Updated June 2026 for Refresh 32: GSA issued Refresh 32 (Mass Mod A917) in June 2026, building on Refresh 31 with new FAR 52.222-90 DEI compliance requirements, EOS product rules, and a 30-day acceptance window. See our Refresh 32 action guide for the latest contractor requirements.
Most GSA contractors missed this. GSA MAS Refresh 31 was not a routine update. It was a signal.
GSA is raising the standard across the Multiple Award Schedule program — and many contractors are not keeping up. If you are on a GSA Schedule or planning to get on one, here is what actually changed and why it matters.
1. TDR Expansion Changes the Game
More contractors can now opt into Transactional Data Reporting (TDR) instead of submitting a Commercial Sales Practices (CSP) disclosure.
Sounds like a win. But here is the tradeoff: by opting into TDR, you take on the responsibility of monthly reporting, accurate transactional data, and consistent submissions every single month.
If your back office is not set up for that level of discipline, TDR becomes a liability, not a benefit. It is a system that rewards contractors with strong internal processes and quietly punishes those who are not organized.
2. Sales Reporting Is Now Being Enforced
GSA is paying attention to reporting in a way it has not before. Late or inaccurate Industrial Funding Fee (IFF) reporting can now trigger:
- Contract compliance flags
- Increased audit risk
- In serious cases, contract termination
A lot of contractors are still treating quarterly sales reporting like an afterthought. That is a mistake. Refresh 31 signals that GSA is tightening its oversight posture, and reporting is one of the first places they look.
3. Your Pricing Documents Must Match Exactly
Your Commercial Pricelist must match your awarded contract pricing, align with your SIN structure, and stay consistent across every document that references your rates.
If it does not match, it will get flagged. This becomes a problem during modifications, option year renewals, and audits. Many contractors have not reviewed their pricelist since the day they were awarded. That disconnect is a real vulnerability.
4. SIN Alignment Is Under the Microscope
If your services do not clearly and specifically fit your awarded SIN, you are exposed. Refresh 31 put SIN alignment under greater scrutiny, especially for contractors whose offerings have evolved since original award.
This issue surfaces most during:
- Contract modifications
- Audits and contractor assessments
- Attempts to expand into new SINs
If your scope has drifted from your original award, now is the time to realign — not when a contracting officer is already asking questions.
5. Catalog and Pricing Must Stay in Sync
Your pricing on GSA Advantage must match your awarded contract rates. It sounds obvious, but most contractors have not done a full pricing audit in months. Some have not touched it since award.
That gap — between what is on your contract and what is in your catalog — is exactly where compliance problems start. Refresh 31 makes this a higher-priority issue because GSA buyers compare these records directly.
The Reality Most People Will Not Say
Getting on a GSA Schedule is not the hard part anymore. Staying compliant is.
Right now there are two types of GSA contractors:
- Those who actively manage their contract and stay ahead of changes like Refresh 31
- Those who treat their contract as a set-and-forget asset and slowly fall out of compliance
There is no middle ground. A GSA Schedule that is out of alignment is not just a paperwork problem. It is a contract risk.
What to Do Now
If you have not reviewed your contract since Refresh 31 dropped, start with these five areas:
- Review your TDR eligibility and decide whether to opt in
- Audit your IFF reporting history for late or missing submissions
- Compare your Commercial Pricelist to your awarded contract rates line by line
- Confirm your active SINs match the services you are currently delivering
- Check your GSA Advantage catalog pricing against your contract
If any of those feel uncertain, that uncertainty is your answer.
We Can Help
At GO GSA, we help contractors identify compliance gaps before they become contract problems. Whether you need a full contract audit, help with reporting, or guidance on navigating Refresh 31 requirements, reach out directly — we will take a look at your contract and tell you exactly where you stand.