GSA has issued an important compliance reminder regarding the use of Amazon and other non-MAS online marketplaces to fulfill Multiple Award Schedule orders.
The notice was updated on July 30, 2026, to clarify its scope. It applies specifically to the use of non-MAS online marketplaces for MAS order fulfillment.
It does not:
- Affect agency use of the GSA Commercial Platforms Program
- Prevent vendors from selling non-MAS products through commercial marketplaces
The primary concern is whether the MAS contractor can demonstrate full compliance with all applicable contract requirements.
For every MAS order, the Schedule contractor remains the contractor of record and is responsible for ensuring that the order is properly accepted, processed, fulfilled, shipped, invoiced, reported, and performed.
This includes compliance with:
- Trade Agreements Act requirements
- Awarded MAS pricing and product scope
- Industrial Funding Fee and sales reporting requirements
- Product marking and labeling requirements
- Applicable invoicing and ordering procedures
- Supply-chain integrity and product traceability
Using a third-party marketplace does not transfer these responsibilities to the marketplace seller.
GSA explained that marketplace-based fulfillment presents a high risk of non-compliance and is, in most cases, inconsistent with MAS contract requirements unless the contractor can affirmatively demonstrate full compliance.
Potential risks include:
- Unverified country of origin
- Unauthorized or untraceable suppliers
- Product substitutions
- Pricing and invoicing discrepancies
- Incorrect sales reporting
- Products outside the contractor’s awarded scope
Contractors currently using online marketplaces or third-party marketplace fulfillment for MAS orders should promptly review their procedures and transition to compliant fulfillment methods where necessary.
Depending on the circumstances, non-compliance may result in financial liability, corrective sales reporting, negative past performance information, adverse CPARS ratings, contract cancellation, suspension, or debarment.
Can you document the complete supply chain from the manufacturer or authorized distributor through delivery to the federal customer?
Now is the time to review your fulfillment procedures, supplier documentation, TAA verification, invoicing controls, and sales-reporting practices.
