★ ANNUAL REVIEW 2027 SPONSORSHIPS NOW OPEN   Learn more →

Log In  |  Become a Member  |  Sponsor  |  ⌕ Search

News/Transforming Procurement/General Services Acquisition Regulation; Acquisition of Information and Communication Technology; Notice of Listening Sessions and Request for Comments
Free SampleYou’re reading a free sample of the Transforming Procurement Brief. Members get every case digest like this, six days a week.See Membership Options
EOs & Regulations·Transforming Procurement Brief

General Services Acquisition Regulation; Acquisition of Information and Communication Technology; Notice of Listening Sessions and Request for Comments

GSA is proposing a new GSAR clause (552.239-7001) governing basic safeguarding of Government Data within Large Language Model AI systems used in federal contracts. The clause applies whenever an LLM processes Government Data, with exceptions for embedded commercial products or incidental LLM functionality. It defines key roles in the LLM supply chain (Developer, System Operator, System Integrator, Service Provider) and requires the flowdown of relevant obligations to subcontractors who fill these roles.

Key requirements include Government ownership of all data and custom developments, prohibitions on using Government Data for model training or commercial purposes, strict data handling and access-restriction safeguards, 72-hour incident notification, foreign-control risk mitigation, data portability, advance notice of material changes, and adherence to “Unbiased AI Principles” requiring truthfulness and political neutrality, with Government evaluation and remediation rights.

Comments are due August 3, 2026, with a public listening session July 14, 2026, at GW Law School. This revised draft responds to industry feedback on the January 2026 version, narrowing scope and clarifying definitions and flowdown mechanics.

[pdf-embedder url=”https://cdn.pubkgroup.com/2026/06/2026-12205.pdf”]

Not ready to join? Take the free Pub K Weekly digest.One email. Free. Top industry articles, the community calendar, and the latest job postings.