GSA updated key parts of its Multiple Award Schedule (MAS) pricing approach in 2026. The updates affect how contractors support pricing, demonstrate discounts, and manage price adjustments over the life of the contract.
Two groups feel this most. Current Schedule holders managing modifications and option exercises, and businesses preparing offers that must hold up under pricing review from day one.
Pricing issues rarely appear early. They tend to surface when something has to be approved, defended, or renewed. That’s why the smartest move in 2026 is not guessing what changed. It’s knowing which pricing compliance model governs your contract, then running your internal process to match it.
When you know which model applies, pricing decisions get simpler. Modifications move with less back-and-forth, documentation stays ready, and you reduce the chances of a pricing question disrupting revenue timing.
In 2026, the biggest pricing change is not one new rule. It’s that two pricing compliance models now operate side by side on MAS, and your contract file determines which one governs you.
Under the traditional approach, contractors complete a Commercial Sales Practices (CSP) disclosure, which explains how you price commercially and what discounts you typically provide. GSA uses that disclosure to establish a Basis of Award customer relationship. That relationship is the benchmark customer or customer category used to evaluate whether the government’s discount is fair and reasonable.
Many contractors refer to this benchmark as the “Most Favored Customer.” Under MAS, however, the operative concept is the Basis of Award relationship documented in your contract.
From there, the Price Reduction Clause (PRC) can apply. The PRC requires action if the discount relationship tied to that benchmark shifts in a way that makes the commercial customer more favorable than the government. If you are not operating under TDR, that monitoring responsibility remains active.
Transactional Data Reporting (TDR) works differently. Instead of maintaining a disclosure-driven benchmark relationship, the compliance posture is built on reporting actual Schedule sales transactions. For eligible categories, CSP disclosures and PRC tracking are removed, and the contract shifts into a monthly transactional reporting requirement.
Whether TDR can apply often depends on your Special Item Number (SIN), the MAS category code that defines what you sell on the Schedule. Certain SINs are eligible for TDR while others remain under the traditional structure.
MAS Solicitation Refresh 31 and later refresh cycles expanded TDR eligibility across additional SINs and clarified that implementation occurs through contract modification. Those updates did not eliminate the traditional CSP and PRC model across the board. They reinforced a simple reality. Your active contract file controls what you are accountable for.
One practical way to determine which pricing model governs your contract is to check the clause version in your award. If your contract includes the standard PRC language, the Basis of Award relationship remains active. If it reflects the TDR version of the clause, the PRC does not apply and transactional reporting controls instead.
If your contract is under TDR, compliance is built on reporting discipline. You are reporting what you actually charged on covered Schedule transactions, and that pulls pricing oversight closer to accounting, invoicing, and item setup.
Transactional sales data is reported monthly through the FAS Sales Reporting Portal. The Industrial Funding Fee is still remitted quarterly, but the sales data is submitted each month. That makes process design part of compliance. If item setup is inconsistent or discounts are applied differently across teams, the reporting starts to show variance you may not be ready to explain.
TDR also does not come with a blanket “low commercial sales” exemption. Applicability is based on SIN eligibility and contract terms, not volume alone. The practical question is straightforward. Can you capture the required data fields consistently, and can you trace a reported price back to the supporting record without gaps?
Think of TDR as a systems test. Clean reporting reduces data gaps, limits follow-up questions, and keeps pricing decisions tied to documented transactions instead of assumptions. When your data is clean, pricing reviews and contract actions tend to move with less friction because your numbers tell a consistent story.
If your contract is not under TDR, the traditional model still governs. That means your CSP and PRC expectations tied to your Basis of Award relationship remain active. Compliance here is less about monthly reporting and more about keeping what you promised aligned with how you sell today.
Alignment means three things stay consistent. What you disclosed in your CSP, how you price commercially now, and how you monitor changes tied to the benchmark relationship. When those drift apart, risk builds quietly. A discount offered for competitive reasons can create a contract issue if it affects the Basis of Award relationship and is not evaluated in context.
Recent refresh guidance clarified how PRC triggers are interpreted. Not every commercial discount requires a government price adjustment. The deciding factor is whether the discount changes the benchmark relationship tied to your contract. That determination needs documentation, not assumption.
Economic Price Adjustment (EPA) provisions allow price changes during the contract term, but only through the method your contract authorizes. What determines how smoothly an increase moves is not urgency. It’s whether the request clearly maps to your EPA method and matches your commercial reality.
When pricing support is incomplete or inconsistent, review timelines extend and follow-up questions increase. Clean support helps pricing actions move with less back-and-forth because your rationale is easy to validate.
Before adjusting pricing, use this decision filter:
That is how you protect eligibility and reduce avoidable friction during contract actions.
Pricing compliance issues rarely start with bad intent. They start with assumption. Assuming your SIN moved to TDR, assuming the PRC no longer applies, assuming your documentation will hold when pricing is reviewed during a modification or option exercise.
A protected MAS posture comes from validation, not guesswork. Identify the governing pricing model in your contract file. Then run reporting, discounting, and price adjustment requests in a way that matches that model. When your contract posture is consistent, you reduce eligibility risk and make pricing easier to defend when questions come up.
Since 2010, USFCR has helped simplify government contracting for over 300,000 businesses, including firms working through MAS acquisition and ongoing contract management. If you want experienced guidance before you submit changes, USFCR can review your Schedule pricing posture, help you determine whether TDR or the traditional CSP and PRC model governs your contract, and tighten the documentation that supports modifications and price adjustments. That kind of review helps keep contract actions cleaner and reduces avoidable exposure tied to misalignment.
Does MAS Solicitation Refresh 31 mean every Schedule is now under TDR?
No. Refresh 31 expanded TDR eligibility and clarified implementation through modification for certain SINs, but many contracts remain under the traditional CSP and PRC model. Practical implication: verify your contract file before assuming anything changed.
What is a SIN and why does it matter for pricing?
A SIN is the Schedule category code tied to what you sell and how your offer is organized. Some SINs are eligible for TDR and others are not, so SIN selection can affect which pricing compliance model applies.
If I’m under TDR, do I still track the Price Reduction Clause?
Typically no. Under TDR, CSP disclosures and PRC tracking are removed for participating SINs, and monthly transactional reporting becomes the compliance backbone. Practical implication: focus on reporting accuracy and reliable data capture.
How often is TDR reported in practice?
Transactional sales data is reported monthly through the FAS Sales Reporting Portal, while the Industrial Funding Fee is remitted quarterly. Practical implication: build a monthly close process so reporting stays consistent.
Did EPA rules change because of inflation in 2026?
The core EPA mechanism remains, but recent refresh cycles clarified timing and documentation expectations. Practical implication: match your support package to the EPA method in your contract so requests stay defensible.