The General Services Administration (GSA) announced back in January that Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 – Refresh # 31 is expected to be issued in March/April 2026. Refresh #31 will introduce significant changes, including new Artificial Intelligence (AI) requirements alongside the expansion of the Transactional Data Reporting (TDR) pilot program. Government contractors should review the proposed updates (summarized below) and submit comments to GSA on Refresh #31 by March 20, 2026, to stay ahead of compliance obligations and prepare for future offers, new AI requirements, and the expanded TDR program.
Proposed Changes
In an unsurprising change, further demonstrating the growing trend of AI regulation, GSA plans to incorporate terms and conditions for AI systems into the MAS solicitation. Due to this change, contractors offering AI products or services under MAS will be required to comply with these requirements, which implement policy direction from OMB Memorandum M-25-22: Driving Efficient Acquisition of Artificial Intelligence in Government.
Additionally, the TDR pilot program is expected to expand. TDR is a method for GSA to collect a wide variety of data points about the prices paid for products and services to determine whether an offer is fair and reasonable. As such, GSA intends to expand TDR to remaining Services Special Item Numbers (SINs) (112 in total) and make TDR mandatory for all SINs under the MAS solicitation. Therefore, all new MAS offers submitted after Refresh #31 will likely have to follow the TDR format.
Category Updates
Refresh #31 also includes targeted updates across multiple MAS Large Categories, including:
- Office Management
- Human Capital
- Information Technology
- Professional Services
- Transportation and Logistics Services
- Travel
Key Takeaways
MAS contractors should monitor the release of Refresh #31 and evaluate how the changes may affect their contracts and future offers. In particular:
- Contractors offering AI solutions should review the draft AI terms found here. Particularly on the proposed language regarding contractor obligations found at GSAR 552.239-7001(e), as that will have a significant impact on compliance measures.
- Given the expansion of the TDR program, companies should begin preparing for mandatory TDR, as it provides GSA with more data on making “fair and reasonable” pricing determinations, which is especially vital with the government’s focus on rooting out fraud, waste, and abuse.
- While GSA will continue to provide additional details as it determines a defined release date for Refresh #31, businesses should be ready to accept the mass modification no later than 60 days after the modification is issued.
As GSA moves toward issuing Refresh #31, contractors should review the proposed updates and assess how the changes may affect their compliance obligations and future offers, particularly where early preparation can ensure a smoother transition related to AI requirements and the expansion of TDR. Contractors should also provide feedback to maspmo@gsa.gov before the March 20, 2026, deadline.
If you have questions regarding Refresh #31, please contact Cy Alba, Adel Mansour, or another member of PilieroMazza’s Government Contracts practice group.
