GSA Proposes “American AI” Clause for All Schedule Contracts
Date: March 6, 2026
Details: GSA introduced a surprising proposed GSAR clause (GSAR 552.239-7001) that would mandate the use of only “American AI Systems” in the performance of GSA Schedule orders. It requires contractors to disclose all AI used, enable human oversight, and report incidents within 72 hours.
Why It Matters: This represents a massive shift toward domestic-only AI procurement. Contractors must begin inventorying AI use (direct and indirect) and prepare to renegotiate terms with “Service Providers” to ensure “Unbiased AI Principles” and data segregation are met. Comments are due by March 20, 2026.
UPDATE: GSA Extends Deadline for “American AI” Clause in MAS Refresh 32
Explanation: In response to significant industry pushback, the GSA has extended the comment period for the proposed AI Clause (GSAR 552.239-7001) to April 3, 2026. This clause, which mandates strict “American-made” requirements and broad government data rights for AI, will now be deferred from Refresh 31 to Refresh 32.
Why It Matters: This gives firms an extra window to assess their AI supply chains. However, Refresh 31 (launching in late March/April) still moves forward with a mandatory Transactional Data Reporting (TDR) expansion for 112 additional SINs, effectively ending the legacy “Price Reductions Clause” for most services.
