PSC Comments on GSA's Revised Draft GSAR Clause on LLM Data Safeguarding

August 3, 2026 | By PSC Staff

On August 3, 2026, PSC submitted comments to GSA on its revised GSAR clause, 552.239-7001, “Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems (LLMs),” building on PSC's earlier March 20, 2026, comments on the initial draft.

PSC welcomed several revisions, including a narrower license grant, preserved contractor IP ownership, and a shift toward risk-based foreign-ownership screening—but urged GSA to further clarify the clause's scope, narrow data/IP ownership provisions, address unworkable flowdown obligations for open-weight model developers, provide a phased implementation timeline, and reduce compliance burdens that could disproportionately affect small businesses. Click here to access PSC’s comments.