Major Updates On the Horizon with TDR Expansion and New AI GSAR Clause
GSA’s MAS Solicitation Refresh #31 is expected to be released very soon and will introduce a significant program change: the expansion of Transactional Data Reporting (TDR) to all MAS contractors. This update will eliminate legacy Commercial Sales Practices and the Price Reduction Clause with it. GSA has also proposed a new Artificial Intelligence (AI) clause that would impose strict requirements on how contractors use and disclose AI in contract performance.
The AI clause implementation has been pushed to Refresh #32, but contractors still have a limited window to provide feedback, with comments due by April 3, 2026. As GSA moves closer to releasing Refresh #31, contractors should prepare for these updates. We expect the Mass Modification deadline to be 60 days instead of the usual 90, so be ready to take action soon.
We are excited to announce our new subsidiary "Winvale EU, GmbH" and new office in Wiesbaden, Germany! This strategic expansion allows Winvale to serve key markets, as both an advisor to European companies that want to sell to the U.S. public sector, and to support U.S. companies that want to sell to European defence markets and NATO. Learn more on our new EU website.
GSA offers a suite of integrated eTools to make the acquisition process more efficient for small businesses. These complimentary eTools, including the GSA eLibrary, the Forecast of Contract Opportunities, and several others will help you expedite market research and more. This session is part of our Small Business First Fridays training series, which delivers targeted educational sessions covering essential core topics. These sessions will provide actionable insights and strategies for vendors, equipping them with the knowledge and tools required to successfully navigate the complexities of the federal procurement landscape.
Are you interested in obtaining a GSA MAS contract but don’t know where to start? Join this informational session to learn more about GSA’s MAS program, its benefits, IT offerings and options in the offer process. By the end of the session, attendees will be ready to begin their journey toward obtaining a MAS contract. Commercial IT products, services, solutions and emerging tech businesses interested in obtaining aGSA MAS contract should register here.
GSA is expanding Transactional Data Reporting (TDR) to all Multiple Award Schedule (MAS) contractors in Solicitation Refresh #31—are you prepared? If you are currently under Commercial Sales Practices (CSP) or new to the GSA Schedules Program overall, you’ll need to start learning about TDR and what it means for your contract. Things will change in the way you report sales, how frequently you submit your sales reports, and how you prepare your GSA Schedule offer.
Please join us for a webinar on the ins and outs of TDR and how it might impact your business.
April is a Reporting Month (and May Be the Last Quarterly GSA Sales Report)
GSA MAS contractors should begin preparing for the following reports due at the end of April:
Subcontracting Reporting: Contractors qualifying as an “other than small business” and that have an Individual Model Subcontracting Plan in place will need to prepare and submit the Individual Subcontract Report (ISR) by April 30th. GSA recently retired the Electronic Subcontracting Reporting System (eSRS) dedicated to federal subcontracting reporting; contractors are now required to submit these reports in SAM.gov.
Sales Reporting: Contractors currently under the Commercial Sales Practices (CSP) method report total sales per Special Item Number (SIN) on a quarterly basis, and the report for the first quarter of 2026 is due by May 15th (extended formally last year from April 30th). Just like any other month, contractors under Transactional Data Reporting (TDR) will need to submit their sales data for March by April 30th using the FAS Sales Report Template. Whether your contract is under CSP or TDR, both reports are completed in the FAS Sales Reporting Portal (SRP).
Looking ahead, GSA plans to make TDR mandatory for all contractors in MAS Solicitation Refresh #31. Contractors who currently report their sales quarterly under CSP will be transitioned to monthly reporting under TDR, so it’s important to begin reviewing the requirements for TDR now.
QUICK TIP
Reviewing and Accepting Mass Mods
With Solicitation Refresh #31 well on its way, it’s important to make sure you know how to review and accept Mass Modifications once they are released. Once Refresh #31 is released, you will have 60 days to accept the Mass Mod in the Mass Mod portal. Before accepting a Mass Mod, it’s important to review the contents to make sure you know what it is you’re accepting. Once the Mod is released and you’ve reviewed the Significant Changes, you’ll need to accept the Mass Mod in the Mass Mod Portal. After logging into the Mass Mod Portal, you’ll be prompted to accept each of the changed terms of the solicitation. Once you’ve finished accepting the Mass Mod, you’ll receive the SF30 via email.
In Refresh #31, you could have as many as three Mass Mods to accept: The Refresh Mod, a “Participate in TDR” Mass Mod, and an OLM Sin Mass Mod. If reviewing and accepting all of these Mods sounds daunting, Winvale can help – we provide personalized guidance throughout the Mass Mod process. Learn more in our blog.
EMERGING BUSINESS OPPORTUNITIES
Request for Information (RFI) for Product Support Business Case Analysis (BCA) for USAF E-7A Aircraft
The United States Air Force E-7A Program Office (AFLCMC/WIW) has released a sources sought under NAICS Codes 541611 (Administrative Management and General Management Consulting Services) and 541330 (Engineering Services) to identify interested parties with the ability to perform a comprehensive Product Support Business Case Analysis (BCA) for the E-7A aircraft fleet. The E-7A will provide critical airborne early warning, surveillance, and battle management capabilities to the United States Air Force, and will need to conduct a comprehensive BCA to ensure optimal fleet readiness and long term affordability. The BCA will analyze the costs, benefits, and risks of different product support strategies for the E-7A aircraft, and its sustainment at both the field level (organizational and intermediate maintenance) and depot level. Interested parties should submit a response by May 11, 2026. Additional information and submission requirements are available under Notice ID AFLCMC_WIW.
R799--VA Occupancy Measurement and Reporting RFI
The Office of Asset Enterprise Management (OAEM) within the Department of Veterans Affairs (VA) has released a sources sought under NAICS Code 541611 (Administrative Management and General Management Consulting Services) to identify qualified parties capable of providing technology-enabled building occupancy and measurement solutions. The VA is seeking industry input from organizations experienced in gathering, measuring, and reporting daily occupancy counts for owned and leased locations for corporate and governmental organizations with more than 50 locations. Additionally, qualified parties should be experienced in designing and maintaining systems of sensors to measure unique occupancy, and installation of discrete and dedicated IT networks for measurement and transmission of occupancy data to avoid use of the government’s secure IT network. Responses are due by May 22, 2026. Additional information and submission requirements are available under Notice ID 36C77626Q0132.
FREQUENTLY ASKED QUESTIONS
Q: What is Transactional Data Reporting (TDR)?
A: TDR is a method of sales reporting and pricing disclosure designed to replace the legacy Commercial Sales Practice (CSP) method. Under TDR, the Price Reduction Clause no longer applies to your Schedule contract. The Price Reduction Clause mandated vendors disclose their commercial discounting practices, and define a “Most Favored Customer,” for the purpose of negotiating a price with the government. In removing this clause from their contract, contractors under TDR have much more flexibility in proposing prices on Schedule. However, there is additional sales reporting requirements associated with TDR.
Q: What are the Changes in Reporting Requirements Under TDR?
A: TDR changes the cadence of reporting from quarterly reporting to a monthly reporting schedule (the Industrial Funding Fee is still required to be remitted quarterly, but can be paid monthly). In addition, there is more information that must be tracked in the sales report. This is designed to provide the government with real-time market data on what agencies are paying for the various products and services sold under the MAS program.
Q: When Will TDR Become Mandatory?
A: We expect TDR to become mandatory for all MAS contractors any day now. When TDR becomes mandatory for all contracts, GSA has forecasted that the transition will occur via a mass modification, much like the regular Solicitation refreshes.
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