What’s Changing in Federal AV Contracts for 2026

Federal AV work has never been simple, but 2026 is shaping up to be one of the more complex years contractors have had to navigate in recent memory. The changes aren’t coming from one big rule, though. They’re arriving from several directions at once: procurement reform, cybersecurity enforcement, AI governance, catalog modernization, and updated trade thresholds. For AV integrators working in the federal space, this is the year that compliance moves from background noise to front-of-mind.

Here’s what’s shifting, and what it means in practice.

GSA MAS Refresh 31 Is Rewriting the Rules for Schedule Sellers

The most immediate structural change for firms selling through the GSA Multiple Award Schedule is Refresh 31, expected around March/April 2026. The headline change is mandatory Transactional Data Reporting (TDR) for all MAS SINs. 

Under the draft, all non-TDR and CSP-1 references will be removed from the solicitation, and existing contractors who haven’t transitioned will receive a mass modification to participate. That mod must be accepted within 60 days of issuance.

What this means operationally: Schedule compliance is no longer primarily a pre-award pricing exercise. It’s becoming an ongoing, transaction-level reporting discipline, tracking what was sold, at what price, and through which contract structure. 

For AV firms that have historically relied on loosely maintained Schedule files, 2026 demands tighter internal controls.

Open Market Flexibility Is Getting Narrower

Refresh 31 also signals a meaningful change in how ancillary items are handled. The old flexibility around “open market” purchasing has been replaced by a more structured approach under GSAR 538.71 and 538.72, with GSA strongly recommending contractors add the Other/Logical Market (OLM) SIN to their Schedule.

For AV work, this matters more than it might initially appear. Federal AV projects routinely blend displays, control hardware, racks, cabling, labor, configuration, and training into a single scope. If agencies can no longer handle mixed-scope items the way they used to, contract structuring will require more precision, and contractors who don’t adapt may find items falling outside covered scope at award review.

Catalog Operations Are Modernizing Whether You’re Ready or Not

GSA is migrating existing MAS contracts to the FAS Catalog Platform (FCP) at roughly 700 contracts per month. Contractors receive advance notifications and then have 60 days from system access to initiate the baseline process. Importantly, FCP replaces the older SIP and EDI catalog management tools entirely.

For AV integrators with large product catalogs, bundled solutions, or frequently updated hardware configurations, this is not just a portal swap. It affects catalog accuracy, modification timelines, and how quickly approved products appear for agency buyers. The firms that start preparing now will have significantly less friction than those who wait for the migration notification.

AI-Enabled AV Solutions Could Face a Much Stricter Compliance Environment

GSA released a draft AI clause, GSAR 552.239-7001, in March 2026. Under the draft, contractors would be required to disclose all AI systems used in performance, use only American AI systems (foreign AI systems would be prohibited), and report confirmed or suspected incidents within 72 hours, with daily updates until resolved.

For AV contractors, the scope of this potential clause is broader than it might seem. AI now touches video conferencing platforms, room analytics, auto-framing cameras, speech-to-text captioning, transcription and summarization tools, and AI-assisted digital signage. 

A project sold as “standard AV integration” can easily include AI-capable features that would fall under this clause if finalized. Now is the time to audit your solution stack and understand where AI capability lives in your typical deliverables.

DoD AV Work Is Now Inside a Live CMMC Phase-In

For contractors doing defense-related AV work, the Cybersecurity Maturity Model Certification (CMMC) is no longer a future planning exercise. Phase 1 began November 10, 2025, and runs through November 9, 2026, covering Level 1 and Level 2 self-assessments. Under DFARS Subpart 204.75, contracting officers cannot award a contract or exercise an option without a current CMMC status in SPRS at the required level.

Modern defense AV projects frequently involve networked control systems, secure collaboration spaces, managed AV-over-IP, remote monitoring, and systems that touch Federal Contract Information or Controlled Unclassified Information. That means cybersecurity is no longer a side conversation in the proposal process. It’s an eligibility gate. 

Beginning November 10, 2026, applicable solicitations can begin requiring Level 2 certification in the next phase. Firms without a clear path to certification are already behind.

Section 508 Remains Mandatory and Highly Relevant to AV Deliverables

Federal accessibility requirements aren’t new, but they remain one of the easier places for AV contractors to get tripped up on evaluation and acceptance. The Access Board’s ICT standards require that where ICT displays video with synchronized audio, the system must support closed captions, audio descriptions, and user controls for both. GSA enforces these as mandatory scoping requirements across ICT products and professional services.

In practical terms, this reaches conference room displays, collaboration platforms, video playback systems, digital signage, kiosks, and streaming infrastructure. If your deliverable includes any video, user-facing interface, or audio-visual content component, accessibility requirements may factor into acceptance criteria, and they’re worth reviewing at the design stage, not after installation.

Trade Thresholds Updated in March 2026

FAC 2026-01, effective March 13, 2026, updated trade-agreement thresholds under USTR notices effective January 1, 2026. The WTO GPA threshold is now $174,000 for supply and service contracts. 

For AV contractors supplying displays, processors, cameras, speakers, and control hardware, shifting thresholds can affect how larger buys are structured, sourced, and evaluated. Origin and compliance questions will continue to be part of the conversation on hardware-heavy federal AV projects.

The Bottom Line for Federal AV Contractors

The 2026 federal AV contracting environment rewards preparation. Firms that treat TDR as an admin update, delay their FCP migration, overlook the AI clause implications, or let CMMC drift will face harder problems mid-contract than those who get ahead of each change now.Applied Global Technologies has navigated federal procurement complexity for over 30 years, and we build that knowledge into every engagement from day one. Whether you need support in structuring a compliant AV solution for a government facility or managing a secure, multi-site deployment, our team is ready. Contact AGT to request a custom AV consultation, and let’s make sure your 2026 program is built on solid ground.