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GSA Clarifies the Future of Transactional Data Reporting in the Federal Supply Schedule Program

Client Alert | 1 min read | 04.29.21

On April 27, 2021, the General Services Administration (GSA) announced its intention to not only continue but expand the Federal Supply Schedule (FSS) Transactional Data Reporting (TDR) pilot program, based on a third consecutive year of positive results.

Since 2016, GSA’s pilot has studied the potential for TDR to replace the various onerous requirements FSS contractors must currently fulfill to ensure the pricing offered to GSA customers is fair and reasonable, including the obligation to make Commercial Sales Practice disclosures and to track commercial pricing and discounts to the negotiated Basis of Award customer under the Price Reductions Clause.  Although the TDR pilot program has been well-received by industry participants, the GSA Federal Acquisition Service’s silence on the program after extending it through FY2020 raised concern over the future of TDR, particularly in the face of published criticism of the TDR pilot program by the GSA Office of Inspector General.  This announcement is therefore welcome news to many existing and future FSS contractors, for whom the future of TDR had been in some doubt over recent months.  Contractors interested in TDR should reach out to their FSS contracting officer for additional guidance regarding the program’s planned expansion.

Insights

Client Alert | 4 min read | 09.10.26

European Commission Publishes Landmark Guidelines on Exclusionary Abuses by Dominant Companies

On 3 September 2026, the European Commission adopted new Guidelines on the application of Article 102 TFEU to abusive exclusionary conduct by dominant undertakings. The Guidelines follow a public consultation on a draft published in August 2024 and reflect substantial stakeholder feedback. They replace the Commission's 2008 Guidance on enforcement priorities (which ceases to apply 30 days after publication of the new guidelines in the Official Journal) and represent the most significant reset of the Commission's Article 102 enforcement framework in nearly two decades. The Commission's stated aim is to set out principles and operational guidance, enhance legal certainty, and help companies self-assess their exclusionary-abuse risk....