The General Services Administration (GSA) has issued an advance notice and request for comments on a potential amendment to the General Services Administration Acquisition Regulation (GSAR) addressing the acquisition of Information and Communication Technology (ICT) and the use of Large Language Models (LLMs).
The provision was originally drafted as a Schedule contract clause (GSAR 552.239-7001). In response to industry concerns regarding the breadth of the initial requirements, GSA has expanded its outreach and is seeking broader stakeholder feedback on ICT and AI-related issues before proceeding with formal rulemaking.
Key elements of the draft provisions include:
- "American AI" Requirement: Contractors would be required to use AI systems that are developed and produced within the United States.
- Data Rights: The government would receive broad intellectual property rights and licenses to use AI systems, models, and related data enhancements for any lawful government purpose.
- Cybersecurity and Incident Reporting: Contractors would be subject to stringent cybersecurity requirements, including mandatory reporting of cybersecurity incidents to the Cybersecurity and Infrastructure Security Agency (CISA) within 72 hours.
- System Oversight and Evaluation: GSA would have authority to conduct benchmarking and testing of AI systems to assess compliance, transparency, and standards related to "ideological neutrality."
Regulatory Status and Potential Impact
The proposed GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems, could have significant implications for federal contractors, AI providers, and technology vendors.
- Restrictions on AI Providers and Supply Chains
- Significant Changes to Data Rights and Intellectual Property
- Greater Cybersecurity and Incident Reporting Obligations
- Increased Government Oversight of AI Systems
- Expanded Contractor Liability for Third-Party AI Providers
- Potential Impact on Commercial AI Adoption in Government
GSA is currently conducting listening sessions and soliciting public comments to better understand how LLMs process and interact with government data before issuing a formal proposed rule.
View Notice: Federal Register Page
Submit Comments: Use the Regulations.gov portal and search for docket Notice-MVAC-2026-01.
Key Dates: Comments are due by August 3, 2026, with a public listening session scheduled for July 14, 2026.
How BDO Can Help
As Deltek Costpoint capabilities, federal compliance requirements, and operational needs continue to evolve, having the right support can help your organization make more informed decisions and get greater value from your systems and processes. BDO’s Deltek Costpoint and Government Contracting Advisory professionals work with organizations to address system optimization, compliance readiness, process improvement, reporting needs and other priorities that affect government contractors.
If your team has questions about Costpoint functionality, government contracting requirements, or ways to help improve efficiency across your operations, we welcome the opportunity to connect and discuss how we can help.