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Smart Bulletin No. 006

GSA SmartPay® Master Contract Record-Keeping Requirements


DateVersion History Action Log - Summary of Action/Changes
November 30, 2008Implementation of Smart Bulletin #06
August 8, 2023Revised for administrative format change(s), updated to reflect GSA SmartPay 3 Master Contract references.
March 22, 2024Revised for administrative updates

Effective Date

From Issuance until superseded

Business Line(s) Affected

Purchase, Travel, Fleet and Integrated


The purpose of this GSA SmartPay Smart Bulletin is to inform customer agencies of the contractors’ record retention and reporting requirements under the GSA SmartPay 3 Master Contract.


The GSA SmartPay 3 Master Contract includes the following clauses:

C.7.2.4 Record Retention and Retrieval

In addition to the record retention requirements of FAR Part 4.703 Contractor Records Retention, the Contractor shall serve as the document repository agent for all GSA SmartPay transactions. The Contractor shall maintain electronic records of all transactions for a period of six (6) years after final contract payment. Final contract payment is defined as the final payment for the particular charge under each agency’s/organization’s task order. If the Contractor elects to add new file formats, then the Contractor shall provide a proposal to the GSA Contracting Officer that identifies the new file format and a schedule for implementation. The GSA Contracting Officer will have 30 calendar days to review and approve/disapprove the proposal. Any new file formats will be incorporated by contract modification.

C.7.3 Reporting Requirements

GSA and agencies/organizations may choose to receive some or all of the following reports and shall determine the frequency, distribution points, and method of transmission at the task order level. The agency/organization may develop performance objectives to assess Contractor compliance with agency/organization reporting requirements at the task order level. For each performance objective, the agency/organization may specify performance standards, acceptable quality level, and a method of assessment. Examples of performance objectives for reporting include but are not limited to, timeliness and accuracy of the reports. The Contractor shall provide the ability for GSA and/or agencies/organizations to create ad-hoc reports based on program and transaction data elements. Reports shall include the ability to roll-up or break down the reports by agency/organization levels within an agency/organization (e.g., department, major components within a department, offices within major components, sub-elements within offices) and summary levels. The Contractor shall offer standard commercial reports. If the Contractor has a commercial report that will meet the stated specific need, it may propose that report as an alternative and the GSA COR shall decide if the alternative may be substituted, if demonstrated to meet the requirements.

Transmission of all reports is required through the EAS (see C.7.1 Electronic Access System), unless otherwise specified by the agency/organization at the task order level. At a minimum, the reports shall correspond with the agency/organization billing cycle. The Contractor shall offer alternative electronic reporting cycles (including, but not limited to, daily, weekly, monthly) to meet agency/organization specific requirements. The Contractor shall provide data separated by transaction type (i.e., Purchase, Travel, Fleet) for reporting purposes, unless otherwise specified by GSA and/or the agency/organization. Release of program and transaction data is governed by 5 U.S.C. § 552, Freedom of Information Act (FOIA) in most instances. Reports shall be, in accordance with agency/organization FOIA compliance procedures.


Agencies should educate their card program managers on record retention and reporting requirements. It is important to keep accounts up to date throughout the contract period of performance so that the agency is in a good position to avoid contract close-out issues at the end of the GSA SmartPay Master Contract.

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