GSA MAS Refresh 31 AI Clause Explained | AIGovBid

GSA MAS Refresh 31 introduces an AI transparency clause requiring Schedule holders offering AI-enabled services to disclose how AI is used, training data sources, and bias mitigation practices. Effective for new offers submitted after March 2026, the clause affects roughly 4,200 contractors across 12 SINs.

GSA MAS Refresh 31: What the New AI Clause Means for Your GSA Schedule

GSA MAS Refresh 31 introduces sweeping AI requirements for Schedule holders. Learn what the proposed AI clause means for your small business and how to prepare.

GSA MAS Refresh 31 introduces an AI transparency clause requiring Schedule holders offering AI-enabled services to disclose how AI is used, training data sources, and bias mitigation practices. Effective for new offers submitted after March 2026, the clause affects roughly 4,200 contractors across 12 SINs.

This AIGovBid guide covers gsa schedule for small business government contractors and explains the next steps contractors should take.

Frequently asked questions

What is GSA MAS Refresh 31?

GSA MAS Refresh 31 is the 31st mass modification to the Multiple Award Schedule, introducing new AI transparency requirements, updated pricing policies, and changes to several SIN categories effective for offers submitted after March 2026.

Which SINs are affected by the AI clause in Refresh 31?

The AI transparency clause primarily affects IT-related SINs: 54151S (IT Professional Services), 518210C (Cloud Computing), 54151HACS (Cybersecurity), 511210 (Software), and several professional services SINs where AI tools are used to deliver services.

Do I need to modify my existing GSA Schedule for Refresh 31?

Yes. Existing contractors with affected SINs will receive a mass modification notice requiring them to accept the new AI clause terms through the eOffer/eMod portal within 60 days. Failure to accept results in the affected SINs being removed from your Schedule.

What does the GSA AI transparency disclosure require?

The disclosure requires contractors to identify AI tools used to deliver contract services, describe training data sources and any third-party AI platforms, explain bias testing and mitigation procedures, and confirm compliance with applicable AI Executive Orders and OMB guidance.

How can AIGovBid help with GSA MAS Refresh 31 compliance?

AIGovBid reviews your current Schedule contract, identifies affected SINs, drafts your AI transparency disclosure narrative, submits the mass modification acceptance through eMod, and positions your AI capabilities as a competitive differentiator in your GSA catalog description.

Canonical URL: https://www.aigovbid.com/blog/gsa-mas-refresh-31-ai-clause