ARTICLE · 01 JULY 2026

GSA Seeks Comment On Updated AI Contract Clause

Wiley Rein

Explore more from Wiley Rein

The U.S. General Services Administration has released a significantly revised draft of proposed regulations governing how large language model AI systems must handle government data. This second iteration addresses industry concerns from the initial January 2026 proposal while establishing comprehensive safeguarding requirements for contractors and service providers.

United StatesGovernment, Public Sector

Tracye Winfrey Howard

Kevin J. Maynard

Kathleen E. Scott

W. Benjamin Phillips, III

WHAT: The U.S. General Services Administration (GSA) has published a second draft of the proposed GSAR 552.239-7001 clause that is aimed at establishing comprehensive requirements for safeguarding government data within large language model (LLM) artificial intelligence (AI) systems that process such data. According to GSA, this latest draft reflects substantial revisions to the initial draft released in January 2026, based on comments and concerns raised in response to the initial draft. Our coverage of the initial draft can be found here.

WHEN: The proposed clause was published in the Federal Register on June 17, 2026. GSA intends to hold a public listening session on the proposed clause on July 14, 2026 (registration closes July 3, 2026). Comments on the proposed clause, submitted via https://www.regulations.gov/, are due by August 3, 2026.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

Medicare Advantage Whistleblower Case Ends In $22.5 Million Independence Blue Cross Settlement

United StatesGovernment, Public Sector

Miller Shah LLP

Aerospace And Defense Outlook 2026

United StatesGovernment, Public Sector

Hogan Lovells Cadwalader

The Ninth Circuit Upholds Arizona’s Bright Light On “Dark Money”

United StatesGovernment, Public Sector

Weekly Sanctions Update: October 13, 2026

GlobalGovernment, Public Sector

UPDATE: DEA Publishes Registration Applications For Medical Marijuana Manufacturers, Distributors, And Analytical Labs

United StatesGovernment, Public Sector

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Government, Public Sector

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.

United StatesGovernment, Public Sector

Crowell & Moring LLP

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp

United StatesGovernment, Public Sector

Greenberg Traurig

Weekly Sanctions Update: September 14, 2026

The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.

GlobalGovernment, Public Sector

Massachusetts’ 2026 Ballot Questions: What Clients Need To Know

Massachusetts voters will decide nine statewide ballot questions in November 2026 that could fundamentally reshape the state's legal, regulatory, and fiscal landscape. These measures address government transparency, election reforms, housing development, marijuana regulation, firearms laws, and state revenue limits, with implications extending far beyond Election Day to implementation, regulation, and ongoing policy debates.

United StatesGovernment, Public Sector

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

When Can Congress Refuse To Seat A Duly-Elected Candidate?

Never. In 1969, the U.S. Supreme Court ruled that the Speaker of the House could not exclude a duly-elected candidate for the U.S. House of Representatives.

United StatesGovernment, Public Sector

Holland & Knight

DOJ Continues DEI False Claims Act Enforcement With $25 Million Accenture Settlement

The Department of Justice announced a $25 million settlement with Accenture Federal Services over allegations that the company violated the False Claims Act by falsely certifying compliance with anti-discrimination requirements while allegedly using race or sex in hiring, promotion, and access to professional development programs. This marks the third major DEI-related FCA enforcement action in 2026, following similar settlements with IBM and Deloitte.

United StatesGovernment, Public Sector

Bass, Berry & Sims PLC

Weekly Sanctions Update: September 21, 2026

The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 has become law, imposing sweeping sanctions on Russian officials, financial institutions, and shadow fleet vessels while authorizing tariffs up to 100 percent on major purchasers of Russian oil and natural gas. How will these new measures impact global trade relationships, particularly with China and India as the largest buyers of Russian crude?

GlobalGovernment, Public Sector

National Historic Preservation Act Overhaul: What You Need To Know

The Advisory Council on Historic Preservation has advanced a Notice of Proposed Rulemaking that would fundamentally restructure Section 106 of the National Historic Preservation Act, marking the most significant regulatory overhaul in over 20 years. The proposed changes would shift the consultation process from a multi-step framework to an agency-prepared report system, narrow the scope of protected properties, and grant federal agencies greater unilateral authority in resolving adverse effects.

United StatesGovernment, Public Sector

Kelley Drye & Warren LLP

DOJ's $2 Million Honeywell Settlement Under The Civil Cyber-Fraud Initiative: What Compliance Failures Mean For Defense Contractors

The Department of Justice secured a $2 million settlement with Honeywell Aerospace for allegedly failing to comply with NIST SP 800-171 cybersecurity requirements under a Department of War contract. This case demonstrates how cybersecurity compliance failures can trigger False Claims Act liability even without an actual data breach or cyberattack, and highlights the growing role of whistleblowers in exposing contractors' gaps between contractual obligations and actual security practices.

United StatesGovernment, Public Sector

Bass, Berry & Sims PLC

Weekly Sanctions Update: September 8, 2026

Global sanctions enforcement intensifies as the US expands its economic pressure campaigns against Cuba, Iran, and Venezuela while the UK and EU strengthen their Russia sanctions frameworks. Meanwhile, China pushes back against US sanctions targeting its companies over alleged Iran ties, and a Dutch chipmaker faces asset freezes amid a complex ownership dispute involving Chinese courts.

GlobalGovernment, Public Sector