PSC Urges Alignment with Commercial Practices in GSA’s Draft AI Terms and Conditions

March 20, 2026 | By PSC Staff

On March 20, 2026, PSC submitted industry-driven comments to the U.S. General Services Administration’s Advanced Notice for MAS Refresh 31 and Upcoming Mass Modification – specifically the Draft Clause at 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems. Click here to access PSC’s comments.

With this advanced notice, GSA has provided an opportunity for public input on its draft AI Terms and Conditions policy. PSC provided high level comments / concerns and specifically emphasized that the draft clause may (1) limit access to commercial AI solutions and innovation, (2) is misaligned with recent federal policy including OMB AI guidance, and (3) adopts a one-size-fits-all approach rather than a risk-based framework. PSC also highlighted the need for greater alignment with commercial practices, additional clarity on scope and definitions, and revisions to reduce unnecessary compliance burdens and potential duplication with existing requirements.