If you are one of the contractors who hasn’t transitioned yet, you will receive notice about a month before your transition date. GSA has laid out deadlines for when contractors must complete verifications of their seller profiles and initiate the baseline process. If you don’t comply with these requirements, GSA may enact penalties, up to and including contract termination.

12. Keeping Information Up to Date

There are several places where contractor information is kept that GSA Schedule holders need to keep up to date:

• Your SAM registration must be kept active, which requires contractors to resubmit it at least annually.
• Your GSA eLibrary and Advantage presence must reflect the current offerings, pricing, and administrative information for your Schedule.
• You must respond to orders in GSA’s PO Portal, or EDI as applicable

Other Contract Compliance Requirements

While these are some of the most common risks for GSA Schedule contractors, there are still others such as the prohibition on the use of Chinese telecommunications and surveillance equipment by contractors under Section 889 of the Federal Acquisition Regulation (FAR). Remember that GSA Terms and Conditions are unique to your GSA Schedule, so you will ultimately need to pay attention to the Terms and Conditions in your own contract, including any discounts, delivery requirements, and qualifications, to maintain compliance.

Since the government landscape is always shifting, new risks and requirements can appear throughout the life of your contract. It is best to stay informed of any changes that could affect your contract compliance, and one of the best ways to do so is to reach out to Winvale, as we will keep you updated on the federal contracting landscape.