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GSA Finally Confirms that Contractors Can Opt Out of Transactional Data Reporting

Client Alert | 1 min read | 08.18.17

On Thursday, the General Services Administration formally announced that starting with the new solicitation refresh (anticipated in October 2017), participation in the Transactional Data Reporting pilot will be voluntary. Significantly, GSA has also announced that contractors that were forced into TDR (for new contract awards, option exercises, or the addition of a TDR-covered SIN) will have a one-time opportunity to opt back out of TDR. While the long-term fate of the TDR approach to pricing (which replaces the requirement for Commercial Sales Practices disclosures and Basis of Award customer tracking) remains uncertain, this announcement suggests that these long-standing approaches will not be completely eliminated any time soon.


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Client Alert | 2 min read | 09.30.25

CARB Issues Preliminary List of Entities Covered by California Climate Disclosure Laws

On September 24, 2025, the California Air Resources Board (“CARB”) issued a preliminary list of reporting/covered entities under California’s climate disclosure laws SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act) (the “Climate Disclosure Laws”) (both as modified by SB 219)....