GSA released Solicitation Refresh 31 on April 2, 2026, and buried inside it is the biggest reporting change MAS contractors have faced in a decade. A contractor who clicks “accept” on the coming mass modification without reading it will switch their entire pricing-compliance model, and most will not notice until the first report is due.
Transactional Data Reporting (TDR) is now mandatory for all Multiple Award Schedule Special Item Numbers under Refresh 31. In exchange, GSA is eliminating the Price Reduction Clause (PRC) for contracts on TDR. Every MAS holder will move to monthly transactional reporting, with a participation effective date of July 1, 2026.
What Did Refresh 31 Actually Change for TDR?
Refresh 31 turned TDR from an optional pilot into the standard for the entire MAS program. For nearly ten years TDR applied to a limited set of SINs and contractors opted in. That era is over.
Three changes matter most:
- TDR is mandatory across all MAS SINs. There is no longer an opt-in or opt-out decision. New offerors and existing holders are on TDR.
- The Price Reduction Clause is eliminated for TDR contracts. You no longer track a Basis of Award customer or report price reductions against it. This is the trade GSA is offering: monthly sales data in, PRC tracking out.
- The Startup Springboard reverted to IT and FASt Lane eligible offerings only. If you were counting on Springboard for a non-IT offer, that path narrowed under Refresh 31.
The PRC removal is the part contractors underrate. The PRC has driven more compliance anxiety and more voluntary refunds than almost any other clause in the Schedule. Losing it is real relief. The cost is that your monthly TDR data becomes the record GSA, and potentially the OIG, reviews instead.
When Does TDR Take Effect, and What Is the Mass Mod Timeline?
The TDR participation effective date is July 1, 2026. GSA is implementing the change through a Mass Modification that existing contractors must accept.
Here is the timeline GSA has communicated for the transition:
| Milestone | What Happens | Date |
| Refresh 31 released | New solicitation terms, mandatory TDR, PRC eliminated | April 2, 2026 |
| Mass mod accepted on or before June 30 | TDR participation effective the next day | June 30, 2026 |
| TDR participation effective date | Reporting period begins; data quality grace period starts | July 1, 2026 |
| First monthly TDR report due | First transactional sales report for July activity | No later than August 30, 2026 |
Until your TDR participation effective date, you still provide Commercial Sales Practices (CSP) information and meet your existing non-TDR requirements. You do not get to stop one and start the other on your own schedule. The mass mod sets the switch.
If your contract is mid-renewal, mid-modification, or you are unsure when your acceptance window closes, this is the moment to map it. If you are staring at the mass mod and cannot tell what it changes for your specific SINs, a Schedule health check reads your contract and tells you what to accept and when.
What Do You Have to Do Differently Once You Are on TDR?
You report transactional sales data every month, and you stop tracking the Price Reduction Clause. The mechanics are simpler than PRC, but the discipline is monthly instead of quarterly.
Under TDR you report line-level data on each order against your Schedule, including the item, quantity, price paid, and the Industrial Funding Fee (IFF) owed. The practical shifts:
- Monthly cadence, not quarterly. TDR reports are filed monthly. A missed month is visible immediately.
- Your data is the audit trail. With the PRC gone, GSA evaluates your pricing and IFF through the transactional record. Clean, consistent reporting is now your compliance posture.
- IFF still flows through the same process. You report sales and remit the 0.75% IFF; TDR ties the two together in one monthly submission.
- System accuracy matters more. Catalog data on the FAS Catalog Platform and your reported transactions need to line up. Mismatches are what reviewers notice.
For most small and mid-size holders this is a net reduction in work. The contractors who struggle are the ones with messy order data or no internal owner for the monthly filing. A report that is late or wrong every month is worse under TDR than under the old PRC world, because the frequency makes the pattern obvious.
Should You Accept the Mass Mod, or Is There a Choice?
For existing MAS holders there is effectively no opt-out: TDR is now the program standard, and the mass mod is how GSA moves your contract onto it. The real decision is whether you accept it cleanly and on time or let the window lapse.
Mass Mods carry a defined acceptance window, and failing to accept within it puts your contract in a non-compliant status that can stall orders, modifications, and option exercises. This is not a clause to sit on. The strategic move is to accept deliberately, after you understand what it changes, not reflexively and not late.
Our Take
The headline is “TDR is mandatory,” but the story underneath is that GSA traded the PRC for your monthly data, and that trade rewards contractors with clean operations and punishes contractors who run their Schedule on guesswork. We have watched holders treat the PRC as the scary clause for years. Refresh 31 quietly replaced one compliance risk with another that is easier to satisfy and easier to fail in plain sight. The winners will be the firms that build a real monthly reporting habit before August 30, not the ones who scramble after the first report is late. This is exactly the kind of moment GSA Verticalization™ is built for: connecting the contract change, the system update, and the operating habit into one path instead of three separate fire drills.
Frequently Asked Questions
Is TDR mandatory for all GSA Schedule contractors in 2026? Yes. Under Solicitation Refresh 31, released April 2, 2026, Transactional Data Reporting is mandatory for all MAS Special Item Numbers. The previous optional pilot model has ended for both new offerors and existing holders.
Does Refresh 31 eliminate the Price Reduction Clause? For contracts participating in TDR, yes. GSA is removing the PRC in exchange for mandatory monthly transactional reporting. You stop tracking a Basis of Award customer and report sales data instead.
When does TDR take effect under Refresh 31? The TDR participation effective date is July 1, 2026, for contractors whose mass modification is accepted on or before June 30, 2026. The first monthly report is due no later than August 30, 2026.
What happens if I do not accept the Refresh 31 mass modification? Mass Mods have a defined acceptance window. Letting it lapse can place your contract in a non-compliant status that delays orders, modifications, and option exercises. Accept it before your window closes.
Do I still need to report Commercial Sales Practices after Refresh 31? You continue providing CSP information and meeting non-TDR requirements until your TDR participation effective date. After that date, TDR replaces the old reporting obligations tied to the PRC.
Don’t Let the Mass Mod Decide for You
The mass mod is moving your contract to TDR whether you read it or not. Before July 1, you want to know exactly what changes for your SINs, who owns the monthly report, and whether your catalog and sales data actually line up.
We map your contract against Refresh 31, confirm your acceptance window, and set up the monthly reporting so the first August filing is clean instead of a scramble.
→ Start Your Schedule Health Check
The contractors who handle this in June look organized to their CO. The ones who handle it in September are explaining a late report.
