GSA MAS Refresh 31 is Here — And Refresh 32 is Already on the Horizon

The General Services Administration (GSA) released Multiple Award Schedule (MAS) Refresh 31 on April 2, 2026, introducing some of the most significant changes to the MAS program in years. Now, GSA has also issued an advanced notice for upcoming MAS Refresh 32, signaling that additional compliance and operational changes are already underway.

For small businesses operating under a GSA Schedule contract — or planning to pursue one — understanding both Refresh 31 and the anticipated direction of Refresh 32 is critical for staying compliant and competitive.

What Changed in MAS Refresh 31?

Refresh 31 officially shifted the MAS program toward greater pricing transparency, expanded reporting requirements, and tighter oversight of contractor operations. The biggest changes include:

Mandatory Transactional Data Reporting (TDR) for All SINs

The most impactful change in Refresh 31 is the expansion of Transactional Data Reporting (TDR) to all MAS Special Item Numbers (SINs). TDR is no longer optional — it is now mandatory across the MAS program.

This means contractors must report transactional-level sales data directly to GSA on a recurring basis. In exchange, GSA is reducing reliance on traditional Commercial Sales Practices (CSP) disclosures and the longstanding Price Reductions Clause (PRC).

Why This Matters to Small Businesses

For many small businesses, the removal of CSP and PRC requirements may reduce some administrative burden and pricing risk. Contractors no longer need to constantly monitor commercial discount relationships in the same way they did under the old framework.

However, mandatory TDR also raises the bar for operational maturity. Small businesses now need:

• More reliable invoicing and accounting systems

• Better sales tracking processes

• Stronger internal controls

• Improved audit readiness

Companies still relying on spreadsheets or disconnected systems may find the transition challenging as reporting requirements become more data-driven.

Startup Springboard Restrictions

Refresh 31 also narrowed eligibility for the Startup Springboard Program. Previously expanded to support startups across industries, the program is now limited to companies qualifying under the FASt Lane program.

For newer businesses, this means:

• More emphasis on operational readiness

• Increased documentation expectations

• Greater scrutiny during the offer process

Small businesses considering a future MAS offer should ensure their accounting, compliance, and contract administration processes are scalable before applying.

OLM Expansion and Open Market Item Changes

Refresh 31 expanded Order-Level Materials (OLMs) availability to all SINs while continuing GSA’s effort to reduce reliance on open market items.

This may affect:

• Proposal strategies

• Material purchasing practices

• Subcontractor management

• Task order structuring

Contractors should review whether adding the OLM SIN to their contract would provide greater flexibility moving forward.

MAS Refresh 32: What Contractors Should Be Watching

While industry is still adjusting to Refresh 31, GSA has already released an advanced notice for MAS Refresh 32, giving contractors an early look at additional changes under consideration.

One of the biggest anticipated developments involves new Artificial Intelligence (AI) safeguarding requirements for federal contractors.

Proposed AI Safeguarding Clause

GSA is considering implementation of a new clause titled:

GSAR 552.239-7001 — Basic Safeguarding of Artificial Intelligence Systems

Although originally discussed during the Refresh 31 process, GSA delayed implementation and is now expected to address it in Refresh 32.

The proposed clause could create substantial new obligations for contractors using AI tools or AI-enabled services during contract performance.

Potential Requirements Include:

• Restricting use of foreign AI systems

• Requiring disclosure of AI tools used in contract performance

• Prohibiting government data from being used to train commercial AI models

• Expanding government oversight rights

• Requiring AI risk management documentation

• Imposing incident reporting requirements

• Requiring alignment with the NIST AI Risk Management Framework
  

Why Small Businesses Should Pay Attention

Many small businesses may not even realize these requirements could apply to them.

If your company uses:

• AI writing assistants

• Proposal generation tools

• AI-enabled analytics

• Automation software

• Machine learning platforms

• AI-based cybersecurity or business systems

…you could eventually fall under these compliance requirements if the clause is finalized.

For small contractors with limited compliance infrastructure, these changes could create:

• New documentation burdens

• Vendor management challenges

• Additional cybersecurity considerations

• Increased compliance oversight

Even companies that are not “AI companies” may still be impacted simply by using commercial AI tools internally.

Preparing for Refresh 32 Now

Small businesses should start preparing before Refresh 32 is formally released. Recommended actions include:

1. Identify all AI tools currently used within your organization

2. Review whether any systems involve foreign AI providers or hosting

3. Begin documenting AI governance and usage policies

4. Strengthen internal reporting and compliance procedures

5. Evaluate whether accounting and ERP systems can support expanded reporting requirements

6. Monitor upcoming GSA mass modifications closely
   

Final Thoughts

MAS Refresh 31 marked a major shift toward data-driven oversight and modernization of the MAS program. Refresh 32 appears poised to continue that trend — particularly in the area of AI governance and contractor accountability.

For small businesses, the key takeaway is clear: compliance expectations are increasing, and contractors with disciplined operational processes will be better positioned to adapt.

Businesses that proactively strengthen reporting systems, compliance controls, and internal governance now will likely have a significant advantage as the MAS program continues evolving.

For contractors who want to review GSA’s official advanced notice for Refresh 32, GSA’s announcement is available here: Multiple Award Schedule - Advanced Notice for MAS Refresh 32 and Upcoming Mass Modification | Interact | BUY.GSA.GOV