Key Takeaways from GSA Refresh 25: Deleted Clauses & SIN Updates

Key Points:

• GSA Refresh 25, released in March 2025, introduced major policy changes reflecting a shift toward simplification and deregulation in federal procurement.
• The update removed multiple FAR clauses tied to sustainability and DEIA programs and revised SIN descriptions across several MAS categories.
• Contractors must update Price Proposal Templates, accept the Mass Modification in eMod, and review their FAS Catalog listings for compliance.
• Price Reporter helps GSA contractors audit SINs, update documentation, and maintain full compliance with the latest MAS solicitation requirements.

• Overview of Key Administrative and Policy Drivers
• Deleted Clauses: What Was Removed and Why
• Clauses Updated with Deviations
• Price Proposal Templates (PPTs) and Modification Guide Updates
• Large Category and SIN-Level Changes
• General Information Section Updates in Large Category Attachments
• Practical Implications for GSA Contractors
• Final Thoughts
• FAQ: Understanding the Key Takeaways from GSA Refresh 25

On March 25, 2025, the U.S. General Services Administration released MAS Solicitation Refresh 25, marking the second update of the year and the first issued under the new administration. This refresh introduced substantial policy revisions that reflect a noticeable shift in federal procurement priorities.

The GSA’s Multiple Award Schedule (MAS) program is regularly updated through solicitation refreshes to align with evolving laws, Executive Orders, and administrative goals. Each refresh modifies clauses, templates, and category structures to ensure the program remains consistent with federal policy. For contractors, these changes can directly affect compliance requirements, price proposal templates, and eligibility under specific Special Item Numbers (SINs).

Refresh 25 stands out for its deregulatory direction. The update removes and revises clauses related to environmental sustainability, diversity, equity, inclusion, and accessibility (DEIA) initiatives. These adjustments signal a clear departure from previous sustainability-driven procurement policies and introduce a simplified, compliance-focused framework.

This article outlines the most important updates introduced by GSA Refresh 25, including deleted clauses, deviations, and SIN modifications. It also explains what these revisions mean for contractors and how businesses can maintain compliance as the MAS program continues to evolve.

Overview of Key Administrative and Policy Drivers

GSA Refresh 25 reflects a major policy realignment driven by the priorities of the new federal administration. Following the transition in early 2025, several Executive Orders were issued that directly influenced the language and structure of the Multiple Award Schedule (MAS) Solicitation. These Executive Orders form the foundation for the deleted clauses, modified templates, and updated SIN descriptions introduced in Refresh 25.

Executive Order 14168 focuses on ending the federal funding of programs related to gender ideology. It directs agencies to ensure that federal resources are not used to promote or support gender ideology in any form. In the context of the MAS program, this order prompted the removal of certain provisions and SIN language that referenced diversity and inclusion policies previously embedded in the solicitation.

Executive Order 14148 reverses prior sustainability mandates by rescinding earlier directives such as E.O. 14057, which had emphasized clean energy and environmental performance goals. This change led to the removal of non-statutory sustainability programs and environmental preferences from GSA categories, including Energy Star and EPEAT references within IT and facility-related SINs.

Executive Order 14208 introduced a seemingly narrow but symbolically significant policy: prohibiting the procurement and use of paper straws within federal facilities. While the subject matter is limited, its inclusion in the solicitation highlights the administration’s intent to eliminate sustainability mandates considered burdensome or unnecessary.

Together, these Executive Orders reshaped the MAS Solicitation by removing or revising several FAR clauses and SIN descriptions. Requirements related to greenhouse gas reporting, environmental certifications, and DEIA compliance were eliminated or rewritten. As a result, contractors will notice a simplified solicitation structure focused on operational efficiency rather than policy-driven obligations.

Deleted Clauses: What Was Removed and Why

One of the most visible outcomes of GSA Refresh 25 is the removal of several long-standing clauses from the MAS Solicitation. These deletions were made to align the solicitation with the new administration’s policy direction, which emphasizes deregulation and the elimination of requirements tied to sustainability and affirmative action programs. The deleted clauses fall into two main groups.

A. Equal Opportunity and Affirmative Action

Several provisions related to equal employment opportunity and affirmative action were removed from the solicitation, including:

• 52.222-21 Prohibition of Segregated Facilities
• 52.222-26 Equal Opportunity
• 52.222-27 Affirmative Action Compliance Requirements for Construction
• 52.222-29 Notification of Visa Denial

These clauses previously required contractors to make specific representations regarding equal opportunity and compliance with affirmative action laws. Under the new policy framework, GSA has eliminated such representations from the MAS Solicitation to ensure consistency with Executive Order 14168, which restricts references to diversity, inclusion, and gender-based compliance programs.

B. Environmental and Sustainability Provisions

Refresh 25 also removed clauses associated with environmental management and sustainability programs, such as:

• 52.223-19 Compliance with Environmental Management Systems
• 52.223-22 Public Disclosure of Greenhouse Gas Emissions and Reduction Goals
• I-FSS-973 Payments by Non-Federal Ordering Activities

These deletions correspond with Executive Order 14148, which rescinded prior sustainability directives and discontinued non-statutory programs under the Environmental Protection Agency. The goal is to simplify procurement requirements by removing references to programs like Energy Star and EPEAT and eliminating mandatory reporting of greenhouse gas emissions.

It is worth noting that certain language from I-FSS-973 remains embedded within clause 552.238-114, meaning that contractors may still encounter partial remnants of these provisions elsewhere in the solicitation.

Contractors should carefully review their existing offers and contract documents to ensure they do not reference or rely on clauses that have now been deleted. Continuing to include these outdated provisions may lead to inconsistencies during modifications or compliance reviews under the updated MAS framework.

Clauses Updated with Deviations

In addition to removing several clauses, GSA Refresh 25 introduced updates based on two key Class Deviations issued in February 2025: CD-2025-04 and CD-2025-05 (Supplement 1). These deviations temporarily modify certain provisions of the Federal Acquisition Regulation (FAR) to align with new administrative policies before the formal regulatory updates are published.

A Class Deviation allows GSA to apply immediate changes to the solicitation without waiting for the full federal rulemaking process. This approach ensures that the MAS Solicitation reflects the latest Executive Orders and policy shifts in real time.

Among the clauses updated with deviations are several core FAR provisions, including:

• 52.212-3 Offeror Representations and Certifications – Commercial Products and Commercial Services
• 52.212-5 Contract Terms and Conditions Required to Implement Statutes or Executive Orders – Commercial Products and Commercial Services
• 52.223-23 Sustainable Products and Services
• 52.223-1 Biobased Product Certification
• 52.219-9 Small Business Subcontracting Plan
• 52.222-54 Employment Eligibility Verification

These updates primarily remove or adjust sustainability, diversity, and environmental reporting language while maintaining core compliance obligations. The deviations also refine definitions, update cross-references, and clarify implementation procedures in light of the new policy direction.

For contractors, the practical implication is clear. It is essential to review and update all Representations and Certifications in SAM.gov to ensure consistency with the current solicitation language. Offers or contract modifications that reference outdated versions of these clauses could lead to discrepancies or delays in approval. Staying aligned with the latest deviations helps contractors maintain compliance and ensures that submissions under the MAS program are accepted without issues.

Price Reporter Comment: Our GSA experts note that deviations often create temporary inconsistencies between the FAR text and solicitation practice. Contractors should not overlook these details, as timely updates to Representations and Certifications can prevent modification delays or rejections.

Price Proposal Templates (PPTs) and Modification Guide Updates

Along with the solicitation and clause revisions, GSA Refresh 25 included updates to the official Price Proposal Templates (PPTs) and the MAS Modification Guide. According to the changelog published with the refresh, the PPTs were revised to align with the new solicitation version but did not include any structural or formula-based changes. Both the Services and Training and Products templates retain the same data fields, pricing formulas, and validation logic as previous editions.

Even though no numerical or layout adjustments were made, contractors are strongly advised to download and use the most recent templates. Each refresh replaces prior versions of GSA forms, and using outdated files can trigger validation errors or delays when submitting new offers or contract modifications through eOffer and eMod.

The MAS Modification Guide was also updated as part of Refresh 25. The guide now incorporates instructions consistent with the revised solicitation, ensuring that contractors follow the correct process when adding, deleting, or revising SINs. It also reflects the latest compliance language and clarifies documentation requirements under the new administrative directives.

For contractors, the key takeaway is simple. Always rely on the most current version of the Price Proposal Templates and the Modification Guide, even when the updates appear minimal. Using the latest templates ensures that your submission aligns with the GSA’s current policy framework and prevents unnecessary rejections and processing delays.

Large Category and SIN-Level Changes

GSA Refresh 25 introduced a wide range of updates across multiple Large Categories and Special Item Numbers (SINs). Most of these revisions remove references to sustainability programs, diversity initiatives, and environmental certifications that no longer align with the current federal procurement priorities. While many of the changes appear administrative, they have practical implications for both new offers and existing contract modifications.

Facilities Category

The Facilities category was among the most affected. References to Energy Star and the Department of Energy ENABLE Program were removed from SINs 561210FAC, 561730, and 334512. The Energy Savings Performance Contracts (ESPC) subgroup was fully eliminated from the solicitation. Additionally, SINs 326199 and 238160 were updated with clarified descriptions to better reflect current facility and roofing service scopes.

Furniture & Furnishings Category

Within the Furniture and Furnishings category, SIN 321918PF (Portable Flooring Solutions) has been identified for future retirement and will be officially removed in Refresh 26. Contractors holding this SIN should plan accordingly and review potential alternative categories before the next solicitation update.

Human Capital Category

The Human Capital section also saw policy-driven changes. SIN 541612HC (Agency Human Capital Strategy, Policy and Operations) was revised to eliminate language tied to Diversity, Equity, Inclusion, and Accessibility (DEIA) initiatives. This reflects the broader policy shift away from diversity compliance mandates within federal solicitations.

Professional Services and Environmental

Several environmental and remediation SINs were modified to remove non-statutory sustainability and environmental reporting requirements. These include 541620 (Environmental Consulting Services), 562910REM (Environmental Remediation Services), and 562910RMI (Environmental Remediation Services – Multiple Industries). SIN 562112 (Hazardous Waste Disposal Services) was also updated with revised text to more accurately define the types of waste covered under its scope.

Transportation and Logistics Services

Updates in this category remove sustainability references and SmartWay program requirements from SINs 336212 (Trailers and Attachments), 3361V (Vocational Vehicles), and 532111 (Automotive Equipment Rental and Leasing). These changes align transportation-related procurements with the administration’s deregulatory approach by eliminating green initiative obligations.

For contractors, these updates extend beyond technical edits. SIN description changes can impact how products and services are categorized, which in turn affects contract scope, catalog listings, and compliance reviews. It is critical to review each SIN currently held under your contract to ensure that it matches the latest MAS Solicitation language and requirements.

Price Reporter Comment: Based on our experience managing hundreds of GSA contracts, even small SIN description adjustments can impact catalog compliance. We advise contractors to review all listings on the FAS Catalog Platform to ensure each SIN reflects the most current solicitation language.

General Information Section Updates in Large Category Attachments

GSA Refresh 25 also introduced updates within the General Information sections of the Large Category Attachments. These revisions explicitly reference the Executive Orders that guide the policy changes and establish new compliance expectations for contractors.

Each Large Category Attachment now includes direct citations to the recent Executive Orders, ensuring that contractors are fully aware of the administrative directives shaping the solicitation. These references serve as both guidance and restriction, clearly outlining which types of products, services, or solutions are no longer acceptable under the MAS program.

A new requirement was also added, instructing contractors to exclude from their offers any products or services that violate the provisions of these Executive Orders. This includes materials or offerings associated with gender ideology initiatives or sustainability programs that conflict with current federal policy. Contractors must verify that their catalog descriptions, marketing materials, and proposal narratives do not reference or rely on such programs.

This change carries significant compliance implications. Even indirect references to disallowed programs or environmental certifications could affect a company’s eligibility under certain SINs. As GSA increasingly ties policy compliance to contract validity, contractors should ensure their documentation and product data fully align with the revised solicitation language. Proactive review and correction can help prevent future compliance challenges during audits or contract modifications.

Practical Implications for GSA Contractors

For GSA contractors, the release of Refresh 25 requires immediate attention to several compliance and administrative details. While many of the updates appear policy-driven, they have direct consequences for how contractors manage their documentation, price lists, and online catalogs. Taking timely action will help avoid delays, rejections, or compliance issues during future reviews.

Contractors should take the following steps to stay aligned with the current MAS framework:

1. Review existing documentation for outdated clauses. Examine all proposal materials and contract files to ensure there are no references to deleted FAR clauses such as those related to Equal Opportunity, Affirmative Action, or sustainability reporting. Removing these citations will prevent inconsistencies with the latest solicitation text.
2. Update Price Proposal Templates and modification forms. Even though the formulas and fields have not changed, all new offers and modifications must use the current PPT versions introduced with Refresh 25. Submissions using outdated templates may be rejected or delayed in eOffer and eMod systems.
3. Accept the Mass Modification through eMod. GSA will issue a Mass Modification requiring contractor acceptance to incorporate the new solicitation terms into active contracts. Promptly accepting this modification ensures that your contract remains compliant with the updated requirements.
4. Verify that your FAS Catalog is fully synchronized. Review product and service listings on the FAS Catalog Platform to confirm that all descriptions, SIN references, and attributes match the revised solicitation. Any outdated or inconsistent information could impact visibility and compliance status.

As of late 2025, GSA continues to refine and streamline the MAS program, with additional adjustments expected in upcoming refreshes. Contractors that proactively monitor solicitation updates and align their internal records will be better positioned to maintain eligibility and respond quickly to future changes in the MAS framework.

Final Thoughts

GSA Refresh 25 marks a clear policy shift within the MAS program. The update emphasizes simplification and a move away from sustainability and DEIA-driven initiatives that shaped previous versions of the solicitation. By streamlining clauses, revising SIN descriptions, and eliminating non-statutory environmental and diversity requirements, GSA has refocused the program on efficiency, compliance, and straightforward procurement practices.

For contractors, this refresh is more than a procedural update. It represents a turning point that requires companies to adjust not only their documentation but also their broader business strategies. Those who proactively align their offerings, pricing structures, and compliance systems with the new solicitation, will maintain their competitive edge and ensure uninterrupted eligibility within the GSA marketplace.

At Price Reporter, we have been helping businesses succeed on the GSA marketplace for over nineteen years. Our team of experts supports contractors through every stage of the process, from contract acquisition and catalog management to compliance and automation. With more than one thousand contractors served and over fifteen hundred GSA contracts under management, we provide the insight and tools needed to keep your Schedule accurate, competitive, and ready for future changes. Staying proactive today ensures your GSA Schedule remains a long-term advantage tomorrow.

FAQ: Understanding the Key Takeaways from GSA Refresh 25

What is GSA Refresh 25 and why was it introduced?

GSA Refresh 25 is an official update to the Multiple Award Schedule (MAS) Solicitation released on March 25, 2025. It reflects new administrative policies that prioritize simplification and deregulation within federal procurement. The refresh removes or revises several clauses, eliminates sustainability and DEIA mandates, and updates SIN descriptions to align with current Executive Orders. These changes aim to make the MAS program more efficient and less burdensome for contractors.

Which clauses were deleted in Refresh 25 and what do these deletions mean for contractors?

Several clauses related to Equal Opportunity, Affirmative Action, and environmental sustainability were deleted. These include provisions on greenhouse gas reporting, environmental management systems, and diversity compliance. The deletions remove non-statutory obligations and reduce reporting requirements. Contractors should ensure that their offers and contract materials do not reference any of these outdated provisions to maintain compliance with the new solicitation.

What are Class Deviations and how do they affect GSA contractors?

Class Deviations are temporary adjustments to the Federal Acquisition Regulation (FAR) that allow agencies to implement policy changes before they are officially codified. In Refresh 25, Deviations CD-2025-04 and CD-2025-05 (Supplement 1) updated multiple FAR clauses to reflect recent Executive Orders. These deviations mainly affect sustainability, certification, and subcontracting requirements. Contractors should review their Representations and Certifications in SAM.gov to ensure they match the revised FAR language.

How did Refresh 25 impact SINs across Large Categories?

Refresh 25 introduced numerous updates to SIN descriptions across Facilities, Furniture, Human Capital, Professional Services, and Transportation categories. Most of these changes removed sustainability and DEIA language that no longer aligns with federal procurement priorities. Contractors holding affected SINs should review scopes of their contractual segments, along with catalog listings, to verify alignment with the updated solicitation text. Keeping SIN descriptions accurate helps prevent compliance issues and catalog upload rejections.

What steps should contractors take to stay compliant after Refresh 25?

Contractors should begin by reviewing and removing any outdated clauses from their documentation. They must also remain current with the latest Price Proposal Templates, accept the Mass Modification through eMod, and ensure their FAS Catalog matches current SIN descriptions. Even minor inconsistencies can lead to compliance complications during audits or contract renewals. Staying proactive with these updates helps contractors maintain a strong and compliant presence within the GSA marketplace.