GSAR Case 2026-G501 moves Federal Supply Schedule ordering procedures out of FAR subpart 8.4 and into a new GSAR subpart 538.71, organized by order dollar value instead of order type. It is a proposed rule, docket GSA-GSAR-2026-0563, and comments close October 22, 2026. Nothing changes for your orders until GSA issues a final rule.
What is GSAR Case 2026-G501, and when are comments due?
It is GSA's proposed rule, published September 22, 2026 at 91 FR 60063, that relocates Schedule ordering procedures from the FAR to the GSA Acquisition Regulation (GSAR). The comment deadline is October 22, 2026. As of September 30, the Federal Register page shows no extension and only two posted comments.
| Item | Detail |
|---|---|
| Case number | GSAR Case 2026-G501 |
| Docket | GSA-GSAR-2026-0563 |
| Citation | 91 FR 60063 (FR Doc. 2026-19331), RIN 3090-AL13 |
| Published | September 22, 2026 |
| Comments close | October 22, 2026 |
| New home | 48 CFR subpart 538.71, Federal Supply Schedule Ordering Procedures |
| Status | Proposed. Current FAR subpart 8.4 still governs orders. |
Read the primary text on the Federal Register notice for GSAR Case 2026-G501. GSA says it cuts Schedule ordering guidance from over 10,000 words to roughly 2,600.
How does GSAR Case 2026-G501 relate to FAR Case 2026-003?
They are two halves of one move. FAR Case 2026-003 rewrites FAR Part 8 and pulls Schedule ordering procedures out of it, directing agencies to use GSA's procedures instead. GSAR Case 2026-G501 is where those procedures land. Two separate dockets, two separate deadlines: October 19 for the FAR case, October 22 for the GSAR case.
- FAR Case 2026-003 covers FAR Parts 8, 12, 13, 15, 38, 44, 51, and 52. It deletes the Schedule ordering text from Part 8. I covered that case and how to comment on it in FAR Parts 8 and 38 Are Being Rewritten.
- GSAR Case 2026-G501 writes the replacement ordering rules into GSAR Part 538, where GSA controls them going forward.
- The practical consequence: once final, GSA can change Schedule ordering rules through its own regulation rather than a FAR Council case.
If you comment on only one docket, pick this one. It holds the rules your ordering customers will actually follow.
What are the proposed ordering tiers by dollar value?
There are three tiers: at or below the micro-purchase threshold ($15,000), above it but not above the simplified acquisition threshold ($350,000), and above the SAT. The middle tier splits in two based on whether the requirement is clearly defined and fixed-price. Sole source orders above $15,000 need a written justification.
| Tier (proposed section) | What the ordering activity must do |
|---|---|
| At or below $15,000 (538.7103-2) | Order from any Schedule contractor that can meet the need. No minimum number of sources. Agencies "should attempt to distribute orders." |
| $15,000 to $350,000, clearly defined and fixed-price (538.7103-3(a)) | One of three: post an RFQ on eBuy, send an RFQ to three or more Schedule contractors, or consider reasonably available information from three or more Schedule contractors. GSA's examples: capability-as-a-service, subscriptions, training. |
| $15,000 to $350,000, not clearly defined, involves OLMs, needs an SOW, SOO, or PWS, or not fixed-price (538.7103-3(b)) | Post an RFQ on eBuy or send an RFQ to three or more Schedule contractors. The "reasonably available information" option is not allowed. |
| Above $350,000 (538.7103-4) | Post on eBuy, or send the RFQ to as many contractors as practicable to reasonably expect three quotes. Fewer than three quotes requires a file explanation. Prompt notice to unsuccessful quoters; if one asks within 3 days on a non-price-only award, a brief explanation is required. |
| Sole source above $15,000 (538.7104-3) | Written justification. Above the SAT it must cite a listed exception and be posted publicly within 14 days of award (30 days for urgency). |
The dollar figures are the FAR 2.101 thresholds, which the acquisition.gov threshold table shows rose to $15,000 and $350,000 on October 1, 2025. The proposed text references the thresholds by name, so future adjustments carry through.
What actually changes compared with FAR 8.405 today?
Less than some industry write-ups suggest. The "consider information from three contractors" path already exists for supplies and fixed-price services without an SOW. The real changes are structure, an eBuy option for SOW-based services under the SAT, explicit relief from source-selection formalities, and a firmer post-award notice rule above the SAT.
| Topic | Current FAR subpart 8.4 | Proposed GSAR subpart 538.71 |
|---|---|---|
| Organization | Split by order type: FAR 8.405-1, 8.405-2, 8.405-3 | One set of rules keyed to dollar value |
| Supplies and fixed-price services, $15K to SAT | Survey three contractors (GSA Advantage, catalogs) or request three quotes | Same concept, plus eBuy posting as an option |
| SOW services, $15K to SAT | RFQ with SOW and evaluation criteria to at least three contractors | eBuy posting or RFQ to three or more |
| Evaluation formalities | Evaluate against stated criteria | No evaluation plan, scoring, or competitive range required; "broad discretion" |
| Unsuccessful quoters above SAT | "Should" notify; explanation on request | "Provide prompt notification"; explanation if requested within 3 days |
| Order-level price and responsibility | Price reasonableness addressed at order level | Not required for items priced on the Schedule; responsibility settled at contract level |
You can check the current language against FAR 8.405-1 on eCFR. As a Contracting Officer placing Schedule orders, what tripped up files most was not competition. It was which section applied: 8.405-1 or 8.405-2. The dollar-based structure removes that fork, a genuine improvement.
What does this mean for eBuy RFQs?
eBuy remains an option at every tier above $15,000 and a requirement at none of them. Above the SAT, an ordering activity can still skip eBuy and send the RFQ directly to selected contractors. If you are not on the buyer's short list, you may never see the requirement.
- Middle-tier services open to eBuy. SOW-based services between $15,000 and $350,000 can be posted to all holders on eBuy instead of three hand-picked firms.
- The silent comparison path. For clearly defined fixed-price buys, a buyer can compare three contractors' published information and award without any RFQ. Your GSA Advantage listing, pricelist, and SIN descriptions become your quote.
When I was a Contracting Specialist, the Schedule holders who won direct-comparison buys were the ones whose catalog text read like an answer to the requirement. Under this rule, that discipline matters more.
How do order-level materials, CTAs, and BPAs change?
OLM rules move from clause GSAR 552.238-115 into the new section 538.7104-2. Contractor team arrangements stay available unless an agency prohibits them. BPA content, duration, and annual review requirements are consolidated in 538.7104-1, and BPAs can outlast the current Schedule term if options cover the gap.
- OLMs (538.7104-2): must not be the primary purpose of the order, must be labeled as OLMs, and require the OLM SIN on your contract. The ordering CO must make a fair and reasonable price determination, which may happen after award but before you buy the OLM.
- Buying from other Schedules (538.7102(e)): contractors may acquire items from other Schedule contracts during performance without separate FAR 8.105 authorization, and those OLMs skip the order-level price determination.
- CTAs (538.7102(d)): two or more Schedule contractors can combine offerings unless the ordering activity prohibits it.
- BPAs (538.7104-1): minimum content spelled out, multiple-award BPAs may be reserved for small business, and orders above the SAT go to all holders or as many as practicable. Annual reviews ask whether BPA OLMs should be added to your Schedule.
If you rely on OLMs, read 538.7104-2 against your current clause. A restructure is exactly where a detail your pricing depends on can drop out.
What does GSAR Case 2026-G501 mean for small business Schedule holders?
Small businesses are most of the program. GSA's own analysis counts about 14,000 active Schedule vendors at the end of FY 2025, roughly 12,400 of them small. Set-asides for orders and BPAs survive, but the rule's lighter process rewards contractors whose Schedule data is easy to compare.
- Set-asides stay. Section 538.7103-1(b)(1) lets agencies set aside orders and BPAs for small businesses. It is permissive, as today.
- FAR Part 19 does not apply by default. Section 538.7102(b) says FAR Parts 5, 6, 14, 15, 16, and 19 do not apply unless otherwise prescribed. Worth a close read, and possibly a comment, if your pipeline depends on set-asides.
- Getting on Schedule is unchanged. This rule governs ordering, not how offers are evaluated.
How do you submit a comment on GSAR Case 2026-G501?
Submit through Regulations.gov on docket GSA-GSAR-2026-0563 by October 22, 2026. Cite "GSAR Case 2026-G501" and put your name and company on any attachment. Comments are posted publicly, so leave out anything proprietary.
- Open the GSA-GSAR-2026-0563 docket on Regulations.gov and select "Comment."
- Name the exact section you are addressing, for example 538.7103-3(a)(3) or 538.7104-2(a)(4).
- State the operational problem: who is affected, at what step.
- Propose replacement text GSA could adopt as written.
- Attach a file if your comment runs long, then check the docket two to three days later to confirm it posted.
Across eighteen years as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy, I saw comments with a section cite and replacement language get worked while general objections got counted. Strong candidates here: a definition of "clearly defined," notice when the no-RFQ path is used, and the OLM restructure.
What should you do now?
- Keep following FAR subpart 8.4. The GSAR rule is proposed only.
- Calendar two deadlines: FAR Case 2026-003 on October 19 and GSAR Case 2026-G501 on October 22.
- Audit your GSA Advantage listing, pricelist, and SIN descriptions as if a buyer will compare you without asking for a quote.
- Tighten eBuy monitoring for your SINs, especially SOW-based services under $350,000.
- If you use OLMs or run BPAs, compare your current terms against proposed 538.7104-1 and 538.7104-2.
- Submit one focused comment with a section citation and replacement text.
I hold a FAC-C Level III, a Harvard Master of Liberal Arts, and 70+ GSA contract awards, and the pattern holds across all of them: a Schedule only earns when buyers can find and compare it. If you want your catalog, pricing, and eBuy process ready before these rules take effect, our GSA Schedule maintenance program keeps your contract current and competitive through changes like this one.
Frequently Asked Questions
What is GSAR Case 2026-G501?
GSAR Case 2026-G501 is a GSA proposed rule published September 22, 2026 at 91 FR 60063. It moves Federal Supply Schedule ordering procedures from FAR subpart 8.4 into a new GSAR subpart 538.71 and reorganizes them by order dollar value. It is not yet in effect.
When is the comment deadline for GSAR Case 2026-G501?
Comments are due October 22, 2026, through Regulations.gov on docket GSA-GSAR-2026-0563. As of September 30, 2026, no extension had been announced. The related FAR Case 2026-003 closes earlier, on October 19, 2026.
Can an agency place a Schedule order above $15,000 without issuing an RFQ?
Under the proposed rule, yes, for clearly defined fixed-price requirements up to the simplified acquisition threshold of $350,000. The agency may instead consider reasonably available information from three or more Schedule contractors. Current FAR 8.405-1 already allows a similar survey for supplies and fixed-price services without a statement of work.
Is eBuy posting mandatory above the simplified acquisition threshold?
No. Above $350,000 the ordering activity may post on eBuy or send the RFQ to as many Schedule contractors as practicable to reasonably expect three quotes. If fewer than three quotes arrive, the file must explain why.
Can agencies still set aside Schedule orders for small businesses?
Yes. Proposed 538.7103-1(b)(1) allows agencies to set aside orders and establish BPAs with small business concerns, and 538.7104-1 allows reserving multiple-award BPAs for small businesses. Both provisions are permissive, not mandatory.
What happens to order-level materials under the proposed rule?
OLM requirements move from GSAR clause 552.238-115 into GSAR 538.7104-2. OLMs still cannot be the primary purpose of an order, must be labeled as OLMs, and require the OLM SIN on the contractor's Schedule. The fair and reasonable price determination may be made after award but before the contractor acquires the OLM.