GSA MAS Refresh 31: Mandatory TDR and the End of the Price Reduction Clause

GSA’s Refresh 31 mass modification is the biggest change to how Multiple Award Schedule contractors report sales in nearly a decade, and if you haven’t accepted it yet, the clock on your acceptance window is likely already running. Here’s what Transactional Data Reporting (TDR) mandatory status actually means, what’s going away, and what’s probably already effective on your contract right now.

What Refresh 31 Actually Changes

Refresh 31 makes Transactional Data Reporting mandatory across essentially all GSA MAS contracts and SINs, ending the years-long arrangement where TDR was an optional alternative to the older reporting model. Alongside that, GSA is eliminating the existing Price Reduction Clause (PRC) and replacing it with a new version built around a different liability structure that’s actually consistent with TDR reporting — and dropping the Commercial Sales Practices (CSP-1) disclosure requirement along with Most Favored Customer tracking entirely.

Why This Has Been Almost a Decade in the Making

TDR itself isn’t new — GSA has been running it as an optional pilot program across various SINs for years, expanding it refresh by refresh. What’s new with Refresh 31 is the word “mandatory.” Contractors who stayed on the old PRC/CSP-1 model because they preferred it, or simply never switched, no longer have that option once the modification is accepted.

The Modification and Acceptance Timeline

The Refresh 31 mass modification was issued to contract holders starting around February 2026. Contractors have 90 days from issuance to accept it. If you haven’t seen or accepted this modification yet, check your contract’s modification history in eOffer/eMod immediately — a missed acceptance window on a mandatory mass mod is not something to discover by accident during a contract review.

When TDR Actually Becomes Effective on Your Contract

The effective date isn’t the same for everyone — it’s staggered based on when you accept. TDR requirements become effective at the start of the next sales-reporting quarter after your modification is accepted. Practically: accept in February 2026, and TDR is effective April 1, 2026. Accept any time after April 1, 2026, and effectiveness shifts to July 1, 2026. Given that timeline, most contract holders who accepted at a reasonable pace should already be reporting under TDR right now — if you’re not sure whether you are, that’s worth confirming with your contracting officer this week, not at your next contract review.

What Reporting Under TDR Actually Looks Like

Once TDR is effective on your contract, you’re filing monthly transactional data reports rather than maintaining CSP-1 disclosures. Each report is due within 30 calendar days after the end of the previous month — a firm, recurring deadline that replaces the old periodic disclosure-and-negotiate cycle around Most Favored Customer pricing.

Why GSA Is Killing the Price Reduction Clause

The old PRC tied your GSA pricing to your “most favored customer” and required you to track and disclose commercial sales practices to prove you weren’t giving a better deal elsewhere without passing it to the government. TDR flips that model: instead of policing your commercial pricing relationships, GSA collects actual transaction-level sales data and uses that to monitor pricing directly. Removing PRC and CSP-1 removes the administrative burden of the old disclosure regime, in exchange for ongoing monthly data reporting under TDR.

Where This Fits in Your Ongoing Schedule Maintenance

TDR reporting becomes one more item in your regular MAS maintenance cadence, alongside quarterly sales reporting and Industrial Funding Fee (IFF) payments. See our GSA Schedule maintenance guide for how TDR fits into the broader post-award compliance calendar you’re already managing.

What This Means If You’re Still Deciding Whether to Get on Schedule

If you’re evaluating whether a GSA Schedule is worth pursuing in the first place, Refresh 31 is a net simplification on the reporting side — one fewer disclosure regime to maintain, replaced by a data feed most modern accounting/ERP setups can automate. See our GSA Schedule worth-it breakdown and our application guide if you’re building your case for pursuing MAS.

Common Mistakes to Avoid

Don’t assume “mandatory” means it applies the moment Refresh 31 was announced — it applies once you accept the modification, and the effective date runs from there. Don’t confuse the 90-day acceptance deadline with the TDR effective date — they’re different dates governed by different rules. And don’t keep maintaining CSP-1 disclosures out of habit after TDR goes effective on your contract; that’s the exact administrative burden Refresh 31 was designed to eliminate.

Getting Your Systems Ready Before the Deadline

The practical shift with TDR is that you’re now reporting actual transaction-level data monthly instead of periodically disclosing commercial sales practices. If your accounting or ERP system isn’t already set up to export transaction-level GSA sales data on a monthly cadence, that’s the gap to close before your effective date arrives — not after your first report is already late. Most contractors who struggle with TDR in the first few reporting cycles aren’t struggling with the concept, they’re struggling with pulling clean transactional data out of a system that was built around quarterly totals rather than per-transaction detail. Get your first test export built well before your effective quarter starts, so you’re not troubleshooting a data-formatting problem against a 30-day filing deadline.

Key Takeaways

• Refresh 31 makes TDR mandatory for all GSA MAS contracts and SINs, ending the optional-pilot era.
• The mass modification was issued starting ~February 2026, with a 90-day acceptance deadline.
• TDR becomes effective at the start of the next sales-reporting quarter after acceptance — e.g., accepted in February 2026 → effective April 1, 2026; accepted after April 1 → effective July 1, 2026.
• The old PRC and CSP-1 disclosure requirements are eliminated and replaced with monthly transactional data reports, due within 30 calendar days after month-end.
• Most contract holders who accepted on a normal timeline should already be reporting under TDR as of today — confirm your status with your contracting officer if you’re unsure.

FAQ

Is TDR actually mandatory now, or still optional for some SINs?
Mandatory. Refresh 31 ends the optional-pilot arrangement that let contractors choose between TDR and the old PRC/CSP-1 model — once you accept the mass modification, TDR applies.

What happens if I haven’t accepted the Refresh 31 modification yet?
Check eOffer/eMod for your modification history and confirm your acceptance deadline with your contracting officer immediately. Missing a mandatory mass modification’s acceptance window is a compliance risk worth resolving proactively rather than discovering later.

Do I still need to track Most Favored Customer pricing under the new rules?
No — CSP-1 disclosures and Most Favored Customer tracking are eliminated under Refresh 31. Your ongoing obligation shifts to monthly transactional data reporting instead.