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The GSA AI Clause Clock Is About to Start: What Schedule Holders Must Do Before Refresh 32 Drops
Bradley – The market has spent six weeks debating whether GSA’s proposed AI clause — GSAR 552.239-7001 — is good policy. That debate is largely over. GSA extended the comment period to April 3, 2026, collected industry input, and has signaled the clause will be incorporated into MAS Solicitation Refresh 32. The question is no longer whether contractors will face these obligations; it is when and whether they will be ready.