GSA anticipates issuing MAS Refresh 31 in February 2026. The draft changes are shared for industry awareness and comment, but they signal a broad shift toward universal Transactional Data Reporting (TDR), enhanced AI governance, tighter IT-focused pathways, and clearer contract language across the MAS program.
Changes Applying to the Entire MAS Solicitation
1. New Artificial Intelligence (AI) Compliance Language (All Categories)
AI governance becomes a mandatory element within every Category Attachment’s General Information section, aligning MAS contracts with federal AI directives and guidance. This means contractors offering AI systems or AI-enabled services will be expected to meet governance, transparency, and risk-management expectations defined by federal policy.
GSA references Executive Order 13960 on Trustworthy AI in Government, Executive Order 14319 on preventing “Woke AI” in Federal Government, and applicable OMB guidance. Practically, this change signals a baseline expectation that AI-enabled products and services exposed to government operations will be subject to standardized governance, disclosure, and risk controls. This is less a single requirement than an ecosystem shift. For vendors, it’s an invitation to map AI governance into contracts, covering data provenance, model risk management, transparency about AI capabilities, and ongoing monitoring. It also supports agencies’ broader aim of responsible AI deployment.
Key takeaway: If your offerings include AI components, prepare to demonstrate governance, transparency, and risk-management practices that align with federal expectations.
2. Major Revision to SCP-FSS-001 (Instructions to All Offerors)
SCP-FSS-001 will be revised to streamline instructions and reflect mandatory TDR for all MAS SINs, in addition to updates in pricing requirements to align with the new TDR model. Legacy CSP-based pricing concepts are being phased out as part of the modernization effort.
The revision aims to simplify the submission process while tightening how price data and reporting align with TDR requirements. This is part of the broader move to unify data reporting across the MAS ecosystem. For bidders, the change means rethinking how offers are structured and priced. It emphasizes clarity and consistency in pricing disclosures and the underlying data that supports them.
Key takeaway: Expect simpler offer instructions that demand full alignment with TDR-driven pricing and data practices.
3. Transactional Data Reporting (TDR) – FULL EXPANSION (Very Significant Change)
i. TDR Becomes Mandatory for ALL MAS SINs
Beginning with Refresh 31, every SIN under MAS will require TDR, and all non-TDR and CSP-1 references will be removed from the solicitation. This represents one of the most consequential MAS changes in years.
The move to universal TDR eliminates divergent data-reporting paths and pushes for standardized transactional data across all MAS offerings. It will affect how proposals are prepared, priced, and subsequently reported.
ii. What Happens to Non-TDR Offers?
New non-TDR offers should be withdrawn and resubmitted as TDR. If not withdrawn, GSA will reject the offer.
This creates a strict path for bidders who must resubmit non-TDR proposals under the new framework to remain compliant and competitive.
iii. What Happens to Existing MAS Contractors?
Summary: GSA will issue a Mass Modification requiring participation in TDR. Contractors must accept within 90 days. The mod’s effective date aligns with the next sales quarter (Jan 1, Apr 1, Jul 1, Oct 1). Example dates: Mod initiated in Feb 2026; TDR begins Apr 1, 2026; First report due Apr 1, 2026.
This is a program-wide transition that realigns pricing, reporting, and contract administration to TDR.
iv. End of Price Reductions Clause (PRC)
PRC liability ends on the first day of the next sales quarter after accepting the TDR modification.
This creates a clean transition point for pricing governance tied to TDR participation. The TDR expansion is the defining change in Refresh 31. It will cascade through submission, modification, and pricing processes, demanding robust data-management capabilities and disciplined change control across your organization.
Key takeaway: Universal TDR is now the default. Non-TDR pathways are being retired, and contractors must participate in TDR to stay in MAS.
Also Read: Understanding GSA MAS Refreshes and What Contractors Need to Know
4. Startup Springboard Program – Now Limited to FASt Lane (ITC Only)
The Startup Springboard program is narrowed to FASt Lane participants and is ITC-focused. Eligibility is restricted to ITC SINs (except ancillary), assignment of an ITC CO, linkage to a federal IT initiative, written federal agency requests, and strict review timelines. Non-IT startups are effectively excluded.
This shifts the program from broad eligibility toward IT-centric participation, aligning with agency IT initiatives and the ITC’s governance footprint. For startups, the narrowing of eligibility means seeking ITC alignment and agency-backed IT initiatives if you want Springboard access. It emphasizes IT-centric pathways over broader startup support.
Key takeaway: Startup Springboard is effectively an IT-focused channel tied to FASt Lane participation; non-IT startups should plan alternative routes.
5. Firearms & Ammunition – Scope Narrowed
The scope language in each Large Category attachment will explicitly exclude foreign replica weapons and inert ordnance from MAS coverage.
This clarification reduces ambiguity and helps bidders understand the boundaries of what MAS will cover, potentially influencing solution design and risk assessment. Clear scoping reduces ambiguity for programs that involve regulated or sensitive items. It helps agencies and industry align expectations upfront.
Key takeaway: The program’s scope on firearms and ammunition will be tightened to exclude certain inert or replica items.
A Draft-Level Snapshot of the Changes Affecting the Entire MAS Solicitation
The draft Refresh 31 package introduces sweeping, cross-cutting changes that will touch every MAS solicitation and how contractors prepare offers. AI compliance language will be added to the General Information sections to align with federal AI governance. SCP-FSS-001 will be revised to reflect mandatory TDR and updated pricing requirements. The Full Expansion of TDR will remove non-TDR references from the solicitation, marking a major modernization step. For existing MAS contractors, a Mass Modification will require participation in TDR with a 90-day acceptance window and alignment of the mod’s effective date to the next sales quarter. The Startup Springboard program will be limited to FASt Lane ITC participants, narrowing ITC-aligned eligibility. The Firearms & Ammunition scope will be clarified to exclude foreign replica weapons and inert ordnance. Finally, clause and provision updates will bring in TDR-related and RFO-aligned language via FAC 2025-06, with detailed summaries to follow.
Key takeaway: The MAS solicitation landscape is moving toward universal TDR adoption, expanded AI governance, IT-centric Springboard alignment, and tighter scope definitions, together with clearer, more uniform contract language.
How to Apply Changes: Governance, Readiness, and Strategy
The practical path is to build readiness for a TDR-centric MAS environment, with AI governance and IT alignment shaping eligibility and pricing dynamics. Governance teams should map data governance frameworks that cover data lifecycle, audit readiness, and transparency expectations, ensuring operations can handle broader data exposure without compromising data quality. Bidders should prioritize TDR data collection and reporting processes, align internal pricing practices with TDR data elements, and invest in pricing analytics that support transparent disclosures.
What Contractors Should Consider Now:
- Evaluate TDR Readiness:
- Map current pricing data flows
- Identify gaps in data capture, ownership, and governance
- Develop auditable data trails for pricing, performance metrics, and change histories
- Review Pricing Data Maturity:
- Ensure datasets are standardized and version-controlled
- Source data from verifiable documents
- Demonstrate data provenance in bid packages and post-award reporting
- Align with Startup Springboard GSA:
- Coordinate data readiness activities with Springboard milestones and governance expectations
- Frame strategy around data maturity and compliance readiness
- Monitor GSA Communications:
- Stay updated on final Refresh 31 language and transitional provisions
- Maintain open channels with GSA points of contact to review any draft guidance
- Embed TDR-Ready Pricing Narratives:
- Integrate pricing narratives across cross-functional teams (pricing, contracts, compliance, IT)
- Ensure pricing stories are coherent, defensible, and auditable across the MAS lifecycle
- Establish Data Governance Frameworks:
- Build robust data governance frameworks
- Establish pricing data lineage
- Outline a path to demonstrate compliance with evolving transparency requirements
Key takeaway: Prepare now to respond quickly to refresh milestones, whether pursuing TDR-enabled offerings or maintaining flexibility under evolving pathways.
GSA’s Draft Refresh 31 signals a pronounced shift toward pricing transparency and disciplined data reporting. Those who proactively advance data maturity, governance frameworks, and transparent TDR narratives will be well-positioned to navigate a MAS marketplace increasingly oriented toward standardized data trails and auditable pricing stories. Waiting for the final rule language can compress timelines and complicate post-publication adjustments, so it makes strategic sense to begin shaping a credible, auditable pricing narrative now, and to establish governance processes that can scale as Refresh 31 moves toward formal adoption.
If you’re evaluating Refresh 31 readiness for your organization, our team can help you assess options and build a pragmatic roadmap. Explore how our GSA MAS Services supports outcomes like enhanced pricing transparency and post-award compliance alignment, or get in touch to discuss your scenario. Our expert GSA team is ready to help you interpret evolving changes and strategically align pricing, data, and governance posture ahead of the refresh-driven shifts. Contact Us Today to discuss your scenario.
