How to Write a GSA Commercial Sales Practices Disclosure

How to Write a GSA Commercial Sales Practices (CSP) Disclosure

The Commercial Sales Practices (CSP) disclosure is a critical element of your GSA Schedule offer and your ongoing contract compliance. It documents the pricing you give to your most favored commercial customer — the foundation upon which GSA negotiates your Schedule pricing and monitors the Price Reduction Clause. An inaccurate or incomplete CSP creates compliance risk throughout your contract period. Getting it right at the time of offer is significantly easier than correcting it later.

What the CSP Discloses

The CSP form requires you to disclose: your standard commercial price list (your published "list price"), the discounts you offer to different customer categories, the identification of your "basis of award" (BOA) customer — the single customer or category receiving your best pricing — and the specific discount level given to that BOA customer. You must also disclose any special pricing arrangements that deviate from your standard commercial terms, including volume discounts, prompt payment discounts, or special customer arrangements.

Identifying Your Basis of Award Customer

The BOA customer is the commercial buyer who receives your best effective pricing. This could be a specific named customer, a customer category (e.g., "Fortune 500 companies"), or a customer segment (e.g., "volume purchasers over $500,000 annually"). Be precise in your BOA identification — vague descriptions like "our largest customer" create audit risk. If multiple customers receive equivalent "best pricing," describe the category accurately. The GSA Schedule will be priced at or better than this BOA discount, and the Price Reduction Clause tracks changes to this relationship.

Common CSP Errors and How to Avoid Them

The most common CSP errors are: identifying the wrong BOA customer (underestimating actual best discounts), failing to disclose special pricing arrangements (assuming they are not relevant), and using inconsistent pricing documentation (submitted prices don't match the invoices GSA can verify during an audit). Review your commercial invoices for the prior 12 months before completing the CSP. Identify your actual best customer and their effective pricing. If you are unsure whether certain discounts should be disclosed, err on the side of disclosure — omissions are worse than over-inclusion.

Facts in this article verified against GSA.gov and FAI.gov as of March 2026. GSA program requirements are updated periodically — always confirm details directly with GSA or your contracting officer.