What changed on April 6, 2026
GSA quietly shipped a meaningful change to the FAS Catalog Platform on April 6, 2026: the long-standing Terms & Conditions (T&C) file requirement is now built directly into the FCP First Steps onboarding flow. If you log into catalog.gsa.gov and you are subject to this update, you will see an "Update T&C" prompt in the First Steps banner on your Catalog Overview page.
This is not a new MAS requirement. The T&C file has lived in GSAR clause I-FSS-600 ("Contract Price Lists") for years. What changed is enforcement: GSA is no longer relying on you to remember the requirement during a modification cycle. FCP now blocks catalog actions until the T&C file is current.
When I worked as a CO, "system enforces the rule" was always the moment when otherwise sleepy compliance requirements suddenly sent contractors into a panic. Here is how to handle this one without breaking your sales pipeline.
Who is impacted
You need to update your T&C file in FCP if you fall into any of these categories:
- You are a new contractor awarded after August 28, 2025 and have not yet created an initial T&C file in FCP.
- You are a new FCP user and need to establish or update your T&C file.
- You are an existing FCP user adding a new catalog offering that requires a baseline action (for example, you previously offered only products and now want to add services, or vice versa).
You are not impacted if you were awarded after August 28, 2025 and have already uploaded a compliant T&C file, or if you transitioned to FCP before this requirement took effect.
What goes in the T&C file
The T&C file is the section of your Schedule that describes the non-pricing terms that apply to your contract: ordering instructions, points of contact, accepted forms of payment, warranty terms, return policies, scope notes, and any contract-level conditions agreed to with your contracting officer. It is not a pricing document.
That distinction is what trips up contractors:
- Existing contractors transitioning their file: Download your current price list from GSA eLibrary and remove all pricing and catalog details that belong in your Product File or Services Plus File. The T&C file should be terms only.
- New contractors: Build the file to GSAR I-FSS-600 requirements. Do not include pricing unless a specific SIN explicitly requires it (for example, certain SINs require labor category descriptions that are functionally part of the priced offering).
What to actually put in the file
Walk through I-FSS-600 line by line. At minimum your T&C file should cover:
- Contract administration POC, contract specialist POC, and ordering activity POC.
- Geographic coverage and any domestic-versus-overseas delivery conditions.
- Minimum and maximum order thresholds.
- Quantity discount structure (if applicable — note that Refresh 31 has expanded TDR so quantity discount narratives may be different from your prior file).
- Payment terms, accepted credit cards, and prompt payment discounts.
- Warranty terms and return policies.
- Year 2000 / IT compliance language for IT SINs (still required under legacy clauses).
- Special attributes such as environmental certifications, country of origin and TAA compliance, and Section 508 conformance.
The single most common error I have seen — and contracting officers will tell you the same — is leaving stale POCs and stale ordering instructions in a file that has been carried forward through three contract modifications. FCP is now the gatekeeper, so a stale file is a blocking problem.
How to actually do this
Here is the workflow I would run:
- Log in to catalog.gsa.gov. Look for "Update T&C" in the First Steps banner. If you do not see it, you are not in the impacted population — but I would still pull your current T&C file from eLibrary and read it. You will find something stale.
- Download your current T&C file from GSA eLibrary. This is the public-facing version on file with GSA today. Use it as your starting point.
- Strip pricing and catalog details. If a section names a part number, a labor category rate, or a discount tier, that section belongs in the Product File or Services Plus File, not in T&C.
- Update POCs, ordering instructions, and warranty terms. Reconcile to current commercial practice. Your commercial T&C should be reflected here unless you have a specific Schedule deviation in your contract.
- Verify against I-FSS-600. The clause is your checklist.
- Upload via FCP First Steps. Document the upload date and keep a copy of what you submitted in your contract file.
Why this matters more than it sounds
A T&C file looks like paperwork. It is not. Three reasons it matters:
- GSA Advantage and GSA eLibrary will display your T&C file to buyers. A stale file makes you look like an inattentive contractor, and federal buyers do read these documents before placing larger orders.
- The T&C file is a contract document. Inconsistencies between your T&C file and your actual contract terms can be cited at audit. The OIG will not buy "the file was outdated" as a defense.
- FCP blocks catalog actions until T&C is compliant. That means a stale T&C file is now a direct revenue blocker — you cannot add SKUs, refresh pricing, or expand your offering until you fix it.
Bottom line
The April 6, 2026 FCP T&C update converts a long-standing GSAR I-FSS-600 requirement into an enforced gate. If you are a new contractor awarded after August 28, 2025, a new FCP user, or an existing user adding a new offering type, log in to catalog.gsa.gov this week, pull your file from eLibrary, strip the pricing, refresh the POCs and warranty terms, and upload. The contractors who treat this as a 30-minute hygiene task will keep their catalogs flowing. The ones who ignore the banner will discover, mid-Q3 selling season, that they cannot publish a price update.