If you’re fulfilling MAS orders through Amazon or any other online marketplace, read this now.
The Federal Acquisition Service (FAS) just issued a compliance reminder aimed at MAS contractors using marketplaces to fulfill orders. In most cases, GSA says that setup is inconsistent with your contract, unless you can prove full compliance.
GSA specifically named Amazon in this reminder, but the language covers “similar platforms” broadly, meaning any third-party marketplace you’re using for fulfillment, not just Amazon.
Here’s the core of it. You are still the contractor of record, no matter which platform touches the order. You remain responsible for every order being accepted, processed, fulfilled, shipped, invoiced, reported, and performed according to your MAS contract and GSA’s ordering procedures. That includes Trade Agreements Act compliance, Industrial Funding Fee reporting, product marking, pricing, product scope, invoicing, and supply-chain integrity. In addition, it applies no matter which channel the order came through, including eBuy or GSA Advantage.
If you’re currently using marketplace fulfillment, review your setup now. Non-compliance can mean contract remedies, cancellation, financial liability, repayment of sales, negative CPARS ratings, or suspension and debarment.
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