GSA is extending the compliance enforcement window for MAS Transactional Data Reporting (TDR), not the reporting requirement itself. You still must report. The extensions give most contractors a grace period through the reporting period ending December 31, 2026, with enforcement by the Contracting Officer beginning January 1, 2027. Treat the next several months as practice runs — but run them.
Let me be blunt about the part contractors keep misreading: this is an enforcement pause, not a reporting holiday. I spent 18 years across GSA, IRS, DoD, and DOI as a Contracting Specialist and Contracting Officer, and "we thought we had a grace period" is exactly the sentence that precedes a cancellation conversation. Here is who gets which grace period and where the real risk sits.
Does the TDR extension mean you can skip reporting?
No. The extensions change only when compliance is enforced, not whether you report. You must continue submitting TDR reports throughout the grace period. During this window you may receive "soft flags" identifying discrepancies or non-matches, but those are practice feedback — not penalties.
GSA's intent is to let contractors get up to speed on the reporting mechanics and shake out bugs before strict enforcement starts. Use the soft flags. Every flag you clear now is one that will not be an enforcement finding once the Contracting Officer can act on it in 2027.
What is the grace period for contracts transitioning to TDR?
Contracts transitioning to TDR effective October 1, 2025 through July 1, 2026 — and thereafter — get a temporary grace period through the reporting period ending December 31, 2026. Starting with the reporting period effective January 1, 2027, compliance becomes subject to enforcement action by the Contracting Officer.
During the grace period you may receive soft flags for reporting discrepancies or non-matches. Nothing about that softens the January 1, 2027 line — that is when soft flags become hard findings.
What happens if you don't accept mass mod A909?
Contractors who do not accept mass modification A909 by June 2, 2026 face possible contract cancellation at the Contracting Officer's discretion. If your contract is not cancelled and you sign the mod after July 1, 2026, your grace period still ends December 31, 2026 without exception, with enforcement beginning the reporting period starting January 1, 2027.
This is the single highest-risk item in the whole TDR rollout. An unaccepted A909 is not a paperwork gap — it is grounds for cancellation. From the CO seat, a contractor who ignores a mass mod with a stated deadline has handed the CO a clean reason to act. If you have not accepted A909, do it before you read the rest of this.
| Your situation | Grace period | Enforcement starts |
|---|---|---|
| Transitioning to TDR 10/1/2025–7/1/2026+ | Through reporting period ending 12/31/2026 | Reporting period effective 1/1/2027 |
| A909 not accepted by 6/2/2026 | Possible cancellation; if signed after 7/1/2026, grace ends 12/31/2026, no exception | Reporting period starting 1/1/2027 |
| Existing TDR contracts (pre-10/1/2025) | 6-month trial on new data elements from 7/1/2026 | Targeted reporting period beginning 1/1/2027 |
| All contractors — new SRP fields | 6-month trial to implement | End of trial, then CO-enforceable |
What new TDR data fields are in the trial period?
Existing TDR contracts effective before October 1, 2025 enter a temporary trial period for new data elements. Starting July 1, 2026 you must report these during the six-month trial, but you will not be penalized for non-compliance — only soft-flagged for missing or invalid data.
- Ship Date (products only)
- Order Date (products only)
- Zip Code Ship To (all offerings)
- Federal Customer (all offerings)
- UCID (items not listed for click-and-buy)
- Cloud Service Type (SIN 518210C only)
Several of these were previously optional and are now required during the trial. After the trial ends — currently targeted for the reporting period beginning January 1, 2027 — compliance with the new fields becomes enforceable by the Contracting Officer.
Which new fields are not yet available in the FAS SRP?
Three required fields are not yet incorporated in the FAS Sales Reporting Portal (SRP), so all contracts get a separate six-month trial period to implement them once they go live. They are Order Type, Order Discount, and Worksite, each with its own applicability.
- Order Type — all offering types.
- Order Discount — Highly Configurable Products (HCP) and Configurable Services (CS) only.
- Worksite — for required labor-hour rate-breakdown reporting only.
Upon completion of that trial period, compliance with these fields becomes enforceable by the Contracting Officer. Full detail is posted in the MAS Community on GSA Interact.
What Should You Do Now?
- Accept mass mod A909 immediately if you have not — non-acceptance risks cancellation at the CO's discretion.
- Keep reporting every period. The extension pauses enforcement, not reporting.
- Clear every soft flag now, while they carry no penalty.
- Start capturing the new fields — Ship Date, Order Date, Zip Code Ship To, Federal Customer, UCID, and Cloud Service Type — from July 1, 2026.
- Mark January 1, 2027 as the date soft flags become enforceable findings.
TDR mechanics are where good contractors quietly fall out of compliance, because the reporting is detailed and the deadlines stack. Blackfyre's contract management service is $299/month, and right now we are including an Add-SIN modification at no additional cost — a $2,500 value. You get a former GSA Contracting Specialist and Contracting Officer with a Harvard M.S., FAC-C Level III, and 18 years across GSA, IRS, DoD, and DOI keeping your reporting clean before enforcement starts. We have supported 70+ companies across every type of GSA transaction. See the proof of work at Blackfyre.
Frequently Asked Questions
Does the TDR extension mean I can stop reporting?
No. The extension pauses compliance enforcement, not the reporting requirement. You must keep submitting TDR reports every period; during the grace window you may receive soft flags for discrepancies, but they are not penalties.
When does TDR enforcement actually begin?
For most contractors, enforcement by the Contracting Officer begins with the reporting period starting January 1, 2027. The grace period generally runs through the reporting period ending December 31, 2026.
What if I haven't accepted mass mod A909?
Contractors who did not accept A909 by June 2, 2026 face possible contract cancellation at the Contracting Officer's discretion. If not cancelled and you sign after July 1, 2026, the grace period still ends December 31, 2026 without exception.
What new data fields do I have to report?
During the trial, existing TDR contracts must report Ship Date and Order Date (products), Zip Code Ship To and Federal Customer (all offerings), UCID (non click-and-buy items), and Cloud Service Type (SIN 518210C). These are required starting July 1, 2026, with soft flags during the trial.
What are Order Type, Order Discount, and Worksite?
They are new required fields not yet incorporated in the FAS Sales Reporting Portal. Once live, all contracts get a six-month trial to implement them — Order Type for all offerings, Order Discount for HCP and CS, and Worksite for labor-hour rate-breakdown reporting — after which they become CO-enforceable.
What is a soft flag?
A soft flag is GSA identifying a reporting discrepancy, non-match, or missing or invalid data during the grace or trial period without imposing a penalty. It is practice feedback; resolve flags now so they do not become enforcement findings after January 1, 2027.