Federal News
GSA Delays AI Procurement Clause Rollout
March 24, 2026
The General Services Administration (GSA) has postponed the implementation of its proposed artificial intelligence (AI) acquisition clause for the Multiple Award Schedule (MAS) Refresh 31, extending the public comment period to April 3, 2026. This draft clause, designated as 552.239-7001, introduces comprehensive new requirements for contractors providing AI systems or incorporating AI in contract performance, including government ownership of data, restrictions on foreign AI components, and adherence to "American AI" principles. Industry stakeholders, represented by groups such as the Professional Services Council, have raised concerns about the clause's broad scope, immediate enforcement without a phase-in period, and potential impacts on innovation and competition. The delay reflects GSA's response to these concerns and signals a significant shift in federal AI procurement policies that will affect contractors across multiple sectors.
- Why this matters: Contractors on GSA Schedules must prepare for substantial compliance obligations related to AI, including data licensing, disclosure, and government rights, which may require contract renegotiations and operational adjustments.
- The clause's emphasis on domestic AI products aligns with federal policy priorities, potentially affecting supply chain decisions and vendor eligibility.
- Procurement professionals should engage in the extended comment period to influence final clause terms and assess impacts on existing and future AI-related contracts.
- Organizations should evaluate their AI offerings and subcontractor relationships for compliance readiness and consider legal counsel guidance on liability and contract terms under the new clause.
GSA’s proposed AI Clause would impose significant compliance requirements on contractors that are either directly providing AI systems to the Government or using AI systems in the performance of a government contract.
— Tracye Winfrey Howard, Partner at Wiley Rein LLP
The draft is "a huge policy in an emerging area of the law that’s going to be extremely consequential."
— Jessica Tillipman, Associate Dean at George Washington University
The clause requires immediate implementation with no phase-in period, posing challenges for contractors with existing AI agreements.
— Dan Ramish, Partner at Haynes Boone
Agencies
General Services Administration, Office of Management and Budget, Department of Defense, Department of Transportation, Federal Aviation Administration
Vendors
AWS, GDIT, Mantech, Maximus, SAIC
Contracts
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Locations
Sources
- GSA extends comments on sweeping AI clause after industry pushback | FedScoop · FedScoop · Mar 23
- GSA’s new AI clause drives contractors to sound the alarm | Federal News Network · Federal News Network · Mar 24
- As GSA prepares its next Schedule refresh, contractors are weighing how AI fits into rules that weren’t built for it | Federal News Network · Federal News Network · Mar 24
- Contractors weigh in on how AI fits into GSA rules that weren’t built for it | Federal News Network · Federal News Network · Mar 24
- GSA Delays Rollout of AI Procurement Terms and Conditions, Extends Comment Period to April 3: Wiley · Wiley Rein · Mar 24