On June 26, 2025, the General Services Administration (GSA) released MAS Refresh #27—the latest GSA Multiple Award Schedule (MAS) solicitation update and mass modification. Among other changes, Refresh #27 significantly expands the use of Transactional Data Reporting (TDR), making it mandatory for contracts containing one of the 177 TDR-eligible Special Item Numbers (SINs). Further, GSA intends to make TDR mandatory for all MAS contracts in an upcoming refresh anticipated in Fiscal Year (FY) 2026. This move marks a major expansion of GSA’s data-driven procurement approach and will require contractors to adapt quickly. If you hold an MAS contract and have not yet opted into TDR, now is the time to prepare for new compliance obligations and evaluate how TDR will affect your reporting, pricing, and business strategy.
Mandatory Transactional Data Reporting
The most significant change introduced by this refresh is the phased implementation of mandatory TDR. Refresh #27 expands the use of TDR to 62 new product and cloud service SINs and changes the TDR program from optional to mandatory, so that 177 SINs now require TDR. Existing contract holders with these SINs must accept the mass modification and opt into TDR by September 30, 2025. In a future FY 2026 refresh, GSA will extend TDR to all remaining SINs, thus making TDR participation mandatory for all MAS contracts.
TDR implementation will reduce the administrative burden and improve procurement transparency for both the government and contractors. TDR requires contractors to electronically report detailed line-item sales data through GSA’s Sales Reporting Portal. This includes 16 transactional data elements (12 required; 4 remain optional) such as the price paid, quantity, and federal customer (commercial sales outside of the MAS program do not need to be reported). This data provides the government with market intelligence to make smarter acquisitions and achieve taxpayer savings. TDR allows GSA to more easily determine the items and services agencies are purchasing and the prices they are paying.
The major benefit to contractors of using TDR is that they will no longer have to provide Commercial Sales Practices (CSP) disclosures, comply with Most Favored Customer and Basis of Award (BOA) price/discount relationship limitations, or track and report price reduction violations. TDR is estimated to cut annual reporting costs by more than $3,000 and 22 labor hours per contract.
With Refresh 27, participation in TDR will be mandatory for any MAS contract that includes one or more of the 177 TDR-eligible SINs. Contractors that have not yet opted into the TDR program will be expected to opt in no later than September 30, 2025, by submitting a “Participate in TDR” modification. The effective date and requirement to report TDR data will be set to align with the first day of the next applicable sales quarter. Contractors will be required to report data monthly. The contract will require TDR for the life of the contract, including any option periods.
Other Key Changes Applicable to All MAS Contract Holders
Refresh #27 also makes several other important changes to MAS contracts.
Implementation of Executive Orders (EOs): The refresh includes provisions aligning MAS contracts with recent EOs. For a detailed summary of relevant EOs, refer to PilieroMazza’s Executive Order Resource Center.
Expansion of Out of Scope Items: GSA added eight categories of products to its list of items considered out of scope for MAS contracts. These include children’s toys, dolls, and games; promotional products; sporting goods; musical instruments; and customizable awards, medals, and ribbons.
Retirement of Certain SINs: GSA retired ten SINs across several categories—five under Furniture and Furnishings, three under Miscellaneous, and one each under Office Management and Facilities. According to GSA, the products associated with these SINs are available through alternative procurement channels.
Revised Letter of Supply Requirements: Going forward, Letters of Supply from Original Equipment Manufacturers will only be required for Information Technology (Category F) and Printing and Photographic Equipment (Subcategory A10). Other categories are exempt, though offerors under Office Management Maintenance and Repair (Subcategory A05) must still provide proof of authorization to perform services on applicable brands.
Resubmission Waiting Period Extended: If an MAS contract is cancelled or allowed to expire due to low sales or non-compliance with other contract terms, the contractor now must wait 24 months (extended from the previous 12-month waiting period) before submitting an offer for a new contract.
Incorporation of Wage Determinations (WD): The refresh incorporates the updated Service Contract Labor Standards WD index. GSA is not changing any clauses or policies, but reminds offerors to ensure pricing and WD numbers are updated and included in their Service Contract Act matrix.
Takeaways
- TDR is mandatory but welcome: TDR is now mandatory for all product SINs and cloud SIN 518210C, and all MAS contracts will be subject to TDR in the near future. TDR will remove the administrative burdens and liability associated with the Price Reduction Clause, potentially making the MAS program more attractive to commercial businesses. However, contractors need to ensure they have systems capable of accurately capturing and reporting the line-item sales data required by TDR.
- Don’t forget to accept and submit your TDR mod: GSA MAS contract holders must accept the modification no later than 90 days after the modification is issued. Affected contractors that have not yet opted into the TDR program must opt in by September 30, 2025.
- Upcoming GSA webinar: On July 17, 2025, at 11 am EST, GSA is hosting an MAS Office Hours session on how TDR works for participants new to the process. You may register to join here.
Attorneys in PilieroMazza’s GSA Federal Supply Schedules Group are able to assist you in preparing for these new compliance requirements. If you have questions, please contact Jackie Unger, Krissy Crallé, or another member of our GSA Federal Supply Schedules Group.
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If you’re seeking practical insights to gain a competitive edge by understanding the government’s compliance requirements, tune into PilieroMazza’s podcasts: GovCon Live!, Clocking in with PilieroMazza, and Ex Rel. Radio.
