Transactional Data Reporting (TDR) FAQs

In the near future, many GSA Schedule holders will need to add another acronym to their vocabulary of federal contracting terms, TDR. TDR, which stands for Transactional Data Reporting, started as a pilot program in 2016, and is finally rolling out to all Schedule holders. As of MAS Solicitation Refresh #28, TDR became mandatory for any Schedule holder with a TDR-eligible Special Item Number (SIN).

With Solicitation Refresh #31, GSA is expanding TDR eligibility to all SINs, meaning all remaining non-TDR Schedule holders will be required to transition to TDR. With this important milestone coming up, as well as keeping in mind that many contractors have recently switched over to TDR, I would like to answer some of the FAQs you may be having as you enter the TDR program.

What is Transactional Data Reporting?

TDR is a method of sales reporting and pricing disclosure, designed to replace the previous Commercial Sales Practice method. Under this new method, Schedule holders are no longer required to submit their Commercial Sales Practice (CSP) information, in which they disclosed to GSA the discounting practices they offer to commercial customers. Under the CSP model, contractors were required to ensure that a discount relationship was maintained between GSA discounts and the discounts provided to a Basis of Award customer identified in the Commercial Sales Practices. TDR removes the requirement to provide CSP data, so you are free to discount as desired to commercial customers without fear of disrupting that Basis of Award relationship.

However, in exchange, the contractor is required to report additional information when filing GSA sales reports, and those reports become monthly rather than quarterly.

What is Transactional Data and How Much Additional Reporting Information is Required?

Transactional data consists of the additional elements contractors are required to report in their monthly GSA sales report. Under TDR, contractors report information by order, not just the sum of all sales per SIN. Specifically, the following fields are required, by line item on GSA orders, as applicable:

• Contract or blanket purchase agreement number
• Delivery, task order number, or procurement instrument identifier
• Non-federal entity
• Special item number
• Description of deliverable
• Manufacturer name
• Manufacturer part number
• Unit measure
• Universal product code
• Quantity of item
• Price paid per unit
• Total price

There are also four additional fields, which are currently optional:

• Federal customer
• Order date
• Ship date
• ZIP code shipped to

Isn’t this More Work? What are the Benefits of TDR?

Generally speaking, contractors tend to find that the benefits of reduced compliance risk and increased pricing flexibility for commercial customers outweigh the burden of additional reporting requirements after the initial adjustment period.

For contractors, the benefit is primarily the reduced compliance risk, as contractors are no longer required to track discounts to commercial customers for Price Reductions Clause violations. Triggering the Price Reductions Clause by disrupting the Basis of Award discount relationship would generally result in penalties that included refunding government customers for overpayments and mandatory proportional reductions in GSA price.

Under TDR, this requirement is removed. In addition, under TDR, contractors are technically no longer required to provide pricing support, such as invoices, as part of offers and modifications. However, Contracting Officers do reserve the right to ask for pricing support if necessary to confirm pricing is “fair and reasonable,” and they do often exercise this right.

For GSA, the main benefit is that the transactional data being reported helps the government make better purchasing decisions by providing a wider base of market research from the transactional data, since it shows what rates are actually being charged to government customers, not just what the ceiling GSA rates are. For example, transactional data is incorporated into the Compliance & Pricing Report that is generated when contractors submit a Product File through the FAS Catalog Platform (FCP).

Is My GSA Schedule Currently Eligible for TDR?

The easiest way to check if your Schedule is eligible for TDR is to go to GSA’s Transactional Data Reporting requirements webpage. If your SIN is currently listed in the list of eligible SINs, you are required to opt into TDR, if you have not done so already. If none of your SINs are listed, you will become eligible once Refresh #31 is released.

When Will TDR Become Mandatory?

Solicitation Refresh 31, which will make TDR mandatory for all remaining non-TDR GSA Schedule holders, is currently slated to be released in March or April of 2026. You can keep an eye on the GSA Interact post for this Solicitation Refresh for any updates.

How Do I Transition to TDR?

Current GSA Schedule holders who are eligible for TDR but have not yet opted into TDR should submit a modification through eMod. GSA has provided a checklist of required documents for this mod type in their MAS Modification Guide and step by step instructions for submitting in the eMod help center.

For Schedule holders who are not yet eligible for TDR, once TDR rolls out to the entire MAS program in Refresh #31, GSA has said that you will simply be able to opt into TDR as part of an associated Mass Modification and will not need to submit a separate mod through eMod.

For contractors submitting an offer for a GSA Schedule, if you have a SIN that is currently eligible for TDR, you should ensure that you opt into TDR when prompted in eOffer. If you are not currently eligible for TDR, it is generally recommended to wait until Refresh #31 is released to submit your offer, if possible.

How Do I Report Sales Under TDR?

GSA Schedule holders will continue to report sales through the FAS Sales Reporting Portal. Contractors can continue to enter their sales through a “form entry” method in which they enter transactional data directly into the Sales Reporting Portal. This option is primarily for contractors with relatively few orders and line items on those orders.

For those with more orders or many line items per order, there is a spreadsheet template that you can download through the Sales Reporting Portal, complete with your transactional data, and then upload. GSA maintains instructions for how to complete and upload this file in the FAS SRP GSA User Guide.

I Have Submitted Offer That Isn’t Under TDR: Do I Need to Take Action?

GSA has stated that contractors should withdraw any offers that were not submitted under TDR within 10 business days of publication of Refresh #31 and then resubmit the offer under TDR. If you have any questions regarding what action you should take and how this will affect review of your offer, you should reach out to your assigned Contracting Specialist or Officer before withdrawing.

What Changes Do I Need to Make at My Company to Prepare for TDR?

You should review the TDR template provided by GSA, downloadable from the Sales Reporting Portal. Then, you should try to discern where you can gather the data required for the spreadsheet to start building your reporting process. Many contractors are able to pull some or all of the data directly into the template through reports from their accounting system.

If not, tweaking your accounting system to include as much of the required data elements as possible will save you time in the long run. Contractors should also inform all relevant parties internally that they will no longer be required to track and report price reductions.

When Do I Submit My First Monthly Report After Opting Into TDR?

Contractors will submit one final quarterly report for the quarter during which the contractor officially opted into TDR. Contractors will need to start gathering transactional data with the first month after that quarter. For example, if your Schedule is opted into TDR on March 15^th, you will submit a final quarterly report by April 30^th for the quarter from January through March. Your first monthly report will be for the month of April and must be submitted by May 30^th. The obligation to disclose Commercial Sales Practices and track price reductions will also no longer apply starting April 1^st.

Are There Any Changes to the Industrial Funding Fee (IFF) Remittance?

Contractors are still required to remit the 0.75% Industrial Funding Fee in the FAS Sales Reporting Portal. IFF remittance is still only due quarterly. That being said, you can optionally remit the IFF monthly after reporting the monthly sales, or at any time between the time sales are reported and the quarterly IFF payment deadline. The IFF deadline and whether the fee has been paid for a specific month will be visible in the FAS Sales Reporting Portal.

Help Transitioning to TDR

I hope that this information demystified some of the questions you had regarding Transactional Data Reporting. For many contractors, this will be a time of adjustment as you discover the best practices that work for your company when completing the monthly transactional data reports. If you have any questions that weren’t mentioned or would like to discuss the TDR transition and requirements, you can reach out to Winvale, and we will be happy to discuss how your company can best adjust to Transactional Data Reporting.