GSA compliance means following the terms of your Multiple Award Schedule, or MAS, contract throughout its entire life, not simply meeting the requirements needed to receive an award. Contractors must accurately report Schedule sales, pay the Industrial Funding Fee, maintain current contract and catalog information, comply with applicable product and sourcing requirements, keep supporting records, and fulfill any additional obligations included in their specific contract.
The exact requirements vary according to the products or services offered, applicable Special Item Numbers, or SINs, and other contract-specific provisions. A product reseller may face sourcing and product-data requirements that do not apply in the same way to a professional services company, while some contractors have additional obligations such as subcontracting-plan requirements.
Compliance should therefore be treated as an ongoing business function. A contractor that was fully compliant on the date of award can develop problems later if its pricing, products, suppliers, sales processes, or company information change without corresponding contract administration.
Sales Reporting, TDR, and the Industrial Funding Fee
Accurate sales reporting is one of the core responsibilities of a GSA Schedule contractor. Companies need procedures for identifying which transactions are Schedule sales and capturing the information required by GSA. This becomes particularly important when a business handles commercial, open-market, and Schedule transactions through the same accounting or order-management systems.
Transactional Data Reporting, or TDR, became mandatory across MAS SINs under MAS Solicitation Refresh 31 in 2026. Contractors report required transaction-level information through GSA's Sales Reporting Portal. Reports are due within 30 calendar days after the end of each month, including reporting periods in which no reportable sales occurred.
Contractors must also account for the Industrial Funding Fee, or IFF. The IFF is currently 0.75 percent of reported GSA Schedule sales and is included in awarded Schedule prices. GSA requires the fee to be remitted within 30 calendar days following the end of each quarter, although contractors may remit it monthly.
This makes accurate identification of Schedule sales particularly important. A transaction classified incorrectly can affect both reporting data and IFF calculations. Companies should have a consistent method for determining whether an order is a GSA sale and should reconcile reporting information against internal order and accounting records.
At minimum, a recurring reporting process should address:
- correct identification of GSA Schedule sales;
- collection of required transactional data;
- monthly submission through the applicable reporting system;
- reconciliation of reported sales with internal records;
- accurate calculation and timely payment of the IFF.
Automation can simplify these processes, particularly for contractors processing large order volumes. However, using an automated system does not transfer responsibility for compliance away from the contractor. The company remains responsible for the accuracy and completeness of the information it submits.
Keeping the Contract, Pricing, and Catalog Information Current
A GSA Schedule must continue to reflect the contractor's actual awarded offering. Companies frequently change products, services, commercial pricing, employees, suppliers, addresses, and other business information. When a change affects the Schedule, the contractor needs to determine whether a formal contract modification or another update is required.
Products should not simply be added to a federal catalog because the company has started selling them commercially. Similarly, a commercial price change does not automatically change an awarded GSA price. Contract changes must follow the procedures applicable to the MAS contract.
Catalog accuracy is especially important because federal buyers use GSA systems to evaluate available products and services. Outdated descriptions, incorrect pricing, discontinued products, or inconsistent manufacturer information can create both sales and compliance problems.
The following table summarizes several major areas of ongoing compliance:
| Compliance area | Contractor responsibility | Common compliance risk |
| Sales reporting | Report required Schedule transaction data accurately and on time | Incorrectly classified or missing sales |
| Industrial Funding Fee | Calculate and remit the applicable IFF | Payment does not reconcile with reported sales |
| Contract modifications | Process applicable changes through GSA | Business changes are made without updating the contract |
| Catalog management | Keep published information aligned with awarded terms | Outdated products, descriptions, or pricing |
| Product compliance | Maintain eligible products and applicable supporting information | Noncompliant products remain on the Schedule |
| Recordkeeping | Retain records supporting contract activity | Contractor cannot substantiate reported information |
| Subcontracting | Follow applicable subcontracting-plan obligations | Required goals or reporting are overlooked |
Contractors should also monitor GSA solicitation changes and system transitions. MAS requirements are updated through solicitation refreshes, and GSA has been transitioning contractors to the FAS Catalog Platform, or FCP. A process that was correct several years ago may therefore no longer reflect the current method for maintaining a contract.
Product, Sourcing, and Other Contract-Specific Requirements
Product contractors need to pay particular attention to what they are selling through their Schedule. Having a commercial product available for sale does not automatically mean that the product is eligible for federal purchasing under the contract.
Country-of-origin requirements are especially important where the Trade Agreements Act, or TAA, applies. Contractors need to understand the origin of products offered under affected contract terms and ensure that their offerings remain compliant. Changes in manufacturers or supply chains can create compliance issues even when the commercial product appears unchanged to the customer.
Resellers also need to maintain appropriate supply relationships and supporting information where required. A supplier change should not be viewed only as a procurement decision. It may affect information associated with the GSA contract and should be reviewed accordingly.
Service contractors face different risks. Labor categories, qualifications, descriptions, and awarded rates should remain consistent with contract terms. Adding a new commercial service or changing the way a company packages its services does not necessarily authorize the same change under the Schedule.
Other obligations depend on the individual contractor. For example, certain contractors may have an approved subcontracting plan with associated goals and reporting responsibilities. Compliance procedures should therefore be based on the actual awarded contract rather than a generic checklist downloaded for all MAS contractors.
How Price Reporter Can Help With GSA Compliance
Maintaining compliance becomes more difficult as a GSA business grows and the number of products, modifications, orders, and reporting obligations increases. Price Reporter provides GSA Contract Management and compliance services to help contractors keep their Schedule information current and address ongoing administrative requirements.
Founded in 2006, Price Reporter has managed more than 1,500 GSA contracts and completed more than 20,000 GSA contract modifications. Our team assists contractors with contract modifications, catalog updates, compliance, Contractor Assessment support, and other areas of Schedule administration. Price Reporter also provides order-management solutions for companies that need to streamline transactions with federal buyers.
Contractors can use this support to address compliance continuously instead of waiting until outdated information, missed updates, or reporting discrepancies become larger problems. For companies preparing for a Contractor Assessment, Price Reporter can also assist with reviewing contract administration and addressing areas that may require attention.
Recordkeeping and Contractor Assessments
A contractor needs records that support what it reports and how it administers its Schedule. This includes relevant sales and order information, IFF records, approved modifications, pricing documentation, catalog records, and other materials required under the contract.
Good recordkeeping is particularly valuable during a Contractor Assessment. GSA Industrial Operations Analysts, or IOAs, conduct assessments during the life of MAS contracts to evaluate contractor compliance and provide guidance regarding contractual obligations.
A Contractor Assessment is not the same as an audit by the GSA Office of Inspector General. However, it can reveal weaknesses in sales reporting, IFF administration, recordkeeping, subcontracting obligations, or other areas of contract performance. Contractors should therefore maintain assessment-ready records as part of normal operations rather than attempting to reconstruct them only after GSA requests information.
Internal reviews can help identify discrepancies earlier. For example, reported Schedule sales can be reconciled with accounting and order records, catalog information can be compared with current awarded terms, and modification histories can be reviewed to confirm that business changes were properly incorporated into the contract.
Compliance responsibilities should also have a clear owner. Sales, finance, operations, and product teams can all make decisions that affect the Schedule, but someone needs responsibility for determining when those changes require GSA action.
The most effective approach is to connect GSA compliance with normal business processes. Changes to pricing, products, services, suppliers, company information, or government sales procedures should trigger a contract review when appropriate. Combined with accurate reporting, timely IFF payments, organized records, and current catalog information, this helps keep the Schedule aligned with both GSA requirements and the contractor's actual federal business.
