GSA has announced a temporary grace period to help contractors transition into the expanded Transactional Data Reporting (TDR) program.
Contractors Entering TDR Between October 1, 2025 and July 1, 2026
If your GSA Multiple Award Schedule (MAS) contract enters TDR during this timeframe, GSA will provide a Grace Period through December 31, 2026.
During the Grace Period:
• Contractors will not face penalties for reporting errors or noncompliance.
• GSA may issue “soft flags” identifying missing information, discrepancies, or reporting issues.
• Contractors are still required to report all applicable sales.
• The purpose of the Grace Period is to allow contractors time to learn the reporting requirements and correct any issues before enforcement begins.
Beginning January 1, 2027, TDR compliance will be fully enforceable by the Contracting Officer.
Contractors That Do Not Accept Modification A909
Contractors were required to accept Modification A909 by June 30, 2026. Failure to accept the modification may result in contract cancellation at the discretion of the Contracting Officer.
If A909 is accepted after July 1, 2026 and the contract enters TDR later than expected, the Grace Period will still end on December 31, 2026. GSA will not extend the Grace Period because of a delayed modification acceptance. Enforcement of TDR compliance will begin January 1, 2027.
Existing TDR Contractors Prior to October 1, 2025
Contractors already participating in TDR before October 1, 2025 will receive a six-month Trial Period for several newly required reporting fields, including:
• Ship Date
• Order Date
• Ship-To ZIP Code
• Federal Customer Name
• Unique Customer Identifier (UCID)
• Cloud Service Type (for SIN 518210C contractors)
These fields become required beginning July 1, 2026. During the Trial Period:
• Contractors will not be penalized for missing or inaccurate data.
• GSA may issue soft flags for incomplete reporting.
• Contractors should use this time to update internal systems and reporting processes.
After the Trial Period ends, compliance with these fields may be enforced by the Contracting Officer.
Additional Reporting Fields Coming Later
Some new reporting fields are not yet available in the FAS Sales Reporting Portal (SRP). These include:
• Order Type
• Order Discount
• Worksite Information
Once these fields become available in SRP, contractors will receive a separate six-month Trial Period to implement them. After the Trial Period concludes, reporting compliance for these fields will become mandatory and subject to enforcement.
GSA is giving contractors additional time to adjust to expanded TDR reporting requirements. While penalties will not be issued during the Grace and Trial Periods, contractors should use this time wisely to review internal reporting processes, validate data collection methods, and prepare for full compliance by January 1, 2027.
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