GSA Continues Tracking Contractor Transactional Data
Published Date: 12/17/2025
Notice
Summary
The General Services Administration (GSA) is asking for approval to keep collecting detailed sales data from certain contractors who work with them. This helps GSA track what products and services are delivered under specific contracts. If you’re a contractor on these schedules, get ready to keep sharing your transaction info, with comments due by January 16, 2026—no extra fees, just some paperwork time.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 3 costs, 1 mixed.
Large Estimated Annual Time and Cost Burden
GSA estimates a large public burden from TDR: Year 1 total estimated cost $121,766,340 with 1,553,495 hours, and Years 2 & 3 total estimated cost $69,731,624 with 1,044,217 hours. Year 1 is higher because existing FSS non-TDR contracts are expected to transition to TDR during that year.
Transactional Data Reporting Becomes Mandatory
If you are a contractor on GSA Federal Supply Schedules (FSS) or a non-FSS contractor subject to TDR, you must continue to provide transactional data under the Transactional Data Reporting (TDR) rules. The class deviation (CD-2025-13) was issued on June 26, 2025, making TDR mandatory for the FSS program and requiring existing FSS contractors to transition to TDR during Year 1 of the renewal period.
Setup and Monthly Reporting Time Estimates
GSA estimates one-time setup time averages 10 hours for a manual reporting system and 245 hours for an automated system. Monthly reporting time estimates vary by sales category: Category 1 ($0 sales) manual 0.5 hours / automated 2.0 hours; Category 2 ($0.01–$25,000) manual 2.5 / automated 2.5; Category 3 ($25,000.01–$250,000) manual 5 / automated 3; Category 4 ($250,000.01–$1,000,000) manual 18 / automated 4; Category 5 (over $1,000,000) manual 50 / automated 5.
FSS Pricing Disclosures Replaced by TDR
GSA will amend the FSS solicitation to remove prior pricing disclosures and sales reporting requirements and make TDR mandatory for the FSS program, per Class Deviation CD-2025-13 (issued June 26, 2025). GSA also states that GSAR clause 552.238-120 (Economic Price Adjustment--Federal Supply Schedule Contracts) replaced a prior clause and is "less burdensome" and provides more flexibility.
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Key Dates
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Previous: 2025-23082 — Submission for OMB Review; General Services Administration Acquisition Regulation; Federal Supply Schedule Pricing Disclosures and Sales Reporting
The General Services Administration (GSA) is asking to keep collecting info from companies that sell products through its Federal Supply Schedule. These sellers must share pricing and sales details to keep things fair and clear. If you’re a contractor, get ready to keep reporting as usual, with comments due by January 16, 2026—no big cost changes, just a smooth extension!
Next: 2025-23084 — Submission for OMB Review; General Services Administration Acquisition Regulation; Construction Manager as Constructor (CMc)
The General Services Administration (GSA) is asking for public feedback on extending a rule that helps manage construction projects where the builder also acts as the project manager (called Construction Manager as Constructor or CMc). This update affects contractors and government staff by keeping a smooth process for pricing and settling construction contracts. Comments are due by January 16, 2026, and the paperwork takes about 400 hours and $33,300 a year to handle.