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GSA Refresh 31 Major Changes Ahead

GSA has delayed Release 31 of the Multiple Award Schedule updates. Instead of releasing it earlier, the agency now plans to issue Refresh 31 around March or April 2026. It is explained that this delay will allow GSA to fully finalize the changes before contractors must follow them.

GSA already shared a draft version of updated proposal instructions on January 28, 2026. Minor edits and new Information Technology updates were added on February 19, 2026. The guidance discussed regarding Transactional Data Reporting, known as TDR, has not changed. The most important takeaway is that any company preparing a new GSA MAS offer should start preparing under the TDR format now. After Refresh 31 becomes effective, all new MAS offers will be required to use TDR. Companies that still use the old reporting method should begin transitioning immediately to avoid delays when submitting an offer.

Once Refresh 31 is officially released, GSA will issue a Mass Modification to all current schedule holders. Contractors will have 90 days to accept the modification and comply with the new rules. There will be several major program changes that are coming:

  • GSA will introduce governmentwide terms and conditions for Artificial Intelligence systems and services. Any contractor offering AI tools or AI enabled services must follow federal AI acquisition rules established by the Office of Management and Budget.
  • Transactional Data Reporting will expand significantly. TDR will move beyond a pilot program and become mandatory across the entire Multiple Award Schedule, covering more than one hundred additional services SINs. This change replaces traditional pricing disclosures and requires contractors to report actual sales transaction data.
  • The Startup Springboard Program will also change. Only companies that qualify under the FASt Lane program will be eligible going forward.
  • GSA is clarifying weapons restrictions within the schedule program. Foreign replica weapons and inert ordnance will now be clearly excluded from MAS eligibility.
  • Contract clauses and templates will be updated to align with recent Federal Acquisition Circular updates and the ongoing FAR modernization effort. Subcontracting plan templates will also change to match new FAR overhaul requirements.

Another major change affects Order Level Materials, called the OLM SIN. In the past, contractors could sometimes add open market items with broad flexibility. Under Refresh 31, that flexibility will end. Contractors must use the OLM SIN if they want to include non-schedule items on task orders. GSA strongly recommends contractors accept the Mass Modification adding the OLM SIN if it is not already on their contract. Existing contractors will receive a one-time opportunity to add it automatically.

Beyond these overall policy updates, GSA is revising instructions, templates, and descriptions across many Large Categories. These include Office Management, Human Capital, Information Technology, Professional Services, Transportation and Logistics, Travel, and several others. Most of these revisions clarify proposal requirements, update templates, or refine service descriptions rather than create entirely new programs.

In simple terms, Refresh 31 focuses on modernization. GSA is standardizing reporting through TDR, tightening compliance requirements, adding AI governance rules, updating proposal instructions, and restructuring how open market items are handled under MAS contracts. More details will be released once GSA announces the final publication date. Contractors should begin preparing now, especially by transitioning to TDR and reviewing whether the OLM SIN should be added to their schedule.

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