GSA Contract Compliance Checklist: 12 Rules You Must Follow

Holding a GSA Schedule is not a one-time achievement — it creates ongoing compliance obligations that persist for up to 20 years. The Schedule holders who generate the most federal revenue are also the ones who take compliance most seriously, because compliance failures create audit exposure, financial liability, and in serious cases, contract termination. Here are the 12 rules every Schedule holder must follow.

The 12 Compliance Rules Every Schedule Holder Must Follow

1. File quarterly 72A sales reports. Due within 30 days after each quarter ends (April 30, July 30, October 30, January 30). Report all GSA Schedule sales through 72a.gsa.gov. Zero-sales quarters still require a report. Missing a report deadline triggers late fees and compliance notices.

2. Remit the IFF with each 72A report. 0.75% of all quarterly GSA sales is due with each report. Calculate the IFF before filing and submit payment simultaneously. The IFF is not remitted separately — it goes through the 72A reporting portal.

3. Maintain active SAM.gov registration. Renew annually before your registration expires. Set a calendar reminder 60 days ahead. Expired registration suspends payment eligibility and can prevent new orders. Check your expiration date at sam.gov quarterly.

4. Comply with the Price Reduction Clause. Notify your CO within 15 days any time you offer your MFC class prices lower than your current GSA prices. This is an absolute requirement — no exceptions for small discounts, one-time promotions, or accidental discounts.

5. Maintain TAA compliance for all products. Products on your Schedule must continue to be manufactured in or substantially transformed in TAA-designated countries. If your supplier changes manufacturing location to a non-compliant country, you must remove those products from your Schedule immediately. Selling non-TAA-compliant products on your Schedule is a contract violation.

6. Keep your GSA Advantage! pricelist current. Your catalog listing must match your actual contract pricing. If you add products, adjust prices, or discontinue items, update your pricelist through an eMod modification. Selling items not on your pricelist, or at prices that do not match your Schedule, is a compliance violation.

7. Process modifications through eMod for contract changes. Adding SINs, adjusting prices, adding or deleting products, and updating terms all require formal contract modifications. Do not make changes to what you offer on the Schedule without the corresponding eMod. Unauthorized changes are a compliance risk.

8. Submit subcontracting reports (large businesses, orders over $750K). If you are a large business on contracts over $750,000, file Individual Subcontract Reports (ISR) and Summary Subcontract Reports (SSR) through eSRS on schedule. Missed reports are a compliance finding.

9. Maintain your CPARS records and past performance. Agencies submit CPARS evaluations for your federal contract performance. Review each evaluation when notified. You have 60 days to submit a contractor comment if you disagree. Poor CPARS evaluations follow your record and affect future evaluations — address inaccuracies promptly.

10. Honor the contract scope. Only offer products and services covered by your active SINs. Do not accept orders for requirements outside your Schedule scope and bill them as Schedule orders. Out-of-scope work must be pursued through separate contracting mechanisms.

11. Maintain accurate business information. Company name changes, address changes, ownership changes, and banking changes must be updated in both SAM.gov and through GSA. Ownership changes significant enough to constitute a novation require a formal novation agreement.

12. Cooperate with GSA review visits and audits. GSA's Industrial Operations Analysts (IOAs) conduct periodic Schedule reviews. Provide requested documentation promptly. If an IOA identifies compliance issues, respond to corrective action requests within the specified timeframe.

GSA program details verified against GSA.gov and FAI.gov as of March 2026. Requirements, fees, and thresholds change — confirm current details at gsa.gov before submitting your application.