A new era of transparency

On June 9, 2025, the General Services Administration (GSA) announced one of the most consequential changes to the Federal Supply Schedule (FSS) program since its inception — it would begin expanding its Transactional Data Reporting (TDR) requirement across the entire FSS program. Starting with Solicitation Refresh 27, TDR will become mandatory for all product Special Item Numbers (SINs) and cloud service SIN 518210C, eventually extending to all remaining SINs.

Translation? The Commercial Sales Practices (CSP) disclosure and Price Reductions Clause (PRC) requirements will be eliminated (or, in the case of the PRC, significantly altered), relieving contractors of some of the most burdensome and risky aspects of GSA Schedule contracting. PRC liability, long viewed as a significant compliance risk due to its complexity and potential for costly penalties — will effectively disappear. But while this shift may appear to simplify the landscape for contractors, it also ushers in a new era of uncertainty.

TDR, while less burdensome in some respects, brings its own set of challenges: increased data transparency, heightened scrutiny of pricing consistency across federal agencies and potential questions around value and fairness — particularly if notable pricing differences emerge between agencies or contract vehicles. As the GSA shifts from historical pricing disclosures to real-time federal sales reporting, contractors must prepare for a fundamentally different risk environment — one that may be less predictable and potentially more demanding in terms of data integrity, pricing strategy and audit readiness.

The FSS pricing paradigm: A high-level primer

Since its inception, the FSS contracting model has been predicated on the principle that items offered under Schedule contracts should meet the definition of commercial items as outlined in Federal Acquisition Regulation (FAR) 2.101[1]. This notion of commerciality implies that the basic principles of supply and demand in the commercial marketplace will result in prices that are inherently fair and reasonable assuming adequate competition exists.

However, vendors are not awarded FSS contracts through direct competition with one another. Rather, the GSA evaluates each offer independently by comparing the proposed pricing and terms to those extended to the vendor’s commercial customers. This evaluation is meant to account for differences in terms and conditions that may influence commercial pricing and discounting practices, enabling the GSA to establish price negotiation objectives for the government.