The General Services Administration (GSA) has revealed that the upcoming Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 – Refresh #31 is anticipated to be issued in March or April 2026. As part of this refresh, notable changes will be introduced, including new requirements for Artificial Intelligence (AI) systems and an expansion of the Transactional Data Reporting (TDR) pilot program. Contractors are encouraged to review the proposed updates closely to prepare for compliance and ensure readiness for these significant updates.
New AI Requirements for Contractors
Reflecting the growing emphasis on AI regulation, Refresh #31 will include terms and conditions specifically addressing AI systems. Contractors offering AI products or services under the MAS program will need to adhere to these new requirements. The changes align with the policy direction outlined in the Office of Management and Budget’s (OMB) Memorandum M-25-22, titled Driving Efficient Acquisition of Artificial Intelligence in Government.
Contractors should take note of the proposed language regarding their obligations, particularly in the draft AI terms found in GSAR 552.239-7001(e). These updates are expected to have a significant impact on compliance measures for those involved in providing AI solutions.
Expansion of Transactional Data Reporting (TDR)
Another major update in Refresh #31 involves the TDR pilot program, which is set to expand to include all Services Special Item Numbers (SINs) under the MAS solicitation. Currently covering a portion of SINs, TDR allows GSA to gather data on the prices paid for products and services. This information is then used to determine whether an offer is fair and reasonable.
Under the changes proposed, TDR will become mandatory for all SINs. This means any new MAS offers submitted following the release of Refresh #31 must adhere to the TDR format. Contractors are advised to prepare for this shift, as it plays a key role in GSA’s efforts to enhance pricing transparency and prevent fraud, waste, and abuse.
Targeted Updates Across Large Categories
In addition to the AI and TDR changes, Refresh #31 will include updates across several MAS Large Categories. These categories include:
- Office Management
- Human Capital
- Information Technology
- Professional Services
- Transportation and Logistics Services
- Travel
These updates may affect contractors operating in these areas, and they are encouraged to evaluate how their contracts and future offers could be impacted.
Important Deadlines and Takeaways
GSA has called on contractors to review the proposed updates and submit feedback before the comment period closes on March 20, 2026. As businesses prepare to comply with these changes, GSA emphasizes the importance of early preparation to ensure a smooth transition.
"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", the agency notes.
Contractors providing AI services are also encouraged to carefully review the draft AI terms and conditions to understand their obligations under the new requirements. GSA advises businesses to be ready to accept the mass modification no later than 60 days after it is issued.
As Refresh #31 approaches, contractors should remain vigilant, assess how these developments may affect their operations, and take proactive steps to ensure compliance with the new terms. By engaging with the proposed updates before the deadline, businesses can better position themselves to navigate the evolving requirements of the MAS program.
