What is GSA Compliance? (+ Checklist for 2025)
Staying compliant with GSA requirements isn’t just about following rules; it’s about protecting your federal contracting business and maximizing opportunities. Many contractors find themselves overwhelmed by GSA compliance requirements that seem to change constantly.
In this guide, we’ll walk through what GSA compliance really means in practical terms and provide a usable checklist to keep your contract in good standing through 2025.
What is GSA Compliance?
GSA compliance refers to meeting all the rules, regulations, and contractual obligations established by the General Services Administration for contractors who hold a GSA Multiple Award Schedule (MAS) contract.
These requirements cover pricing policies, reporting obligations, documentation standards, and ethical practices that contractors must follow throughout the life of their contract.
- Contract validity: Non-compliance can lead to contract cancellation
- Business reputation: Violations can damage your standing with federal agencies
- Financial stability: Penalties for non-compliance can be substantial
- Competitive advantage: Compliant contractors gain more federal opportunities
- Risk management: Proper compliance reduces audit risks and potential legal issues
Key GSA Compliance Requirements
Let’s break down the most critical compliance areas that every GSA contractor needs to understand:
Pricing and Disclosure Requirements
The foundation of GSA compliance rests on transparent and fair pricing. When you applied for your GSA Schedule, you likely submitted Commercial Sales Practices (CSP) disclosures that revealed your pricing structure to commercial customers. The government uses this information to negotiate fair pricing.
Once your contract is awarded, you must maintain the pricing relationship established during negotiations. This means if you offer deeper discounts to your commercial “Basis of Award” customer than what was disclosed, you may need to extend similar discounts to the government under the Price Reduction Clause.
- Commercial Sales Practices (CSP) disclosure
- Price Reduction Clause (PRC) monitoring
- Most Favored Customer (MFC) pricing relationships
- Basis of Award customer tracking
Reporting and Financial Obligations
Every GSA contractor must report their contract sales quarterly through the FAS Sales Reporting Portal. This isn’t just administrative paperwork – it’s tied directly to the Industrial Funding Fee (IFF), currently set at 0.75% of your GSA sales, which funds the operation of the GSA Schedules program.
Missing reporting deadlines or underpaying the IFF can trigger compliance flags in the GSA system. Your accounting systems need to accurately track GSA sales separately from your commercial business. This separation is crucial not only for reporting but also for potential audits down the road.
- Industrial Funding Fee (IFF) payment (currently 0.75% of sales)
- Quarterly sales reporting through the FAS Sales Reporting Portal
- Accurate contract sales tracking systems
Product and Service Requirements
If you sell products through your GSA Schedule, you need to ensure they comply with the Trade Agreements Act (TAA). This means they must be manufactured or “substantially transformed” in the United States or designated countries. Products from non-designated countries like China are generally prohibited.
For service providers, compliance means ensuring that the personnel performing work meet the qualifications and experience levels specified in your contract.
- Trade Agreements Act (TAA) compliance for products
- Approved labor categories and qualifications for services
- Accurate product/service descriptions in all catalogs
Administrative Requirements
Maintaining an active registration in the System for Award Management (SAM.gov) is a fundamental requirement that’s easy to overlook. Your registration must be renewed annually, and any changes to your business information must be updated promptly.
You also need to submit contract modifications for any significant changes to your offerings, pricing, or company information. Selling products or services not properly added to your contract through the modification process is a compliance violation that can have serious consequences.
- System for Award Management (SAM.gov) registration
- Timely contract modifications
- Proper use of GSA logos and marketing practices
- Cybersecurity compliance (FISMA, CMMC where applicable)
- Socioeconomic reporting
GSA Compliance Checklist for 2025
Let’s walk through a practical checklist organized by the stages of your GSA contract journey:
1. Pre-Contract Compliance
Before you even receive your GSA Schedule contract, several compliance measures must be in place:
- Complete and maintain SAM.gov registration
- Prepare accurate Commercial Sales Practices (CSP) disclosure
- Verify all products meet Trade Agreements Act requirements
- Conduct internal pricing analysis to establish discount structure
- Develop compliant marketing materials and digital assets
- Establish systems for tracking GSA sales separately from commercial sales
- Identify your Basis of Award customer(s) for Price Reduction monitoring
2. Post-Award Compliance
Once your GSA Schedule is awarded, immediate compliance actions include:
- Submit accurate product/service data for GSA Advantage
- Set up quarterly calendar reminders for IFF payments
- Configure accounting systems to track GSA sales separately
- Train sales staff on GSA pricing requirements
- Update company website with GSA contract information
- Establish internal contract management responsibilities
- Create a modification request process for contract changes
3. Ongoing Contract Maintenance
Throughout your contract period (up to 20 years), maintain compliance through:
- Conduct quarterly reviews of your commercial pricing vs. GSA pricing
- Ensure you’re not offering deeper discounts to commercial customers than your Basis of Award
- Submit a price reduction modification if required
- Perform internal audits of GSA sales at least annually
- Verify that all products/services sold were on your current contract
- Confirm all labor categories billed met contract qualifications
- Ensure pricing was consistent with contract terms
- Maintain comprehensive GSA transaction records
- Keep quotes, purchase orders, invoices, and delivery confirmations
- Store records for the life of the contract plus three years (recommended)
- Submit contract modifications promptly when needed
- Add new products/services
- Update pricing or discount structures
- Revise contact or business size information
- Never sell unapproved items outside your awarded scope
What Happens If You’re Not Compliant?
Non-compliance with GSA requirements can result in serious consequences:
- Financial penalties: Fines can range from thousands to millions of dollars depending on the violation
- Contract cancellation: GSA can terminate your contract for repeated or serious violations
- Payment suspension: The government may withhold payments until compliance issues are resolved
- Debarment: In severe cases, contractors can be prohibited from future federal contracting
- Legal action: The Department of Justice may pursue False Claims Act cases for pricing violations
- Reputational damage: Non-compliance can harm your standing with all federal agencies
The GSA Office of Inspector General (OIG) actively conducts pre-award, post-award, and claims audits to verify compliance. These audits can be triggered by various factors, including contract size, reported sales volume, or random selection.
Final Thoughts: Stay Ahead of GSA Compliance
GSA compliance isn’t something you achieve once and forget about. It requires ongoing attention and resources. The contractors who succeed in the federal marketplace are those who build compliance into their business processes.
Take a proactive approach by scheduling regular internal reviews rather than waiting for problems to surface. Many successful contractors conduct quarterly compliance checks that mirror what a GSA auditor might look for.
Stay informed about changing GSA regulations. The rules evolve over time, and what was compliant last year might not be this year. Industry associations, GSA webinars, and professional consultants can help you stay current.
Road Map Consulting GSA Services
At Road Map Consulting, we’ve guided hundreds of contractors through the complexities of GSA compliance since 2009. Our approach focuses on making compliance manageable and integrating it into your normal business operations.
Our GSA compliance services include:
