Want to win federal contracts and keep them? GSA compliance is non-negotiable. It’s not just about rules – it’s about building trust, maintaining eligibility, and unlocking billions in government spending opportunities.

Here’s what you need to know upfront:

• Stay Registered: Keep your SAM.gov profile updated annually.
• Meet Sales Thresholds: $25,000 in the first 2 years; $100,000 in the first 5 years.
• Pay Fees: A 0.75% Industrial Funding Fee (IFF) on GSA sales is mandatory.
• Report Sales: Quarterly or monthly, depending on your contract type.
• Keep Pricing Transparent: Notify GSA of price changes within 15 days.
• Avoid Penalties: Non-compliance can lead to contract loss or steep fines.

New rules, like the Revolutionary FAR Overhaul (RFO) and Executive Order changes, are reshaping compliance. Contractors must stay proactive to avoid risks like contract termination or financial penalties.

Bottom line: GSA compliance isn’t just a requirement – it’s your ticket to long-term success in federal contracting.

GSA Compliance Requirements

Main Compliance Requirements

Navigating GSA compliance is essential for contractors holding Multiple Award Schedule (MAS) contracts. These requirements extend beyond basic contract duties, touching on nearly all aspects of federal contracting operations.

Registration and Profile Management is a cornerstone of compliance. Contractors must update their SAM.gov profile annually and keep their registration active throughout the contract term. Additionally, a FAS ID is required to access the FAS Sales Reporting Portal, which plays a key role in ongoing compliance efforts.

Another critical area is Sales Performance and Reporting. Contractors are required to meet specific sales thresholds: $100,000 within the first five years and $125,000 for each subsequent five-year period. Tracking sales by special item number (SIN) and paying the industrial funding fee (IFF) through the FAS Sales Reporting Portal are also mandatory.

Here’s how reporting schedules differ by contract type:

Pricing and Contract Updates are equally important. Contractors must notify the contracting officer of any price reductions within 15 days, submit modifications through eMod, and keep pricelists up to date. Each quote should clearly display the GSA contract number.

Timeliness is also vital for Documentation and Data Submission. Contractors must upload electronic contract data to GSA Advantage within 30 days of award and keep their Vendor Support Center profile current.

Compliance also extends to Equal Opportunity and Certification Requirements. This includes adhering to equal opportunity laws and maintaining small business certifications as required. Proper documentation is key for meeting these obligations.

Stephanie Hagan, Training and Communications Manager at Winvale, highlights the complexities of managing MAS contracts:

"Managing your GSA Multiple Award Schedule (MAS) contract is not an easy task. There are many items to keep up with, which require organization, knowledge, and most of all, time."

Fortunately, GSA assigns an industrial operations analyst to assist contractors throughout the contract term.

Recent Rule Changes

Federal contracting is undergoing significant changes, directly impacting GSA compliance. One major initiative is the Revolutionary FAR Overhaul (RFO), which aims to simplify the Federal Acquisition Regulation (FAR). This effort focuses on removing non-statutory rules that have accumulated over time, streamlining the regulation to its core statutory requirements.

Executive Order Changes are also reshaping compliance. For example, on February 18, 2025, GSA issued Class Deviation CD-2025-04 to implement Executive Order 14173, which revoked Executive Order 11246. Supplement 1 of this deviation removed "gender identity" from FAR 22.801 and related clauses in FAR Part 52. Contractors should coordinate with procurement and legal teams to ensure proper clause modifications.

Another impactful development is GSA Program Rightsizing. Federal Acquisition Service Commissioner Josh Gruenbaum emphasizes the agency’s focus on value and fiscal responsibility:

"FAS takes seriously its responsibility to the American taxpayer, and rightsizing the MAS Program is a significant opportunity for us to prioritize value and fiscal responsibility in contracting".

This initiative involves phasing out contracts that fail to meet sales thresholds and addressing non-compliance more rigorously. With MAS Program sales surpassing $51.5 billion in FY 2024, GSA is concentrating on contractors who consistently deliver value.

Gruenbaum further explains:

"By refocusing the program on the items and services the government is actually buying, we can help our industry partners maximize their time and efforts while providing the best pricing possible for these mission-critical needs".

Streamlining Initiatives are also underway, aimed at reducing regulatory burdens in some areas while tightening enforcement in others. Agencies are being directed to simplify their FAR supplements, eliminating rules not grounded in statute or executive orders.

Lastly, Diversity, Equity, and Inclusion (DEI) Changes are creating a shifting landscape. Some DEI requirements are being paused or contested in court, leading to uncertainty for contractors. It’s crucial to seek clear, written guidance from contracting officers to avoid disruptions in contract performance.

These ongoing changes highlight the importance of strong internal processes to manage compliance risks effectively.

Webinar Replay: GSA Is Changing Fast – Is Your Contract Still Compliant?

Core GSA Compliance Areas

Staying on top of core compliance areas is essential for maintaining a strong foothold in federal contracting. From pricing to modifications, every detail must align with GSA standards. These areas require continuous oversight and careful management to ensure your contract remains in good standing.

Pricing Disclosures and Basis of Award

Pricing transparency is non-negotiable under GSA’s Basis of Award (BOA) requirements. Contractors must ensure their pricing disclosures are accurate and consistent with the BOA, which identifies the customer or customer class that serves as the benchmark for GSA pricing. If commercial pricing changes in a way that affects the BOA, it could trigger a price reduction under Clause 552.238-81. Contractors must notify their Procurement Contracting Officer (PCO) within 15 days of such changes.

For contractors participating in Transactional Data Reporting (TDR), the rules differ. TDR eliminates the need for Commercial Sales Practices (CSP) disclosures and BOA tracking, shifting the focus to broader data transparency instead of traditional pricing audits.

Eric Aaserud highlights the importance of accuracy in pricing disclosures:

"To avoid legal issues and penalties, it is essential that Schedule contractors disclose accurate, current, and complete CSP information."

To stay compliant, contractors should adopt these best practices:

• Clearly define discount structures.
• Avoid offering undocumented discounts in commercial sales.
• Document exceptions for sales that are not comparable to GSA transactions.

Regular internal reviews of pricing structures can help contractors stay competitive and audit-ready. These efforts also set the foundation for accurate sales tracking, which is another critical compliance area.

Sales Tracking and Reporting

Accurate sales tracking is just as important as maintaining proper pricing disclosures. As Isabel Sabie, Winvale’s Contract Administrator, explains:

"As a contractor for the General Services Administration (GSA), you know that a key part of contract compliance is regularly reporting your sales and paying the Industrial Funding Fee (IFF)."

The IFF, set at 0.75%, must be paid within 30 days after the end of each quarter. Even if your sales for the quarter equal $0, reporting is still required.

The reporting frequency depends on your contract type:

• Non-TDR Contracts: Submit quarterly sales reports, broken down by Special Item Number (SIN).
• TDR Contracts: Provide monthly reports with detailed line-item data covering 16 elements, offering deeper insights into contract performance.

To avoid overpaying the IFF, contractors must carefully separate GSA sales from non-GSA sales. When processing orders that include both contract items and open market items, clearly mark the open market items to prevent confusion.

With GSA MAS purchases surpassing $41.1 billion in Fiscal Year 2023 and covering over 12 million approved products and services, accurate sales tracking is more critical than ever. As Global Services emphasizes:

"GSA places considerable importance on accurate and comprehensive tracking and reporting of sales."

GSA’s Contractor Assessments ensure compliance with these reporting requirements, making consistent and precise invoicing practices a must.

Contract Modifications and Updates

Keeping your GSA contract up to date is vital for staying compliant and competitive. Contractors must ensure their offerings reflect their current commercial capabilities. The eMod system is the primary tool for submitting contract modifications, and prioritizing modifications based on business needs can help streamline the process. Following GSA’s naming conventions and formatting guidelines is key to avoiding delays.

For Mass Modifications, contractors have 90 days to provide signatures after receipt. Pay close attention to emails from your Administrative Contracting Officer (ACO) and monitor SAM.gov for updates. Once a modification is approved through eMod, update your GSA Advantage! and eLibrary price lists within 30 days to ensure government buyers have access to the most current information.

Compliance with the Trade Agreements Act is another important aspect. All products listed on GSA schedules must come from approved countries. If manufacturing locations or supply chains change, contractors may need to modify their contracts to remain compliant. Regularly reviewing GSA’s Available Offering and Requirements webpage can help you stay informed about changes in documentation and procedures.

Non-Compliance Risks and Penalties

Failing to meet GSA compliance requirements isn’t just a paperwork problem – it can derail your federal contracting ambitions entirely. The penalties for non-compliance range from steep financial losses to outright exclusion from government contracts. For contractors, understanding these risks underscores why compliance is not just a box to check but a necessity for staying competitive in the federal marketplace.

Financial Penalties and Contract Loss

The financial consequences of GSA non-compliance can be staggering, threatening the very survival of a business. For example, in 2020, Oracle settled with GSA for a jaw-dropping $199.5 million due to violations tied to pricing disclosures. Similarly, a 2024 case resulted in over $16 million in damages and $38 million in penalties for issues like sales reporting failures and Trade Agreements Act violations.

Contracts can also be canceled or suspended for failing to meet minimum sales thresholds, such as the $25,000 requirement within the first 24 months. On top of that, if GSA faces extra costs due to vendor-related freight issues or discrepancies, those expenses – and potential penalties – are often passed back to the contractor.

These examples highlight the importance of having strong internal controls to avoid financial pitfalls, as documented in numerous GSA OIG investigations.

GSA OIG Investigations

The GSA Office of Inspector General (OIG) plays a critical role in enforcing compliance. Through audits, inspections, and investigations, the OIG identifies fraud, waste, and mismanagement within GSA programs. The outcomes of these investigations can be severe, ranging from criminal charges to civil settlements and administrative actions that can effectively end a contractor’s ability to work with the federal government.

Contractors are legally obligated to cooperate with OIG investigations, as failing to do so can lead to harsher penalties. Between FY 2018 and FY 2023, the GSA OIG’s budget grew from $65.0 million to $74.6 million, reflecting an increased focus on enforcement. Common triggers for investigations include misrepresentations about labor qualifications, pricing discrepancies, and violations of contract terms. The OIG also collaborates with the Department of Justice to address fraud risks, including antitrust violations, bribery, and false claims.

Contract Termination Scenarios

When non-compliance persists, the consequences can escalate to the termination of your GSA contract. Termination not only cuts off access to the federal marketplace but also leaves a lasting stain on your company’s reputation. As GSA explains:

"The S&D process protects the federal government from fraud, waste and abuse by using a number of tools to avoid doing business with non-responsible contractors."

Criminal activity, major performance failures, or failure to disclose key information can trigger immediate contract termination and possible debarment. Even repeatedly failing to meet the $25,000 annual sales requirement can result in cancellation or suspension.

The fallout from contract termination extends far beyond losing access to GSA opportunities. Termination becomes part of the public record, which can hinder future bids with both government agencies and private companies. Rebuilding from such a setback often requires significant legal and compliance investments, and even then, regaining trust can take years. For many businesses, the financial and reputational damage from GSA contract termination is simply too much to recover from.

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How to Maintain GSA Compliance

Ensuring GSA compliance isn’t a one-and-done task – it’s a continuous commitment. Successful contractors in the federal marketplace treat compliance as an ongoing process woven into their daily operations.

Internal SOPs and Audit Readiness

Clear Standard Operating Procedures (SOPs) are essential for staying compliant. These procedures should outline how to properly classify open market items versus GSA-specific items and assign responsibility for this task. Misclassifying items can lead to pricing and reporting errors, so this step is critical. Your SOPs should also include guidelines for handling quotes and retaining records for Order-Level Materials (OLMs) that exceed the Simplified Acquisition Threshold.

Your accounting system must separate GSA and non-GSA transactions. This ensures accurate reporting of GSA sales and payment of the Industrial Funding Fee (IFF). Regularly review and update your SOPs to address any gaps or changes in GSA requirements. Make sure your sales and contract management teams are following these procedures.

Audit readiness isn’t something you can scramble to achieve at the last minute – it should be built into your daily operations. When you receive an agency’s request for information, conduct an internal pre-audit to identify potential issues before the official audit begins. Organize all required documentation, make backup copies, and get your management team prepared for their roles in the audit process.

To stay ahead, consider advice like that from Baker Tilly, which recommends reviewing contracts at least 12 months before their option expiration date. This allows time to make necessary updates before receiving the option extension notification letter.

Strong internal processes not only keep you compliant but also set the stage for effective team training and thorough documentation.

Training and Documentation

Once you’ve established solid internal controls, continuous team training is the next step. Regular training ensures your team stays up-to-date with GSA requirements and minimizes compliance risks. Since GSA guidelines are subject to frequent updates, training should cover areas like document retention, sales reporting, pricing disclosures, and Trade Agreements Act compliance. Take advantage of GSA’s training resources and webinars. These sessions often include continuous learning points (CLPs), which can count toward contracting certifications and ongoing education requirements. GSA even offers YouTube playlists featuring webinars on topics such as professional services and Multiple Award Schedule training.

Keeping detailed documentation is just as important. Maintain well-organized contract files that include pricing justifications, sales records, and correspondence with GSA. This level of detail will make responding to audits much smoother. During option renewal periods, review your pricing practices and update your disclosures as needed. Test your internal controls to ensure they’re functioning properly, and revise your policies to address any current compliance concerns.

Tools and Expert Support

GSA provides a range of tools to help contractors stay compliant, but many businesses don’t fully utilize them. Start with the GSA Schedule Contractor Compliance Checklist to systematically manage your contract. GSA Interact offers updates on policies and requirements, while webinars and events provide insights into best practices. The Vendor Support Center can assist with maintaining your price list and answer specific contract-related questions. Additionally, GSA eBuy helps you find opportunities aligned with your Special Item Numbers (SINs), ensuring you maximize your contract’s potential while staying compliant.

For small businesses, professional GSA consultants can be a game-changer. Firms like GSA Focus offer full-service support, covering everything from compliance assurance to ongoing contract management. With a 98% success rate, GSA Focus helps businesses navigate the complexities of compliance while focusing on expanding their federal footprint.

Staying updated with GSA changes is crucial. For example, in August 2024, GSA released MAS Solicitation Refresh #22, expanding the Transactional Data Reporting (TDR) program to 67 additional SINs. Contractors affected by this had to revise their reporting systems to stay compliant.

Ultimately, treating GSA compliance as an integral part of your operations – not just an administrative task – sets you up for success. Companies that prioritize compliance, invest in training, and make full use of available resources are better positioned to thrive in the federal marketplace.

Conclusion

Securing GSA compliance sets your business on a path for sustained success in the federal marketplace, offering a solid framework for long-term growth. With GSA Schedule contracts starting at a 5-year base and renewable for up to 20 years, they provide a sense of stability that’s hard to find in today’s unpredictable business landscape.

Winning a GSA contract is more than just a credential – it’s proof that your business meets stringent standards, unlocking opportunities across the federal contracting ecosystem.

The financial potential is equally noteworthy. By meeting the minimum sales thresholds – $100,000 in the first five years and $125,000 for each subsequent five-year period – your business can tap into consistent revenue streams year after year.

For many successful contractors, compliance isn’t just about meeting requirements – it’s a strategic advantage. As Douglas Allen puts it:

"A strong ethical culture builds trust, enhances reputation, and lays the foundation for long-term success".

This perspective shifts compliance from being a mere obligation to a powerful driver of growth and credibility.

Partnering with experienced professionals can make all the difference. GSA Focus, for example, boasts a 98% success rate, enabling businesses to focus on delivering exceptional value to federal clients while navigating compliance with confidence.

FAQs

What happens if a business fails to meet GSA compliance requirements?

Failing to adhere to GSA compliance requirements can bring about serious setbacks for businesses. These can range from hefty financial penalties and the termination of existing contracts to being barred from pursuing future federal contracting opportunities. Beyond the financial and operational impact, non-compliance can tarnish a company’s reputation, making it much harder to win new contracts.

Issues like inconsistent pricing, inaccurate reporting, or neglecting to update contract modifications can quickly draw the attention of the GSA Office of Inspector General (OIG). Such audits or investigations often lead to significant disruptions in daily operations and can jeopardize long-term growth opportunities. Ensuring compliance isn’t just a regulatory box to check – it’s a crucial step for minimizing risks and staying competitive in the federal contracting space.

How do recent changes like the FAR Overhaul and new Executive Orders impact GSA compliance for federal contractors?

Recent Updates in GSA Compliance for Federal Contractors

Big changes are underway for federal contractors, thanks to the FAR Overhaul and two new Executive Orders – 14240 and 14275. These updates are shaking up the landscape of GSA compliance, aiming to simplify processes and reduce unnecessary red tape.

The FAR Overhaul: Cutting Through the Noise

The FAR Overhaul is all about trimming the fat from procurement rules. By removing outdated requirements, it’s designed to lighten administrative loads and make federal contracting more efficient. The goal? To streamline operations, encourage healthy competition, and ultimately ensure taxpayers see better value for their money.

Executive Orders 14240 and 14275: A Unified Approach

Meanwhile, the new Executive Orders are shifting focus toward a more unified federal procurement system. By consolidating efforts across agencies, they aim to cut down on duplication and waste. For contractors, this means clearer compliance guidelines and fewer headaches navigating complex regulations.

Together, these updates are paving the way for a simpler, more efficient compliance process – one that reduces risks and makes life easier for contractors navigating federal contracts.

What are the best strategies for maintaining long-term GSA compliance?

To stay compliant with GSA requirements over the long haul, contractors need to prioritize a few essential strategies. First, make sure all registrations, such as SAM.gov, are always up-to-date and renewed annually. Missing renewal deadlines can disrupt your eligibility, so staying on top of this is crucial.

Next, establish clear internal procedures for handling compliance-related tasks. This includes creating standard operating procedures (SOPs) for pricing disclosures, tracking sales, and updating contracts on time. Regular training sessions for your team can ensure everyone understands their responsibilities and stays aligned with compliance standards.

Another key step is conducting regular internal audits. These audits help uncover any potential issues early, giving you a chance to address them before they turn into bigger problems. Alongside this, maintaining well-organized records and keeping all documentation current will make GSA audits less stressful and help minimize the risk of penalties.

By taking these proactive measures, you’re not just meeting compliance requirements – you’re also reinforcing your reputation and credibility in the federal contracting space.

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