GSA Releases New TDR Compliance Guidance for MAS Contractors

The General Services Administration (GSA) has issued new guidance regarding Transactional Data Reporting (TDR) compliance, including the implementation of temporary grace periods and trial periods for contractors transitioning into the TDR Program and for those already participating in it. 

This guidance is important for MAS contractors because it clarifies how GSA will handle compliance as new reporting requirements take effect, when enforcement will begin, and what steps contractors should take to prepare. Below is an overview of the key guidance so contractors can better understand GSA’s expectations and ensure they remain compliant with TDR requirements. 

Grace Period for Contractors Transitioning to TDR 

For MAS contracts entering the TDR Program between October 1, 2025, and July 1, 2026, GSA is providing a temporary grace period through December 31, 2026. The purpose of this period is to give contractors time to become familiar with monthly TDR reporting requirements and address any reporting issues before compliance enforcement begins. 

During the grace period, contractors will not be penalized for reporting non-compliance. However, GSA may issue “soft flags” identifying reporting discrepancies, missing information, or data mismatches. Contractors are still expected to report all sales and work to correct any identified issues. 

Beginning January 1, 2027, TDR compliance will become subject to enforcement action by the Contracting Officer (CO).
 

Contractors That Have Not Accepted Modification A909 

GSA also provided guidance for contractors that have not yet accepted TDR Modification A909. Contractors that fail to accept the modification by June 30, 2026, may have their contracts cancelled at the discretion of the CO. In addition, delayed acceptance will not result in additional grace period time. Even if acceptance occurs after July 1, 2026, and leads to a later TDR implementation date, the grace period will still end on December 31, 2026.  

As a result, contractors should review and accept the modification as soon as possible to avoid unnecessary compliance challenges.

Trial Period for Existing TDR Contractors 

For contractors already participating in TDR prior to October 1, 2025, GSA is implementing a six-month trial period for several newly required reporting fields, including: 

• Ship Date 

• Order Date 

• Zip Code Ship To 

• Federal Customer 

• Unique Catalog Identifier (UCID) (for applicable contractors) 

• Cloud Service Type (for applicable Special Item Number [SIN] 518210C offerings) 

These reporting elements become required beginning July 1, 2026. During the six-month trial period, contractors will not be penalized for missing or invalid data, though GSA may issue soft flags to identify reporting issues. The trial period is intended to provide time for contractors to update internal systems, reporting processes, and data collection practices before enforcement begins. 

Once the trial period concludes, compliance with these mandatory reporting fields may be enforced by the CO. 

Additional Fields Still Pending in Sales Reporting Portal (SRP) 

GSA also identified several required fields that are not yet available within the Sales Reporting Portal (SRP): 

• Order Type 

• Order Discount (for applicable offerings) 

• Worksite (for labor-hour reporting requirements) 

Once these fields are added to SRP, contractors will receive a six-month trial period before compliance becomes enforceable. 

What This Means for Contractors 

GSA’s guidance gives contractors additional time to adjust to new TDR reporting requirements while preparing for future enforcement. Contractors should use the grace and trial periods to review reporting processes, validate data collection methods, and address any reporting issues before compliance enforcement begins.  

If you have questions about these changes or need assistance with TDR compliance, Global Services is here to help. Our team can provide guidance and support to help ensure your organization remains compliant with GSA requirements.