GSA mass MAS mod for refresh #25 revises sustainability and equal opportunity clauses

GSA issued a mass modification this week that significantly revises several contract clauses for Schedule contract holders, with a focus on sustainability reporting and regulatory compliance alignment. The mod, posted via GSA’s Mass Mod Portal, deletes eight clauses and replaces three with updated versions that include formal deviations.

What changed

Removed clauses include:

• 52.222-26 (Equal Opportunity) and 52.222-21 (Prohibition of Segregated Facilities), both core EEO requirements
• 52.223-19 (Environmental Management Systems), and I-FSS-973 (Payments by Non-Federal Ordering Activities)
• An older version of 52.212-5, which incorporates key statutory and executive order requirements

Replaced with updated deviated clauses:

• 52.223-10 (Waste Reduction Program) – now refreshed with a February 2025 deviation
• 52.223-2 (Reporting of Biobased Products) – also reissued with deviation
• 52.212-5 (Contract Terms and Conditions) – updated to January 2025 version with deviations aligning GSA policy with federal statutes

The most notable change is the removal of foundational EEO clauses, which may shift compliance obligations onto other parts of GSA contract enforcement or reflect duplicative coverage through broader statutory mechanisms. Contractors must carefully review whether their internal compliance frameworks continue to meet applicable civil rights and anti-discrimination requirements despite the deletions.

Reissued environmental clauses—especially those related to waste and biobased products—signal continued emphasis on sustainable acquisition, with GSA tailoring language through deviations to better reflect its procurement strategy. These changes may also influence reporting burdens for service and construction contractors.

The update to 52.212-5, a critical clause incorporating multiple statutory requirements by reference, suggests GSA is actively refining how FAR-based statutes apply to commercial item acquisitions under its Schedule program.