The Revolutionary GSAR Overhaul, decoded: what it means for your GSA Schedule
GSA is rewriting its own rulebook, the GSAR, to match the FAR overhaul. Can't decipher it? What it is, how it reaches your contract, and what to do now.
The short answer: The Revolutionary GSAR Overhaul (RGO) is GSA's rewrite of its own acquisition rules, the GSAR, to match the government-wide FAR overhaul. For GSA Schedule (MAS) contractors, it means fewer and renamed clauses, some new ones, and changes that arrive through the mass modifications you accept, with the next big one (Refresh 34) expected in November 2026. Your day-to-day work (monthly reporting, eMod, accepting mass mods) stays the same.
The three rulebooks, in one minute
FAR (Federal Acquisition Regulation): the government-wide buying rules for every agency.
GSAR (GSA Acquisition Regulation): GSA's own binding add-on to the FAR, including the Schedule rules in Part 538. It applies to GSA contracts, including your MAS contract.
GSAM and the GSA Acquisition Handbook: GSA's internal guidance for its staff. The non-binding guidance is moving into a new handbook.
What happened, step by step
April 15, 2025: Executive Order 14275 calls for a rewrite of the FAR. The effort is called the Revolutionary FAR Overhaul (RFO).
November 3, 2025: GSA's first FAR overhaul changes take effect for Schedules. FAR Part 38 is removed, and the Schedule ordering rules move from FAR 8.4 into GSA's own rules (GSAR Subpart 538.71). Our earlier guide covers this.
January 15, 2026: GSA issues memo RGO-2026-01 and starts the Revolutionary GSAR Overhaul, rewriting the GSAR in "waves."
2026: GSA releases the waves part by part. The wave that covers the Schedule rules (Part 538) is called "Wave 4."
September 2026: the FAR Council and GSA publish proposed rules to make these changes permanent. Comments closed in October.
November 2026 (expected): MAS Refresh 34 brings the Part 538 changes into Schedule contracts.
Two ideas that clear up most of the confusion
1. A "deviation" is temporary. A "final rule" is permanent. GSA is using class deviations so it can work from the new text now, while the formal rules go through the slower rulemaking process. That's why some official rule websites still show the old text. For your contract, what counts is what's in your contract, which brings us to point 2.
2. Changes reach your contract through mass modifications. The rules don't rewrite your contract on their own. GSA updates the MAS solicitation through a "refresh," then sends existing contract holders a mass modification to accept. Refresh 30 (November 2025) brought in the first overhaul changes. Refresh 34 is next.
What's changing for Schedule contractors
Based on GSA's draft for Refresh 34 (the final version can differ):
Fewer clauses. The draft deletes 41 GSAR provisions and clauses and 8 Schedule-specific clauses.
Five new combined clauses:
552.238-190, Team Arrangements
552.238-191, Contract Requirements
552.238-192, Order-level Requirements
552.238-193, Product Offering and Sales Requirements
552.238-194, Sales Criteria
No more 20-year limit. The draft removes the 20-year cap on how long a MAS contract can run.
New numbers for the price adjustment clause. Under the overhaul, Schedule contracts use 552.216-90, Economic Price Adjustment, Alternate I. It used to be 552.238-120, and before that 552.216-70.
A new AI clause (552.239-7001) is in the draft.
What stays:
monthly Transactional Data Reporting (552.238-80)
requesting your own changes through a modification (552.238-82)
the option to extend your contract
the catalog and pricing data clause
Ordering rules (how agencies buy from you, including BPAs) are not part of this wave. They changed in November 2025 and are still going through rulemaking.
Why the clause numbers keep changing
The content is moving, not disappearing:
The ordering rules moved from FAR 8.4 to GSAR 538.71.
The price adjustment clause moved from 552.216-70 to 552.238-120 to 552.216-90 Alternate I.
Many Schedule clauses are being merged into the new 552.238-190 to -194.
If your team's checklists cite old numbers, they may point to rules that have moved.
What you need to do now
Accept your mass mods. GSA won't approve your other modifications while a mass mod is overdue.
Check your Authorized Negotiators. Only they can sign mass mods. GSA recommends at least two, with at least one a company employee. You update them through eMod.
Make sure your eMod and FAS ID sign-ins work before Refresh 34 arrives.
Read the final Refresh 34 notice before you accept. Compare it with the draft; GSA has said the final may change.
Update your internal checklists that cite FAR Part 38, FAR 8.4 or old clause numbers.
Keep reporting monthly. Nothing in the overhaul pauses Transactional Data Reporting.
Keeping up with GSA's rule changes, and showing what each one means for your contract, is part of what AcqVerity is built for: a step-by-step tool for preparing your own GSA contract changes. We're opening a small early-access group; join the list at AcqVerity.com.
This guide is general information from public sources, including GSA's RGO-2026-01 memo and the draft Refresh 34 notice, as of October 2026. It is not legal or contracting advice. Draft and proposed rules can change. Your contract terms, GSA and your Contracting Officer decide. AcqVerity Technologies LLC is not affiliated with GSA.