The General Services Administration Federal Acquisition Service plans to release GSA Multiple Award Schedule Solicitation Refresh 31 in February 2026. This refresh will bring some of the most meaningful structural updates the MAS program has seen in years. These changes affect solicitation language, compliance requirements, reporting obligations, and several Large Categories and SINs. Once Refresh 31 is issued, GSA will release a Mass Modification. Contractors will have 90 days from the issue date to accept it. Failing to accept a mass mod on time can place a contract out of compliance, which can affect eligibility, sales activity, and future modifications.
One of the most significant shifts in Refresh 31 is the formal integration of federal artificial intelligence policy into the MAS solicitation. GSA will add new language to the General Information section of each Large Category to support compliance with federal AI requirements. This includes alignment with Executive Order 13960 on trustworthy AI, Executive Order 14319, and recent Office of Management and Budget guidance such as M-26-04, M-25-22, and M-25-21. Contractors offering AI-enabled systems or services should expect increased scrutiny on how solutions meet federal trust, risk, and governance standards. GSA is also revising SCP-FSS-001, which governs instructions applicable to all offerors. These revisions will impact how offers and modifications are prepared moving forward.
Another major change is the expansion of Transactional Data Reporting as GSA plans to extend TDR to the remaining Services SINs, adding more than 100 SINs to the program. After Refresh 31, TDR will become mandatory for all SINs under the MAS program. This will eliminate the current divide between TDR and non-TDR contracts and makes transactional reporting a standard requirement.
The Startup Springboard Program will also narrow in scope. Going forward, only offerors who qualify under FASt Lane will be eligible for Startup Springboard. This change signals a stronger emphasis on readiness, documentation, and past performance alignment even for newer businesses.
GSA will update firearms and ammunition language across all Large Categories to clearly exclude foreign replica weapons and inert ordnance from MAS scope. Refresh 31 will also roll in multiple clause and provision updates which will include TDR-related clauses, revisions aligned with the Revolutionary FAR Overhaul, and updates required by Federal Acquisition Circular 2025-06. Subcontracting plan templates will be refreshed to reflect new FAR structures and reporting expectations.
On another note order level materials will also become more structured. One of the most operationally important changes appears in the Complementary SINs Subcategory. GSA will revise Order-Level Materials instructions to remove old subcategory limitations and fully align OLMs with GSAR 538.71 and 538.72. The long-standing flexibility around “open market items” is ending. Contractors will no longer rely on broad discretion to add open market components. Instead, items must meet specific OLM requirements and be supported under the OLM SIN framework.
Because of this shift, GSA strongly recommends that contractors add the OLM SIN when the Mass Modification is released. New awardees will continue to receive OLM through mass modification. Existing contractors without OLM will receive a one-time opportunity to add it. Contractors who ignore this update risk limiting their ability to support task orders that require incidental materials.
There will be targeted changes by large category and SIN: Refresh 31 also includes a wide set of revisions to SIN descriptions, instructions, and templates across multiple categories. For example, in Office Management, GSA is revising Office Supplies subcategory instructions and templates for office products, support services, and related SINs. Printing and additive manufacturing SIN instructions will also change.
In regard to Human Capital, GSA is adding new instructions for separation and retirement services and revising multiple SINs tied to human capital strategy, employee performance, employee relations, talent acquisition, and workforce development.
Professional Services will see updates in Environmental Services, specifically auditing services. Training SINs will receive revised descriptions and instructions for acquisition workforce training programs and professional development services.
Transportation and Logistics will experience several template revisions across aircraft maintenance, package delivery, courier services, ground transportation, and automotive rental and leasing programs.
The Travel category will also change as GSA will revise templates and statements of work for employee relocation, long-term lodging, and travel agency services.
Refresh 31 is not a minor housekeeping update. It introduces new compliance expectations, mandatory transactional reporting across the board, tighter controls on materials, and significant SIN-level revisions. Contractors should begin reviewing their current SIN portfolio, TDR status, and whether they have the OLM SIN. Companies offering AI-enabled services should evaluate internal documentation, risk controls, and disclosures. Contractors in affected categories should prepare for template updates and potential modification requirements.
When the Mass Modification is released, it should be reviewed carefully and accepted promptly. This refresh will reshape how MAS contracts are administered going forward, and proactive preparation will reduce disruption to sales, modifications, and audits. If you manage or support GSA contracts, Refresh 31 is one you cannot afford to skim.
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