GSAR 552.239-7001 proposed AI contract clause (GSA): March 2026 draft and June 2026 revised draft (91 FR 36559)

Summary

GSA proposed a new contract clause, GSAR 552.239-7001, for its government-wide contract vehicles. The March 2026 draft would have required contractors to disclose AI systems used in performance, use only 'American AI Systems', support government oversight and report security incidents; after industry requests GSA extended comments from March 20 to April 3, 2026, and kept the clause out of MAS Refresh 31. GSA then published a substantially revised draft in the Federal Register on June 17, 2026 (91 FR 36559), retitled 'Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems', which applies when LLMs process government data, borrows the LLM definition from EO 14319 and keeps a section on the Unbiased AI Principles. Comments were due by August 3, 2026.

Key dates

1. March 6, 2026Issued
2. October 16, 2026Checked against sources
3. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: January 15, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

1. On March 6, 2026, the U.S. General Services Administration (GSA) issued a draft version of a new contract clause, GSAR 552.239-7001

   Supports: Draft clause and date

   Using only "American AI Systems" in contract performance

   Supports: American AI Systems requirement

   The public comment period for this proposed clause has been extended from March 20, 2026 to April 3, 2026 to allow more time for stakeholder feedback.

   Supports: Comment extension

   GSA Proposes New Contract Clause Focused on the Government Use of AI Venable Reporting or analysis

2. Interested parties should submit written comments as noted below on or before August 3, 2026, to be considered in the formation of the final GSAR clause.

   Supports: Revised draft; comment deadline

   The first draft was issued through GSA Interact on January 12, 2026

   Supports: First-draft date per GSA (conflicts with March 6)

   Large Language Model Artificial Intelligence System (LLM) means a generative artificial intelligence model trained on vast, diverse datasets that enable the model to generate natural-language responses to user prompts (Ref. Executive Order 14319 Section 2).

   Supports: Link to EO 14319

   General Services Acquisition Regulation; Acquisition of Information and Communication Technology; Notice of Listening Sessions and Request for Comments Office of the Federal Register (federalregister.gov) Primary source