Contract terms
GSA AI clause 552.239-7001
Review the issued text and the procurement it applies to.
What GSA issued
GSA issued clause 552.239-7001 through class deviation RGO-2026-01 and released its final language on October 13, 2026. The effective date is October 19, 2026, and GSA plans to add the clause to Multiple Award Schedule contracts in Refresh 34, scheduled for November 6, 2026. Formal rulemaking will follow.
Who it reaches
The clause applies when the government buys LLM functionality as a material feature, including LLM-enabled document and productivity tools, and Government Data goes into or comes out of the LLM. Unless the contracting officer identifies otherwise, it is self-deleting for contractor-internal LLM systems not delivered to or accessed by the government. Check the clause on the actual contract. Where it applies, expect subcontractor due diligence and flowdown, notice to the contracting officer within 72 hours of a material violation, and documented proof of compliance.
Prepare before the modification arrives
If you deliver LLM functionality to a GSA customer, list each model, provider and subcontractor involved, and confirm who can attest to what. Your contracts lead or counsel confirms the clause version and scope for each contract.
Reviewed October 17, 2026. Recheck before relying on a finding.
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