What Should GSA Schedule Contractors Do During the TDR Grace Period?

With Transactional Data Reporting (TDR) mandatory for all GSA Multiple Award Schedule contractors and the transition now effective as of July 1, 2026, many companies are preparing to submit sales reports for the first time. While GSA has implemented a grace period through December 31, 2026, contractors should use this time to develop accurate reporting processes and understand what data they are required to submit.

In this guide, we'll explain how TDR reporting works, common reporting mistakes, what data contractors should be tracking today, and how reporting requirements may continue to evolve in future solicitation refreshes.

Brief Recap of Transactional Data Reporting (TDR)

In case you missed out on what TDR is, here’s a brief refresher of the program:

• TDR started as a pilot program in 2015 as a way to replace the legacy Commercial Sales Practices (CSP)
• Contractors must report important details about the items they should through their GSA Schedule contract, such as quantities sold, prices paid, etc.
• Contractors must report their GSA sales monthly under TDR
• The Price Reductions Clause (PRC) is NOT applicable under TDR, and will therefore go away

One analogy we like to use from GSA is thinking of TDR as a detailed receipt from a store versus a monthly invoice with a single number. This detailed receipt gives GSA more information on what is really being bought through the GSA Multiple Award Schedule (MAS) Program. GSA collects this in-depth information and is able to see a better picture of where the demand lies.

What Sales Must Be Reported through TDR?

If you are used to Commercial Sales Practices (CSP), you probably have the general gist of GSA sales, but you will need to learn more about what TDR elements to report on below. But if you are new to sales reporting overall, or you just got your GSA Schedule and aren’t sure where to start, we’ll cover what you need to report on.

All sales under TDR must be GSA Schedule sales only. This includes:

• MAS contract sales (including)
  • Orders placed through GSA Advantage!
  • eBuy awards
  • Direct agency orders against your Schedule
  • Blanket Purchase Agreement (BPA) orders issued under the Schedule

Sales that are NOT under GSA Schedules include:

• Open market sales
• Commercial sales
• State and local sales not placed under the Schedule contract
• Sales through other contract vehicles

What Data Elements Must be Included in My TDR Sales Report?

Right now, contractors NEW to TDR must start reporting on the following elements for each product and/or service you offer through your GSA Schedule MONTHLY:

• Contract/BPA Number
• Order Number/PIID
• Description of Deliverable
• Manufacturer name (applicable for products)
• Manufacturer part number (applicable for products)
• Unit Measure
• Quantity of Item Sold
• SIN Number
• Price Paid per Unit (US$)
• Total Price (US$)
• Non-Federal Entity

If you have already been operating under TDR prior to 10/1/2025, then the following optional data elements you have probably seen by now are mandatory, although GSA is allowing for a trial period through 12/31/2026 for you to work out any issues:

• Ship Date (all product offerings only)
• Order Date (all product offerings only)
• Zip Code Ship To (all product offerings only)
• Federal Customer (all offering types)
• UCID (contractors who do not list the item for click and buy on GSA Advantage (e.g., use the Services Plus File in FCP)
• Cloud Service Type (SIN matches or begins with 518210C only)

Please note that some of these elements are for products only or specific Special Item Numbers (SINs).

It’s important to note that even if you don’t have sales for the month, you must report this in the “Reporting Zero Sales” field on the Form Entry Page in the FAS Sales Reporting Portal (SRP).

Common TDR Reporting Mistakes and How to Avoid Them

Before you begin reporting your sales under TDR for the first time, here are some of the common mistakes contractors make so you can avoid them:

Mistake #1: Reporting the Wrong Sales

If you are new to GSA Schedule sales reporting in general, it’s really important you understand the difference between your GSA sales and commercial sales or sales from other contract vehicles (refer to the graphic above). Have your accounting team have controls in place to separate Purchase Orders and Invoices under GSA sales from other sources of income.

Mistake #2: Using the Wrong Special Item Number (SIN)

Let's say a contractor holds the following SINs:

• SIN 54151S – Information Technology Professional Services
• SIN 518210C – Cloud and Cloud-Related IT Professional Services

The contractor receives a task order from a federal agency for cloud migration support services. The order was awarded under SIN 518210C, but when preparing their TDR report, someone in accounting enters the sale under SIN 54151S because they see "IT services" and assume it's the correct category.

The reported revenue amount is correct, but the SIN is not. Now that you are reporting more than just the sale of each SIN, it’s important you keep each offering straight in your books.

Mistake #3: Missing BPA or Task Order Sales

If you are awarded a Blanket Purchase Agreement (BPA) under your GSA Schedule, it’s important you still treat these as GSA Schedule sales and report accordingly.

For example, if you were awarded a BPA with the Department of Homeland Security (DHA) under your GSA Schedule and over the course of a month, you get:

• One direct Schedule order for $25,000

• Three BPA calls totaling $100,000

If you only report your $25,000 direct Schedule order because that's the transaction you immediately recognize as a GSA Schedule sale, you are missing the other half of the story. Although the BPA is a separate agreement, it was established under your GSA Schedule contract. The BPA calls are still Schedule sales and must be included in TDR reporting.

The BPA calls are mistakenly excluded because the accounting team views them as "BPA revenue" rather than "Schedule revenue."

Mistake #4: Not Knowing What Elements to Report On Or Using Outdated Templates

There will inevitably be a lot going on for the first few months as you adjust to TDR sales. Make sure you know from the list above what elements you need to be reporting on. The additional data elements mentioned above are not something you need to worry about now, but you should definitely start considering them since GSA is making them mandatory for seasoned TDR contractors.

On that note, since TDR reporting often has changes, we suggest you download the latest version of the TDR template before you begin tracking for the month. You can get the latest version in the FAS Sales Reporting Portal under the Reporting tab.

TDR Non-Compliance Grace Periods

As the title of this blog suggests, GSA recently announced a grace period for both contractors new to TDR and seasoned TDR contractors who are new to the additional reporting elements (ship date, order date, etc.) seen above.

For new TDR contractors (contractors transitioning from TDR from 10/1/2025 through 7/1/2026, GSA will allow contractors to make mistakes as they adjust to the new system. This period will go through 12/31/2026. Starting 1/1/2027, Contracting Officers can penalize you for non-compliance. During this period:

• Contractors will not be penalized for non-compliance during this period.
• Contractors may receive “soft flags” identifying reporting discrepancies or non-matches and must ensure all sales are reported.

For contractors who have transitioned to TDR prior to 10/1/2025, you will also have a grace period as you adjust to the new mandatory elements. The same leeway will be in effect as long as they relate to the new elements. This timeline runs through 12/31/2026 as well.

Are You Ready for Your First TDR Sales Report?

The TDR grace period gives contractors an opportunity to learn the reporting process before enforcement begins in 2027, but there’s still a lot to adjust to if you’re not used to this level of reporting. Rather than viewing TDR as another compliance requirement, we suggest you use this period to establish repeatable reporting procedures, improve data accuracy, and make sure your team is well aware of the new requirements. If you want to learn more about filing your first sales report, check out our recent webinar on the topic.

Of course, you don’t have to figure this out on your own either. If you need help managing your GSA Schedule and making that transition to TDR, we are here to help.