Does TDR apply to me now?
If you hold a MAS contract, the answer is yes. MAS Solicitation Refresh 31 made Transactional Data Reporting mandatory across all MAS Special Item Numbers. It reaches your contract through system-generated mass modification A909, and the date you accept decides the month your first report is owed.
Why this is new
Until Refresh 31, TDR was a choice. A contractor weighed TDR against Commercial Sales Practices and the Price Reduction Clause and picked one. That decision no longer exists. Roughly 112 service SINs that were exempt are now inside the requirement, and many of the contractors holding them have never filed a monthly transactional report.
If you have been reading about TDR as an option you might take, that reading is out of date. The question now is not whether, it is from which month.
From which month
Reporting starts on the first day of the sales reporting quarter after you accept the TDR modification. Not the day you accept, and not the start of the next month.
| Accepted | Reporting starts | First monthly report covers | Due |
|---|---|---|---|
| on or before 30 June 2026 | 1 July 2026 | July 2026 | 30 August 2026 |
| 1 July – 30 September 2026 | 1 October 2026 | October 2026 | 30 November 2026 |
| 1 October – 31 December 2026 | 1 January 2027 | January 2027 | 2 March 2027 |
Two consequences follow from that table. Accepting late does not shorten what you owe, it only moves the start. And a contractor who accepts in the fourth quarter of 2026 begins reporting on 1 January 2027 — the day the grace period is already over.
The grace period does not move with you
GSA is not acting on good-faith errors in required data fields through 31 December 2026. That end date is fixed. It does not shift because your own start date shifted to 1 October 2026 or later. From 01 January 2027 compliance is a matter your Contracting Officer acts on, and the instruments are option exercise and contract continuation rather than a fine.
So the later you accept, the less grace period you actually get. A contractor starting on 1 January 2027 gets none of it.
What changes on 01 January 2027 →
What to do, in order
- Read your own mass mod. The acceptance window is stated in the modification GSA sent you; do not take a number off a blog, including this one.
- Accept A909, then accept the Participate in TDR modification that follows it.
- Work out your start quarter from the table above and write down the first month you owe.
- Check whether your invoice export can actually produce the required fields. Several of them are new, and no ERP export has them by default — which fields, and what to do about them.
- File every month from your start date, including months with no sales.
What does not change
The deadline is the same as it always was: 30 calendar days after the last day of the reporting month, twelve times a year. The file format is the same FAS SRP Excel template. The Industrial Funding Fee is still 0.75%, still quarterly, still separate from the monthly report.
Check your own file. Upload your invoice export or a template you have filled in. You get every error and the finished official file, free and without an account.
Open the free validator Then $79/month if you want it to remember everything.Read from GSA's published Refresh 31 material and MAS-TDR guidance, checked 2026-08-17. Acceptance windows and effective dates differ per contract — confirm against your own modification and your Contracting Officer.