GSA Schedule Changes in 2025: 7 Mistakes You're Making with the New FAR Overhaul (and How to Fix Them)
- Aaron Young
- 6 days ago
- 4 min read
The biggest shake-up to GSA Schedules in decades is happening right now, and most federal contractors are completely unprepared.
If you think the upcoming changes are just another routine "refresh," you're already making your first mistake. GSA's Refresh #30, rolling out in November 2025, isn't your typical update: it's a complete regulatory overhaul that will impact 94 clauses and provisions across the entire Multiple Award Schedule (MAS) program.
Here's the reality: 90% of contractors we've spoken with have no idea what's coming, and those who do are still making critical errors that could jeopardize their contracts. Don't be one of them.
Let's dive into the seven most dangerous mistakes contractors are making with the new FAR Overhaul: and exactly how to fix them before it's too late.
Mistake #1: Treating This Like a "Simple Refresh"
The Problem: Most contractors hear "Refresh #30" and assume it's business as usual. They're wrong.
This isn't just another update: it's a fundamental restructuring of how GSA Schedules operate. The Revolutionary FAR Overhaul (RFO) is driving changes to employment clauses, subcontracting requirements, responsibility matters, cost and pricing data, and indefinite quantity provisions.
When GSA announced this on October 17, 2025, they made it clear: this is an "overhaul rather than a simple refresh."
The Fix:
Treat this as a major compliance event, not routine maintenance
Allocate dedicated resources and budget for implementation
Start preparing your team now: don't wait for the official release
Review your current contract terms against the upcoming changes
Mistake #2: Ignoring the 90-Day Deadline Trap
The Problem: Once GSA issues the Mass Modification for Refresh #30, contractors have exactly 90 days to accept it. Miss this window, and you could face contract termination.
We're seeing contractors assume they'll have "plenty of time" or that extensions will be granted. This is a dangerous gamble with your federal contracting future.
The Fix:
Mark your calendar the moment Refresh #30 is released
Create an internal 60-day deadline to give yourself buffer time
Assign a dedicated team member to monitor the acceptance process
Prepare your acceptance documentation in advance
Mistake #3: Underestimating the Scope of Changes
The Problem: Contractors think a few clauses will change. The reality? 94 clauses and provisions are being affected:
36 FAR clauses and provisions deleted
5 new RFO clauses added
53 FAR clauses replaced with RFO deviation versions
This includes critical areas like Iran restrictions, foreign purchases, unmanned aircraft systems, and subcontracting requirements. If you're not tracking every single change, you're setting yourself up for compliance failures.
The Fix:
Request the complete list of affected clauses from GSA
Map each change against your current contract structure
Identify which changes impact your specific business lines
Create a compliance checklist for each affected area
Mistake #4: Missing the SAM.gov Timing Disconnect
The Problem: Here's where it gets tricky. While Refresh #30 launches in November 2025, SAM.gov system updates won't happen until January 2026 at the earliest.
This creates a dangerous compliance gap where your GSA Schedule requirements and SAM.gov profile may be out of sync for months.
The Fix:
Plan for dual compliance periods: old SAM.gov rules and new GSA requirements
Document your compliance efforts during the transition period
Prepare to update SAM.gov immediately when the system allows
Monitor both platforms for conflicting requirements
Mistake #5: Overlooking Special Item Number (SIN) Changes
The Problem: The Order-Level Materials (OLM) SIN is being completely revised, affecting 60 subcategories of materials under the MAS program.
Many contractors with OLM components in their schedules don't realize their entire product categorization could change.
The Fix:
Review every SIN on your current schedule
Identify which subcategories under OLM apply to your offerings
Prepare new product descriptions and categorizations
Budget for potential re-certification costs
Mistake #6: Ignoring the Right-Sizing Initiative
The Problem: Beyond Refresh #30, GSA is implementing a right-sizing initiative that will eliminate contracts failing to meet sales thresholds, address non-compliance, and remove low-demand items.
If your GSA Schedule isn't generating sufficient sales or you're behind on compliance requirements, your contract could be terminated regardless of the Refresh #30 updates.
The Fix:
Audit your sales performance against GSA thresholds immediately
Address any outstanding compliance issues now
Remove underperforming products from your schedule
Focus marketing efforts on your GSA Schedule to boost sales
Mistake #7: Going It Alone
The Problem: The complexity of these changes is beyond what most contractors can handle internally. We're seeing businesses try to navigate 94 clause changes, timing disconnects, and compliance requirements without expert guidance.
This is like trying to perform surgery on yourself: technically possible, but incredibly risky.
The Fix:
Partner with experienced GSA consultants who understand the RFO
Join contractor forums and industry groups for peer support
Invest in compliance training for your team
What This Means for Your Business
These changes aren't just regulatory updates: they're business-critical decisions that will determine your federal contracting future.
The contractors who adapt successfully will gain competitive advantages as less-prepared competitors struggle with compliance. Those who ignore or mishandle these changes risk losing their GSA Schedules entirely.
Your Next Steps
Don't wait for Refresh #30 to be officially released. Start preparing now:
Assess your current compliance status
Review your sales performance against GSA thresholds
Identify which of the 94 changes affect your contract
Create an implementation timeline with buffer time
Consider professional guidance for complex changes
The window for preparation is closing fast. GSA has made it clear that this overhaul is happening whether contractors are ready or not.
Ready to ensure your GSA Schedule survives the 2025 overhaul?Book a consultation with our federal contracting experts who've successfully guided hundreds of contractors through major regulatory changes.
Don't let these seven mistakes cost you your federal contracting future. The contractors who act now will be the ones thriving when the dust settles in 2026.
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