GSA LLM Clause 552.239-7001: Which Federal AI Contracts Are Covered?
GSA's new LLM clause takes effect October 19, 2026. Understand the material-feature test, exclusions, subcontractor obligations, and government-data safeguards that determine which federal AI contracts are covered.
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TL;DR:
GSA’s new LLM clause applies to certain federal AI procurements, not every contract involving AI. Coverage depends on whether LLM functionality is a material feature and government data is processed by the model. Covered contractors face specific data-use, subcontractor, and reporting requirements.
GSA’s new LLM clause applies to certain federal AI procurements, not every contract involving AI. Coverage depends on whether LLM functionality is a material feature and government data is processed by the model. Covered contractors face specific data-use, subcontractor, and reporting requirements.
What you need to know
- The change: GSA introduced clause 552.239-7001, Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems, through its September 2026 class deviation.
- Who is affected: Contractors providing covered LLM-enabled systems, relevant subcontractors handling government data, and GSA acquisition personnel.
- Why it matters: The clause establishes requirements for government-data use, subcontractor oversight, documentation, and related safeguards.
- What to do first: Review the solicitation or contract, determine whether LLM functionality is material to the purchased system, and examine government-data flows.
- Key date: October 19, 2026, is the deviation's effective date. MAS Refresh 34 is planned for November 6.
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