Mandatory TDR Opt-In Coming Soon
As GSA prepares to release Refresh 27 to the Multiple Award Schedule (MAS) Program, contractors need to understand the actions required for the mandatory opt-in of the Transactional Data Reporting (TDR) program.
What is Transactional Data Reporting?
Transactional Data Reporting (TDR) is a reporting program that requires vendors to submit monthly transactional data on federal sales, including information including the quantity, price, and part number or labor category for each item or service sold. This replaces the requirement to track and report commercial sales practices (CSP) and Price Reductions Clause (PRC) compliance. TDR aims to improve pricing transparency and enable data-driven decision-making by government buyers. GSA uses the reported data to evaluate competitiveness and buying trends, allowing agencies to make more informed purchasing decisions.
For years, CSP has been the cornerstone of GSA pricing policy, requiring vendors to disclose detailed commercial pricing, track their Most Favored Customer (MFC), and abide by the PRC. TDR allows GSA contractors to skip the CSP disclosures entirely. Instead of identifying your MFC or Basis of Award (BOA), and then monitoring your prices to ensure GSA always gets the lowest price, you report your actual GSA sales each month and there is no commercial discount tracking required.
Under CSP, you must name your MFC and document your pricing policies in detail, then ensure your GSA price is never higher than the price your MFC receives. This is an ongoing compliance obligation that affects your entire sales strategy. With TDR, that disappears. You don’t identify a MFC, and you don’t track discounts to a BOA customer. You’re free to operate your commercial business without worrying it will impact your government pricing.
The PRC is one of the most restrictive clauses in the MAS program. It requires you to lower your GSA prices any time you give a better price to your BOA customer. This often means limiting discounts and monitoring your commercial pricing to avoid triggering a contract violation. When you opt into TDR, the PRC goes away. You can give promotional discounts, negotiate discounts, and adjust pricing as needed without triggering a contract mod or audit risk.
What’s Changing in Refresh 27?
TDR will become mandatory for all product SINs and the Cloud SIN (518210C). If your contract includes one or more of the 181 TDR-eligible SINs listed by GSA, you will be required to opt into the TDR program no later than September 30, 2025, by submitting a “Participate in TDR” modification.
The requirement to report TDR data will begin on the first day of the following sales quarter after your mod is accepted (e.g., January 1, April 1, July 1, or October 1).
Once your TDR mod is executed, liability under the Price Reductions Clause ends on the first day of the next reporting quarter.
Who Needs to Opt In?
If your contract includes one or more of the newly TDR-eligible SINs, you will need to opt in upon acceptance of the Mass Modification of Refresh 27. This includes many SINs that were not previously covered under the TDR pilot.
In a future refresh, TDR participation will be mandatory for all SINs, not just those covered in Refresh 27. All contractors will opt-in to TDR no later than September 30, 2025.
Some vendors have asked whether mandatory TDR SINs will be auto-enrolled. The answer is no. You must manually opt-in by submitting the Participate in TDR mod, even if your contract already contains eligible SINs. You are not automatically enrolled simply because a SIN becomes mandatory. Please reach out to us if you need support submitting this modification.
Action Items:
Check your SINs. Are they among the 181 TDR-eligible SINs? If so, be prepare to submit the opt-in to TDR mod upon the release of Refresh 27.
If your SIN’s are not on the list of the 181 TDR-eligible SINs, you will need to prepare your TDR mod to be submitted in the coming weeks. Gather the necessary data and documentation to be ready for submission before the September 30, 2025 deadline.
Now is a good time to make sure you have the latest copy of your Price Proposal Template, Awarded GSA Discounts, Commercial Pricelists or Market Rate Sheets, GSA Advantage Pricelist and your SIP or FCP file.
