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GSAR 552.239-7001
Compliance Checklist
5-step action plan for federal contractors preparing for GSA's proposed American AI System clause (GSAR 552.239-7001, expected via Refresh 32). Covers the No-Train rule, 72-hour incident reporting to CISA and your CO, Unbiased AI Principles alignment, and how to embed compliance into your BD cycle before the clause is finalized.
- 01Audit your AI tool footprint
- 02Enforce the No-Train Rule
- 03Build a 72-hour incident protocol
- 04Align with GSA's Unbiased AI Principles
- 05Embed compliance into your BD cycle
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GSAR 552.239-7001
Compliance Checklist
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Context
Why GSAR 552.239-7001 Matters for Every Federal Contractor
On March 6, 2026, GSA proposed GSAR 552.239-7001 — a significant new AI safeguarding clause expected to be incorporated via Refresh 32. The No-Train rule, 72-hour incident reporting requirement, and Unbiased AI Principles alignment are all included in the draft. Final language may still change, but the direction is clear: contractors who act now will be ahead of the curve when the clause is finalized.
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