GSA Schedule Refresh 31 (2026): Key Changes for Contractors

Understanding GSA Schedule Refresh 31

The General Services Administration (GSA) has announced Schedule Refresh #31, scheduled for release in March/April 2026, representing one of the most significant updates to the Multiple Award Schedule (MAS) program in recent years. With a comment deadline of March 20, 2026, contractors holding GSA Schedule contracts need to understand these proposed changes and take action to protect their interests.

GSA Schedule Refresh initiatives occur periodically to modernize contract terms, incorporate new regulatory requirements, and address evolving marketplace needs. Refresh #31 stands out due to its introduction of artificial intelligence requirements and substantial modifications to existing contract terms that will affect thousands of schedule holders across all industry categories.

For contractors, these updates aren't optional. Once finalized, GSA will issue a mass modification to all affected schedule holders, who must accept the changes within 60 days of issuance. Understanding what's coming and participating in the comment period gives you the opportunity to influence these changes before they become mandatory.

Major Changes Proposed in Refresh 31

New Artificial Intelligence Requirements

One of the most significant additions in Refresh #31 is the incorporation of AI-specific requirements and terms. As federal agencies accelerate their adoption of AI technologies, GSA is establishing framework provisions that will govern how AI products and services are offered through the MAS program.

These AI requirements are expected to include:

• Transparency standards for AI algorithms and decision-making processes
• Data governance clauses addressing how AI systems use government data
• Performance metrics specific to AI-powered solutions
• Risk assessment frameworks for AI implementations
• Compliance attestations related to ethical AI use

Contractors offering AI-enabled products or services—even if AI is just one component of their solution—should pay particular attention to how these requirements might affect their current offerings and pricing structures. The introduction of these clauses reflects the broader government shift toward enterprise purchasing channels and modernized acquisition approaches.

Updated Terms and Conditions

Beyond AI-specific provisions, Refresh #31 proposes updates to core MAS terms and conditions that will affect all schedule holders:

Price Reduction Clause Modifications: Changes to how contractors must disclose and pass through price reductions to the government, potentially affecting pricing flexibility and commercial sales strategies.

Sustainability Requirements: Enhanced environmental and sustainability standards reflecting current administration priorities around climate change and green procurement.

Cybersecurity Provisions: Strengthened cybersecurity requirements aligned with recent regulatory developments and the increasing sophistication of cyber threats facing federal systems.

Subcontracting Reporting: Modified subcontracting plan requirements and reporting obligations, particularly for small business subcontracting goals.

Order-Level Materials: Updated guidance on what constitutes acceptable materials for task and delivery order competitions under schedule contracts.

Economic Price Adjustment (EPA) Clause Revisions

The proposed refresh includes modifications to EPA clauses that determine how contractors can adjust pricing over the life of their schedule contracts. These revisions aim to provide more flexibility in responding to market conditions while maintaining pricing competitiveness for government buyers.

Contractors should carefully review how these EPA changes might affect their ability to adjust pricing in response to inflation, supply chain disruptions, or other economic factors that have become increasingly relevant in recent years.

How Refresh 31 Affects Current Schedule Holders

Immediate Compliance Obligations

Once GSA issues the mass modification implementing Refresh #31 changes (expected in March/April 2026), schedule holders will face a 60-day acceptance deadline. This compressed timeframe means contractors cannot wait until the modification arrives to understand its implications.

Failure to accept the mass modification within the required timeframe could result in:

• Contract suspension or termination
• Inability to compete for new task orders
• Loss of schedule contract status
• Disruption to existing customer relationships

Operational and System Changes

The new requirements will likely necessitate operational adjustments across multiple business functions:

Legal and Compliance: Review and potentially update internal policies, particularly around AI governance, data handling, and cybersecurity practices.

Pricing and Finance: Assess how EPA and price reduction clause changes affect pricing strategies, margin management, and financial forecasting.

IT Systems: Evaluate whether current systems can support new reporting requirements or AI-related transparency obligations.

Proposal Development: Update standard proposal templates, past performance examples, and capability statements to reflect new requirements.

Platforms like GovCon SkyNet can help contractors track these compliance requirements and ensure their schedule contracts remain current with all GSA obligations.

Competitive Implications

Contractors who proactively adapt to Refresh #31 requirements will gain competitive advantages. Agencies increasingly evaluate schedule contractors based on their compliance posture and ability to meet evolving requirements. Demonstrating early adoption of AI governance standards or enhanced cybersecurity protocols can differentiate your offering in competitive task order scenarios.

Conversely, contractors who struggle with compliance or delay acceptance may find themselves at a disadvantage when competing against more agile competitors who have already integrated these requirements into their operations.

Actionable Steps: Reviewing and Commenting on Refresh 31

Step 1: Obtain and Review the Draft Documents

GSA has published detailed documentation on the proposed Refresh #31 changes through its Interact portal and official communications channels. Schedule holders should:

• Download the complete "Significant Changes" attachment that outlines all proposed modifications
• Review the draft contract language line-by-line, comparing it to your current schedule contract terms
• Identify provisions that directly affect your product or service categories
• Flag any requirements that would create operational challenges or increased costs

Step 2: Conduct Internal Impact Assessment

Assemble a cross-functional team including legal, compliance, operations, finance, and business development personnel to assess the impact:

Legal Review: Have counsel evaluate new liability exposures, particularly around AI requirements and cybersecurity provisions.

Cost Analysis: Calculate the financial impact of compliance, including any necessary system upgrades, additional personnel, or process modifications.

Competitive Analysis: Consider how these changes might affect your market position relative to competitors.

Customer Impact: Assess whether new requirements might affect current customer relationships or ongoing task orders.

Step 3: Prepare and Submit Comments

The March 20, 2026 comment deadline is firm. GSA genuinely considers stakeholder feedback during the refresh process, and well-reasoned comments can influence the final contract language.

Effective comments should:

• Be specific: Reference exact clause numbers and language rather than making general observations
• Provide rationale: Explain why a provision is problematic, using concrete examples when possible
• Suggest alternatives: Don't just identify problems—propose workable solutions that meet GSA's objectives
• Include data: Support your positions with market data, cost estimates, or implementation timelines
• Address government interests: Frame your concerns in terms of how they affect the government's ability to obtain best value

Submit comments through the official GSA channels specified in the Refresh #31 announcement, ensuring you retain confirmation of submission.

Step 4: Engage with Industry Groups

Many industry associations and professional organizations are coordinating collective responses to Refresh #31. Consider:

• Joining industry working groups focused on the refresh
• Participating in GSA stakeholder engagement sessions
• Coordinating with other contractors in your market segment
• Leveraging association resources to understand broader industry concerns

Collective industry comments often carry more weight than individual submissions, particularly on issues affecting multiple contractors or entire product categories.

Step 5: Begin Preparation for Implementation

Even while the comment period remains open, prudent contractors should begin preparing for implementation:

• Identify necessary policy updates and begin drafting revised documents
• Budget for compliance costs in your 2026-2027 financial planning
• Assess vendor relationships that might be affected by new subcontracting or supply chain requirements
• Consider training needs for personnel who will implement new requirements

The Broader Context: Government Contracting in 2026

Refresh #31 doesn't exist in isolation. It's part of a broader transformation in how the federal government approaches acquisition and procurement.

The government is accelerating its shift toward enterprise purchasing channels, with agencies moving away from fragmented buying toward more centralized, strategic procurement. This shift emphasizes the importance of maintaining compliant, current schedule contracts that can serve as vehicles for enterprise-wide solutions.

Regulatory and defense reforms continue to reshape the contracting landscape, with increased scrutiny on contractor cybersecurity postures, supply chain security, and emerging technology governance. Refresh #31's AI requirements reflect this trend, and contractors should expect continued evolution in these areas throughout 2026 and beyond.

Tools that help contractors stay ahead of these changes—monitoring regulatory updates, tracking contract modifications, and ensuring compliance with evolving requirements—become increasingly valuable in this dynamic environment. Modern platforms like GovCon SkyNet provide the intelligence contractors need to navigate these changes effectively.

Key Takeaways and Next Steps

GSA Schedule Refresh #31 represents a critical juncture for schedule holders. The introduction of AI requirements, updated terms and conditions, and modified pricing provisions will substantially affect how contractors operate under their schedule contracts.

The March 20, 2026 comment deadline is rapidly approaching. Schedule holders should immediately begin reviewing the proposed changes, conducting internal impact assessments, and preparing substantive comments that protect their interests while supporting GSA's modernization objectives.

Don't wait for the mass modification to arrive before understanding these requirements. Contractors who proactively engage with Refresh #31 now will be better positioned to accept the modification promptly, maintain compliance, and capitalize on competitive advantages that come from early adoption.

Review the draft changes today, assemble your internal team, and submit your comments before the deadline. Your participation in this process isn't just about compliance—it's about shaping the future of government contracting and protecting your position in the federal marketplace.