// Data report · 2026

The State of GSA TDR Data Quality in 2026

TDR is now mandatory for every MAS SIN. GSA's own watchdog says the data it collects is largely unusable. Both are true — and the gap between them is where your compliance risk lives.

The number GSA doesn't put on a slide

In a June 2025 alert memorandum, GSA's Office of Inspector General reported that roughly 73% of the sales data reported under Transactional Data Reporting in FY2025 could not be used for meaningful price analysis. It wasn't a one-off: the OIG's earlier review of the TDR pilot found 87% of FY2022 reported sales similarly unusable. And all 23 contracting officers the OIG interviewed said they had never used TDR data in a price negotiation.^[1]

Read that plainly: the government is collecting a monthly data feed that its own buyers don't use and its own auditors can't clean.

So why is it mandatory now?

Refresh 31 (April 2, 2026) made TDR mandatory for every MAS SIN and, in the same stroke, eliminated the Price Reductions Clause and the CSP-1 disclosure — the mechanisms that historically drove pricing-compliance enforcement.^[2] GSA's bet is that a broad transactional feed will, over time, replace the old most-favored-customer machinery. Whether the data ever becomes usable is GSA's problem to solve.

GSA may not read your TDR data for price analysis. But an Industrial Operations Analyst still reads you.

What the data-quality problem means for your contract

Here's the trap: because the aggregate data is noisy, it's easy to assume your individual submission doesn't matter. It does — just not where you'd expect. The Sales Reporting Portal validates your file's format and, post-acclimation, hard-rejects malformed lines. What it will never flag is whether your IFF math is right, whether a line carries TAA or country-of-origin exposure, whether you've crossed the $100K / $125K thresholds, or whether a clause or modification applies to your contract.

Those are exactly the questions a Contractor Assessment Visit asks. TDR accuracy feeds your standing at an IOA review, your option-year exercise, and — if it's wrong enough, often enough — your contract's continuation. The enforcement hammer changed shape after Refresh 31; it didn't disappear.

What to do about it

Treat the SRP as your system of record, not your compliance check. Before you submit each month, verify the layer the portal doesn't: IFF accuracy per period, TAA and country-of-origin, thresholds and SIN mapping, clause applicability, and a defensible audit trail you can hand an IOA. That's the difference between "GSA accepted my file" and "I'm compliant." See the two layers, side by side →

Sources. [1] GSA Office of Inspector General, Alert Memorandum A140143-4 (June 27, 2025). [2] Refresh 31 analysis — Holland & Knight, "Goodbye PRC, Hello TDR." Figures describe TDR data usability in aggregate for GSA price analysis; they are not compliance findings against any individual contractor.

Check the compliance layer before you submit.

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