GSA has officially moved the release of Refresh 31 to March/April 2026. This delay is intended to ensure that all technical updates and policy shifts are fully and appropriately integrated into the system before the official release. For contractors, this provides a brief window to audit current catalogs and prepare for a significant shift in reporting requirements.
Another contributing factor is the ongoing modernization of federal acquisition systems and reporting frameworks. Updates affecting pricing transparency initiatives, reporting practices, and administrative processes require coordination across several procurement platforms. By delaying Refresh 31, GSA can ensure these changes are properly integrated and clearly communicated before contractors are required to adopt them.
For contractors, the rescheduling provides additional time to evaluate potential changes and prepare internal processes for the next MAS update.
Key Changes Expected in the Draft Refresh 31
GSA has officially moved the release of Refresh 31 to March/April 2026. This delay is designed to ensure that all technical updates and policy shifts are fully and appropriately integrated into the system ahead of the official release. For contractors, this provides a brief window to audit current catalogs and prepare for a significant shift in reporting requirements.
OUT-OF-SCOPE ITEMS – Newly Added
One of the most operationally significant changes in Refresh 31 is the expanded list of items now explicitly ineligible under MAS. This is not a minor clarification; it’s a deliberate effort by GSA to eliminate scope creep and bring offerings back in line with SIN intent. Contractors should cross-reference this list against their active catalog before Refresh 31 goes live.
The table below summarizes what’s excluded and where narrow exceptions still apply.
| Excluded Item | Exception |
|---|---|
| Live animals (lab research/testing) | None |
| Food, candy, and beverages | Non-perishable food under SIN 311423 remains allowable |
| Remanufactured items | Toner cartridges only |
| Automotive parts | None |
| Personal hygiene items | None |
| Fully assembled fixed-wing aircraft | None |
| Children’s toys, dolls, and games | None |
| Promotional products | None |
| Sporting goods | None |
| Musical instruments | None |
| Swimming pool equipment and supplies | None |
| Customizable awards, medals, and ribbons | None |
| General clothing items | Workwear (SIN 3152), Uniforms (SIN 315210), and Protective apparel (SIN 339113PA) permitted |
| Books and publications | Technical publications under SIN 511120 remain allowable |
If any products in your current Schedule catalog appear in the “Excluded” column above without a matching exception, they will need to be removed prior to or immediately upon acceptance of the Refresh 31 contract modifications. Leaving ineligible items on your Schedule creates compliance exposure during audits and order reviews.
SIN 339940OS4 – OFFICE PRODUCTS CHANGES
The Office Products SIN is seeing the most structural change of any single SIN in this refresh. The overhaul is intentional: GSA has signaled clearly that this SIN drifted from its original purpose and is being reset to focus exclusively on traditional office consumables. For contractors relying on this SIN for broader supply categories, the implications are significant. Here’s what’s changing.
| Area | Previous Rule | What Changes with Refresh 31 |
|---|---|---|
| Catalog scope | Vendors were required to offer their entire catalog | Vendors may now list only selected products |
| 80/20 rule | Compliance language required | Eliminated entirely |
| Remanufactured products | Ambiguous | Only toner cartridges permitted; all others prohibited |
| Product definition | Broad, with gray areas | Narrowed to traditional office consumables (pens, paper, basic desk supplies) |
| Excluded categories | Unclear | Explicitly excludes furniture, IT products, restroom products, and breakroom supplies |
Contractors currently listing products that fall outside the narrowed definition – breakroom supplies, IT accessories, furniture, or restroom products – should plan to migrate those offerings to the appropriate SIN or remove them entirely. Waiting until after the Refresh 31 acceptance to audit this creates unnecessary timeline pressure.
GSA Recommendation: If you have a non-TDR offer not yet submitted, transition your data to the Transactional Data Reporting (TDR) format now. All new offers submitted after Refresh 31 goes live must follow TDR format. Acting early prevents submission delays.
What MAS Contractors Should Do Now
Even though Refresh 31 has been rescheduled, MAS contractors should treat the delay as preparation time rather than a reason to postpone planning.
1. Audit Your Catalog Against the New Exclusions List
Cross-reference every product in your active Schedule offering against the expanded out-of-scope categories. Any item that falls under an excluded category and lacks a qualifying exception must be flagged for removal before Refresh 31 acceptance.
2. Begin Your TDR Transition Now
If your current offer is non-TDR and hasn’t been submitted yet, begin restructuring your data to the Transactional Data Reporting format immediately. All new offers submitted after Refresh 31 is released must comply with TDR, and this transition takes meaningful lead time.
3. Proactive Impact Assessment
Contract managers and compliance teams should review draft refresh materials as soon as they become available. Early review allows organizations to evaluate potential impacts on pricing structures, reporting obligations, and internal contract management processes.
4. Strategic Monitoring and Timeline Tracking
Monitor official GSA communications for the confirmed release date and acceptance deadlines. Once a refresh is issued, contractors must formally accept updated contract terms within a specified period to remain active and compliant.
5. Comprehensive Internal Compliance Auditing
Conduct an internal MAS compliance review to ensure that reporting practices, contract documentation, and pricing structures align with upcoming policy changes, particularly for organizations managing multiple Schedule contracts simultaneously.
6. Brief Your Internal Teams
Circulate a clear internal summary of Refresh 31 changes to your sales, pricing, and catalog management teams. Changes affecting product eligibility, reporting format, and catalog scope have operational implications well beyond the contracting function alone.
Also Read: Upcoming GSA MAS Refresh 31 – What Contractors Should Expect
FAQ – GSA MAS Refresh 31
Q: What is GSA MAS Refresh 31?
GSA MAS Refresh 31 is an upcoming update to the Multiple Award Schedule (MAS) program that modifies contract terms, reporting requirements, and product eligibility rules across Schedule contracts. Key changes include an expanded out-of-scope items list, a structural overhaul of the Office Products SIN (339940OS4), and a mandatory shift to Transactional Data Reporting (TDR) for all new offers submitted after the refresh is released. GSA has scheduled the release for March/April 2026.
Q: When will GSA MAS Refresh 31 be released?
GSA has rescheduled MAS Refresh 31 for release in March or April 2026. The original timeline was pushed back to allow for the integration of additional policy updates, including pricing transparency initiatives and changes to federal acquisition reporting frameworks, ensuring all changes are fully coordinated across procurement platforms before contractors are required to adopt them.
Q: What products are being removed from the GSA Multiple Award Schedule under Refresh 31?
Refresh 31 significantly expands the list of items ineligible under MAS. Newly excluded categories include live laboratory animals, food and beverages, remanufactured items (except toner cartridges), automotive parts, personal hygiene items, children’s toys, sporting goods, musical instruments, swimming pool equipment, promotional products, general clothing, and books. Narrow exceptions exist, for example, non-perishable food under SIN 311423 and technical publications under SIN 511120 remain allowable.
Q: What is changing for SIN 339940OS4 Office Products under Refresh 31?
SIN 339940OS4 is undergoing a major structural reset. The requirement to offer an entire catalog is being removed, allowing vendors to list only selected products. The 80/20 compliance rule is being eliminated. The SIN’s scope is narrowing to traditional office consumables, pens, paper, and basic desk supplies, and explicitly excluding furniture, IT products, restroom supplies, and breakroom items. Only toner cartridges remain permitted as remanufactured products under this SIN.
Q: What is Transactional Data Reporting (TDR) and why does it matter for Refresh 31?
Transactional Data Reporting (TDR) is a GSA reporting format that requires contractors to submit detailed data on individual sales transactions, including price, quantity, and buyer information, rather than relying on traditional pricing disclosures. Starting with Refresh 31, all new MAS offers must be submitted in TDR format. Contractors currently preparing a non-TDR offer are strongly advised by GSA to transition to TDR before the refresh is released to avoid delays in their submission.
Q: Are MAS contractors required to accept Refresh 31?
Yes. MAS contractors must formally review and accept each refresh update to keep their Schedule contracts active and compliant. Once Refresh 31 is released, GSA will issue contract modifications that contractors must accept within a specified timeframe. Failure to accept an applicable refresh modification can result in compliance issues and may affect a contractor’s ability to receive orders through their Schedule contract.
Staying Ahead of MAS Refresh 31
MAS Refresh 31 is shaping up to be one of the more operationally consequential schedule updates in recent years. The rescheduling to March/April 2026 is not a reason to wait; it is a window to act. Contractors who use this period to audit catalog eligibility, initiate the TDR transition, and align internal teams with incoming changes will be far better positioned to accept the refresh without disruption. Those who treat the delay as downtime risk compressing weeks of necessary preparation into days of reactive scrambling.
At iQuasar, our GSA MAS Schedule Services team helps contractors navigate refresh updates from start to finish, including catalog compliance reviews against the new out-of-scope exclusions, SIN 339940OS4 eligibility assessments, TDR format transitions, and contract modification management. Whether you’re evaluating how Refresh 31 affects your current offerings or need hands-on support preparing your submission under the new TDR requirements, we’re ready to help. Contact us today to speak with a member of our GSA team.
