FY2027 started October 1, 2026 under a continuing resolution that runs only through December 11, 2026. That means a slow, cautious first quarter, and it also means your contract work has to be finished before agencies get full-year money. Accept the Refresh #33 mass mod, clean up your TDR reporting before January 1, 2027, and confirm SAM.gov, FCP, and your option dates now.
This follows our FY 2026 checklist, whose basics still apply. Below is only what is new this year, from 18 years as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy.
Where do FY2027 appropriations stand as of October 2026?
No full-year FY2027 appropriations bill has been enacted. Agencies are running on the Continuing Appropriations and Extensions Act, 2027 (H.R. 6500, P.L. 119-103), signed September 2, 2026. It funds operations at FY2026 levels from October 1 through December 11, 2026. Congress must pass full-year bills or another CR by then to avoid a funding gap on December 12.
| Item | Status |
|---|---|
| Funding vehicle | Continuing resolution, Division A of P.L. 119-103 |
| Signed into law | September 2, 2026 |
| Coverage | October 1 to December 11, 2026 (72 days) |
| Funding rate | Continues operations based on FY2026 levels (Sec. 101) |
| DoD limits | No new starts (Sec. 102(a)(3)); no production rate increases above FY2026 (Sec. 102(a)(2)) |
| Full-year bills | None of the 12 enacted |
Sources: H.R. 6500 on Congress.gov, the White House signing statement, and CRS report R49353. December 11 falls after the November 3 midterm elections, so expect final FY27 numbers to be negotiated in a lame-duck session at the earliest. For where the request itself points, see our FY2027 budget request breakdown.
What does a continuing resolution mean for Q1 Schedule orders?
Under a CR, agencies can keep existing work funded but hesitate to start anything new. Expect renewals, option exercises, and recurring buys to keep moving, while new requirements slide toward the second quarter. Use October through December to win positioning, not to count on new obligations.
- Recurring and incumbent work moves first. Option exercises and follow-on orders for existing requirements are the easiest actions to fund at prior-year rates.
- New requirements wait. DoD is expressly barred from new starts under the CR. Civilian program offices tend to behave the same way even without a statutory bar.
- Funding-contingent awards appear. Some COs will award with FAR 52.232-18, Availability of Funds, which means no government liability until funds are made available and confirmed in writing.
When I sat on the other side of the desk as a Contracting Officer, a CR quarter was when I did my market research and drafted requirements packages so they were ready the day full-year money landed. Contractors with clean pricing and current SINs caught that wave. If a lapse does happen on December 12, our shutdown guide covers stop-work orders and invoicing.
When do you have to accept the Refresh #33 mass modification?
GSA issued MAS Refresh #33 in early October 2026, and the mass modification must be accepted no later than 90 days after GSA issues it. If your mod is dated October 2, 2026, day 90 is December 31, 2026. Check the date on your own mod in eMod and calendar the deadline now.
- Log in to eMod and open the pending mass modification for Refresh #33.
- Read the significant changes document before signing, especially the new supply chain risk management provision and clause, FASt Lane expansion, and the product substitution language.
- If you sell products, note Class Deviation CD-2026-03, which removes the Trade Agreements Act exemption for Federal Prison Industries and AbilityOne participating nonprofits.
- If you hold SIN 517312 Wireless Mobility Solutions, review the three new subgroups. Placement is by request and GSA technical review, not automatic.
- Sign with the digital certificate of an authorized negotiator.
The new terms apply to orders and BPA calls issued after the mod's effective date. Orders already awarded stay under their original terms. See our Refresh #33 mass mod guide. As a Contracting Specialist, I saw unaccepted mass mods hold up later actions on the same contract far more often than contractors expected. Accept it before you file anything else.
What changes for TDR on January 1, 2027?
The MAS Transactional Data Reporting grace and trial periods run July 1 through December 31, 2026. Beginning with the reporting period effective January 1, 2027, compliance becomes subject to Contracting Officer enforcement. You have one quarter left to fix data errors without consequence.
| Requirement | Rule |
|---|---|
| Reporting clause | GSAR 552.238-80, Industrial Funding Fee and Sales Reporting, Alternate I |
| Report due | Within 30 calendar days after the end of each month |
| Zero-sales months | Must still be reported |
| Industrial Funding Fee (IFF) | Remitted quarterly; monthly payment is optional |
| Grace period ends | December 31, 2026, regardless of when you accepted mass mod A909 |
Treat October through December reports as dress rehearsals and clear any soft flags. GSA's Help with TDR page lists the data fields, and our TDR grace period post explains who falls under which window.
Is your FCP Catalog Baseline blocking FY27 pricing changes?
It might be. Once your contract moves to the FAS Catalog Platform, you cannot submit new catalog-related modifications until the First Steps process is complete, and you have 60 days from system access to start the baseline. A stalled baseline freezes the pricing and SIN changes you want in place before Q2.
- Check status in the system, not your inbox. Authorized negotiators receive 28, 14, and 7 day notices, but the platform is authoritative.
- Services contractors: build the Services Plus File from your last awarded Price Proposal Template, then remove those items from your T&C file, per the Vendor Support Center FCP page.
Our posts on FCP invitation waves and the baseline freeze cover the sequencing.
Is your SAM.gov registration ready for the new fiscal year?
FAR 52.204-13 requires you to stay registered in SAM.gov through final payment and to review and update your record at least annually. FAR 4.1201 makes your representations and certifications effective for one year. A lapse or a bad size representation can cost you a Q1 set-aside order.
- Expiration date: renew well before it, since registration must be active at award.
- FAR 52.219-1 NAICS table: if you renewed between March 24 and July 22, 2026, check for N/A values caused by the SAM.gov size representation glitch.
Pull your entity record at SAM.gov first.
Where are you in your option period, and does your CPARS record support it?
MAS contracts run a five-year base and three five-year options. Under GSAR 552.217-71, the Contracting Officer considers the quality of your past performance when deciding whether to exercise an option. If your current period ends in FY27, your sales, compliance, and performance record are being read now.
- Find your period end date on your latest award or option modification.
- Clean up open items: unaccepted mass mods, late TDR or IFF, and stale catalogs are what a CO sees first.
- Review CPARS: FAR 42.1502(c) requires agencies to evaluate orders over the simplified acquisition threshold placed under Federal Supply Schedule contracts. Read and respond to evaluations at CPARS.gov within the comment window.
What the regulation says is that past performance informs the option decision. How a CO actually reviews it is simpler: a contract with no sales, open compliance items, and unanswered emails is hard to justify extending. Our option period service exists for this window. Weak evaluations also hurt in competitions; see our CPARS screening post.
Should you file an Economic Price Adjustment before FY27 buying picks up?
If your costs rose, yes, but only through the EPA method in your contract. GSAR 552.238-120 requires requests to conform to the agreed method, and approved adjustments apply only to orders issued on or after the modification's effective date. Increases do not touch orders already awarded.
- Confirm which EPA method your contract states, such as established commercial pricing or a market index.
- Gather support that matches that method. The CO may use independent market research to accept, reject, or counter.
- Check that the FCP baseline is not blocking catalog changes before you submit.
An increase approved in November is in place when Q2 orders flow.
What should you update in GSA Advantage, eBuy, and your contract contacts?
GSAR 552.238-88 requires you to participate in GSA Advantage, and buyers judge you by what they see there. Before agencies get full-year funding, make your catalog, eBuy notifications, and contract points of contact accurate and reachable.
- GSA Advantage: current prices, descriptions, and no discontinued items.
- eBuy: confirm RFQ notifications reach someone who reads them daily.
- Contract contacts: update administrative and authorized negotiator contacts through eMod.
- Digital certificate: confirm it has not expired.
Which FY27 dates belong on your calendar?
Five Q1 dates matter to every MAS contractor. Put each on a shared calendar with a named owner, because a deadline nobody owns is a deadline that gets missed.
| Date | Event | Action |
|---|---|---|
| October 22, 2026 | OCAS first FY27 pipeline review | Register on GSA Interact; see our OCAS post |
| December 11, 2026 | CR expires | Watch for full-year bills or another CR |
| 90 days after issuance | Refresh #33 acceptance deadline | December 31 if your mod is dated October 2 |
| December 31, 2026 | TDR grace and trial periods end | Final clean report cycle |
| January 1, 2027 | TDR enforcement begins | CO enforcement applies to reports from this period |
What should you do now?
- Accept the Refresh #33 mass mod in eMod and calendar day 90 from your mod's date.
- Run your October through December TDR reports as a full rehearsal for January 1, 2027 enforcement.
- Check FCP status in the platform and finish the baseline before you need a pricing or SIN change.
- Pull your SAM.gov record and fix any N/A size representations.
- Confirm your option period end date and respond to every open CPARS evaluation.
Across our 70+ GSA contract awards and more than 200 MAS contract holders supported after award, the contractors who win in Q2 are the ones who cleaned house in Q1. If you want a former Contracting Officer to run this checklist on your contract every month, look at our GSA Schedule maintenance program.
Frequently Asked Questions
Is the federal government funded for FY2027?
Only temporarily. The Continuing Appropriations and Extensions Act, 2027 (P.L. 119-103), signed September 2, 2026, funds agencies from October 1 through December 11, 2026 at FY2026-based levels. None of the 12 full-year FY2027 appropriations bills has been enacted.
Can agencies still place GSA Schedule orders under a continuing resolution?
Yes. Agencies can obligate funds under a CR for continuing operations, so renewals, option exercises, and recurring buys usually continue. New requirements are often delayed, and DoD is barred from new starts under the FY2027 CR.
How long do I have to accept the MAS Refresh #33 mass modification?
You must accept it no later than 90 days after GSA issues it. If your mod is dated October 2, 2026, that is December 31, 2026. Check the issue date on your own mod in eMod.
When does GSA start enforcing TDR compliance?
The MAS TDR grace and trial periods end December 31, 2026. Starting with the reporting period effective January 1, 2027, compliance is subject to enforcement by the Contracting Officer.
Can I submit a price increase during my FCP Catalog Baseline?
Generally no. Once your contract moves to the FAS Catalog Platform, you cannot submit new catalog-related modifications until First Steps is complete. Finish the baseline first, then file the Economic Price Adjustment under GSAR 552.238-120.
How often do I need to update my SAM.gov registration?
At least annually. FAR 52.204-13 requires you to review and update your SAM.gov information every year and stay registered through final payment, and FAR 4.1201 makes representations and certifications effective for one year.
Does past performance affect whether GSA exercises my MAS option?
Yes. GSAR 552.217-71 states that the Contracting Officer will consider the quality of your past performance when deciding whether to exercise an option.