Disclaimer: This article discusses a proposed federal acquisition rule. It is not legal advice. The rule has not been finalized and could change significantly. Consult a government contracts attorney before making compliance decisions.
Three days. That's what's left.
The GSA's proposed "American AI" contract clause — which we covered in detail in our initial breakdown of the GSA rule — has a public comment period that closes on Thursday, March 20, 2026. After that, the window shuts. GSA will move forward with whatever feedback they've received, and contractors who didn't speak up won't get a do-over.
If you do any federal work — GSA schedule, military base maintenance, VA facilities, anything under a federal contract — this rule could reshape how you use AI tools on the job. And if you're a sub on those projects, yes, it probably applies to you too.
This article isn't a rehash of what the rule says. We covered that already. This is the "what to do right now" guide: how to actually submit a comment, what to write, and what happens after March 20.
Why Your Comment Matters (and What Happens If You Don't Submit One)
Federal rulemaking isn’t a vote. GSA doesn’t count up “yes” and “no” comments and pick a winner. But comments do carry real weight — especially specific, practical ones from people who’d actually be affected.
Here’s what happens when GSA gets substantive comments from contractors:
- They have to respond. Under the Administrative Procedure Act, agencies must address significant comments in their final rule. If 200 electrical contractors say the documentation requirements are unworkable for small shops, GSA can’t just ignore that. They have to explain why they kept the requirement or how they modified it.
- Real-world examples change outcomes. Agency rule writers are policy people. Many of them have never run a construction crew or managed subcontractors on a federal building project. When you explain how a rule would actually play out on a jobsite, you’re giving them information they don’t have.
- Volume signals political pressure. While quality matters more than quantity, a flood of comments from small contractors signals to GSA leadership that this rule has broader implications than they may have considered.
Now here’s what happens if you stay quiet:
GSA finalizes the rule based on the comments they did receive — mostly from large defense contractors, trade associations, and AI vendors. Those groups have different priorities than a 15-person HVAC company doing GSA schedule work. Large primes want compliance frameworks they can staff up for. AI vendors want their products on the approved list. Neither group is thinking about your crew.
The seven-day comment window was already unusually short. Several industry groups have publicly criticized the compressed timeline. But complaining about the timeline doesn’t extend it. You work with the deadline you’ve got.
How to Submit a Comment: Step by Step
The process is free, it’s online, and it takes about 20 minutes if you know what to say (we’ll cover that next). Here’s the exact process.
Step 1: Go to Regulations.gov
Navigate to regulations.gov. This is the official federal portal for public comments on proposed rules. It’s run by the government — it’s not a third-party petition site.
Step 2: Find the GSA Proposed Rule
Use the search bar to search for the GSA American AI clause. You can search by the docket number (which will be listed on the Federal Register notice) or by keywords like “GSA American AI contract clause.” The proposed rule will show up with a blue “Open for Comment” badge if the comment period is still active.
If you have trouble finding it, try searching “GSA” and filtering by “Open for Comment” in the left sidebar. The docket page will show the full text of the proposed rule and a “Comment” button.
Step 3: Click “Comment”
On the docket page, click the blue “Comment” button. This opens the comment submission form. You don’t need to create an account, but you can submit one if you want to track your submission.
Step 4: Write Your Comment
The form has a text box for your comment. There’s no minimum or maximum length requirement, but aim for 200–500 words. Focused and specific beats long and rambling. We’ll cover exactly what to write in the next section.
Step 5: Add Your Information
You’ll be asked for:
- Your name (or your company name)
- Whether you’re commenting as an individual or on behalf of an organization
- Your state (optional but helpful — it shows geographic reach of concern)
- You can upload supporting documents if you want, but it’s not required
Privacy note: Comments submitted to regulations.gov are public. Your name and comment will be visible to anyone. Don’t include sensitive business information, contract numbers, or anything you wouldn’t want a competitor to see.
Step 6: Submit Before 11:59 PM ET on March 20
The deadline is 11:59 PM Eastern Time on Thursday, March 20, 2026. Not Pacific. Not Mountain. Eastern. If you’re on the West Coast, that’s 8:59 PM your time. Don’t cut it close — the site can slow down near deadlines.
After submitting, you’ll get a confirmation screen with a tracking number. Screenshot it or save it. Your comment may take a few days to appear publicly on the docket page, but it’s recorded as soon as you get that confirmation.
What to Actually Write in Your Comment
This is where most people freeze up. They think they need to write a legal brief or a polished position paper. You don’t. You need to write clearly about how this rule would affect your business in practical terms.
Here are the principles that make comments effective:
- Be specific. “This rule would hurt small businesses” is weak. “My 12-person plumbing company does $400K/year in VA facility maintenance. This rule would require me to audit three software platforms I currently use, which I estimate would cost $5,000–$8,000 in legal and IT consulting fees” — that’s strong.
- Reference the actual rule text. If you can, point to the specific section or requirement you’re commenting on. “Section X’s documentation requirement” is more useful than “the paperwork is too much.”
- Propose alternatives. Don’t just say what’s wrong — suggest what would work better. GSA is more likely to modify a requirement if someone hands them a reasonable alternative.
- State your qualifications. Mention your trade, how long you’ve been in business, and your experience with federal contracts. This establishes that you’re a real person who’d be directly affected.
Example Comment: Small HVAC Subcontractor
“I’m the owner of [Company Name], a licensed HVAC contractor in [State] with 8 employees. We perform approximately $600,000 per year in federal building maintenance work as a subcontractor on GSA schedule contracts.
I have two concerns about the proposed American AI clause:
First, the documentation requirements for AI tool compliance would create a significant administrative burden for a company my size. We use AI features built into our scheduling software and our estimating platform. We don’t have an IT department or a compliance officer. Requiring us to obtain and maintain compliance documentation from each software vendor — including training data provenance and server location verification — would likely cost $5,000–$10,000 annually in consulting fees. For a small sub, that’s a meaningful hit to our margins on federal work.
Second, the seven-day comment period is insufficient for small contractors to learn about, evaluate, and respond to a rule with this scope. I’d request a 30-day extension and, at minimum, a longer implementation timeline if the rule is finalized.
I suggest GSA consider a tiered compliance approach based on contract value or company size, similar to existing small business set-aside thresholds. Contractors below a certain dollar threshold could meet simplified documentation requirements rather than the full compliance framework.”
Example Comment: Electrical Contractor (Direct GSA Schedule Holder)
“I operate a 22-person electrical contracting company with a GSA schedule for electrical maintenance and installation services. We’ve held our GSA schedule since [year] and perform work at federal facilities across [region].
We currently use AI-powered tools for estimating, project scheduling, and safety documentation. These tools save us approximately 15 hours per week in administrative time and have reduced our estimating errors by roughly 20%.
My concern with the proposed clause is the data sovereignty requirement as applied to commercial off-the-shelf (COTS) software. Most AI-powered construction management platforms use cloud infrastructure with distributed processing. As an end user, I have no visibility into which specific servers process my data or where the AI model’s training data originated. Requiring contractors to verify this information shifts a compliance burden onto parties who have no ability to verify it.
I’d recommend GSA place the compliance obligation on the AI tool vendors through a certification program, rather than requiring individual contractors to independently verify vendor claims about server locations and training data sources.”
Example Comment: General Contractor Managing Subs on Federal Projects
“I’m a general contractor managing federal construction projects with 15–30 subcontractors per project. If the American AI clause flows down to subcontracts — which federal contract clauses typically do — I would need to verify AI tool compliance for every sub on every federal job.
Many of my subs are small, family-owned trade contractors. They use AI-powered features in their everyday business software without necessarily knowing which features qualify as ‘AI’ under this rule’s definitions. Requiring them to audit their software stack for AI compliance would create confusion, delays in subcontractor onboarding, and potential bid protests.
I’d recommend GSA: (1) clearly define what constitutes ‘AI’ for purposes of this clause, distinguishing it from basic automation and machine learning features embedded in COTS software; (2) create a pre-approved list of compliant platforms; and (3) provide a reasonable implementation timeline of at least 12 months after finalization.”
You don’t need to copy these word-for-word. Use your own numbers, your own situation, your own concerns. The point is specificity. GSA doesn’t need to hear that the rule is “bad for business.” They need to hear exactly how it would affect your business, in dollars and hours.
Why Small Subs Need to Pay Attention
Here’s what catches most small contractors off guard about federal rules: the flow-down effect.
When GSA puts a clause in a prime contract, the prime contractor is typically required to include that same clause (or a version of it) in every subcontract. That means a four-person drywall crew working as a third-tier sub on a federal building renovation could be subject to AI compliance requirements — even though they never signed a government contract directly.
Think about what that looks like in practice:
- Your scheduling app has an AI-powered optimization feature. Is it compliant?
- You use an AI phone answering service for after-hours calls. Does it process data on U.S. servers?
- Your estimating software just added AI takeoff features in the latest update. Where’s that AI model developed?
- You asked ChatGPT to help write a safety plan for a job last week. Does that count?
Most small subs can’t answer these questions right now. And that’s exactly the point you should be making in your comment.
If you’re not sure whether your tools use AI or regular automation, our AI vs. automation explainer breaks down the difference. And if you’re still early in figuring out AI for your business, our getting started with AI guide covers the basics without the hype.
Trade-Specific Scenarios
Plumbers and pipefitters: If you use AI-powered camera inspection software that analyzes pipe conditions, that AI tool would need to meet the clause’s requirements when used on federal jobs. Same goes for AI-assisted estimating in plumbing takeoff software.
Electricians: AI-powered load calculation tools, automated code compliance checkers, and smart scheduling platforms all potentially fall under this rule. If your panel schedule software uses machine learning to optimize layouts, that’s an AI tool under most definitions.
HVAC contractors: Building automation systems with AI-driven energy optimization are increasingly common on federal buildings. If you’re installing or maintaining those systems, the AI clause could apply to the equipment itself — not just your office software.
Roofers and exterior contractors: Drone inspection software with AI-powered damage detection, AI-assisted moisture mapping, and satellite-based measurement tools with AI features are all in scope.
General contractors and project managers: Your project management platform’s AI scheduling features, AI-powered RFI analysis, change order prediction tools — all potentially covered. Plus you’d be responsible for flowing the clause down to every sub.
What Happens After March 20
The comment period closes, but the process doesn’t end. Here’s the likely timeline based on how GSA has handled similar rulemakings:
April–May 2026: Comment Review
GSA staff will read every comment. All of them. They’ll group similar concerns, identify common themes, and draft responses. If they received significant pushback on specific provisions — like the documentation requirements or the seven-day comment period — those sections will get extra scrutiny.
Summer 2026: Possible Revised Proposal or Final Rule
GSA has two options after reviewing comments:
- Issue a final rule. If comments don’t raise issues that require major changes, GSA can finalize the clause. They’ll publish a response to comments explaining what they changed and why, along with the final text. This could happen as early as June or July 2026.
- Issue a revised proposal. If comments reveal significant problems — workability issues, unintended consequences, legal concerns — GSA might publish a revised version with another comment period. This would push the timeline out by several months.
Late 2026–2027: Implementation
Once finalized, the clause would start appearing in new GSA contracts and contract modifications. There would likely be an implementation period — maybe 60 to 180 days — before enforcement begins. But the smart move is to start preparing now, regardless of the exact timeline.
If you’re thinking about building a broader AI strategy for your contracting business — not just reacting to this one rule — our guide to building an AI strategy walks through how to make AI decisions that account for both opportunity and compliance risk.
The Ripple Effect
Even if GSA softens the final rule, the direction is clear. Federal agencies are moving toward regulating AI in contracting. The Department of Defense, the VA, and HHS are all developing their own AI governance frameworks. What GSA does first will become the template.
For contractors, this means AI compliance isn’t a one-time thing. It’s becoming a permanent part of doing federal work — right alongside bonding requirements, prevailing wage rules, and safety certifications. The contractors who get ahead of it now will have an easier time when the next round of rules hits.
Your 3-Day Action Plan
Here’s what to do between now and Thursday night:
Today (Monday, March 17)
- Read the proposed rule. If you haven’t already, read our breakdown of the GSA rule to understand what’s being proposed. If you have time, read the actual Federal Register notice on regulations.gov.
- List your AI tools. Write down every piece of software you use that has AI or “smart” features. Include your CRM, estimating software, scheduling platform, phone system, and accounting tools. If you’re not sure what counts, check our AI data privacy guide for guidance on identifying AI in your workflow.
Tuesday or Wednesday (March 18–19)
- Draft your comment. Use the examples above as a starting point. Personalize it with your company’s details — trade, size, federal contract experience, specific AI tools you use, and specific concerns about how the rule would affect your operations.
- Talk to your trade association. Groups like ABC (Associated Builders and Contractors), AGC (Associated General Contractors), and PHCC (Plumbing-Heating-Cooling Contractors Association) may be filing comments of their own. Your individual comment matters, but knowing what your association is saying helps you fill in gaps they might miss.
Thursday (March 20) — Deadline Day
- Submit your comment on regulations.gov. Don’t wait until 11 PM. Submit by midday if you can. The site can get sluggish near deadlines.
- Save your confirmation. Screenshot the confirmation page and save the tracking number.
- Share this with one other contractor. The more small contractors who comment, the harder it is for GSA to ignore the concerns of the trades. Text this article to someone you know who does federal work.
The Bottom Line
You’ve got 72 hours. That’s not a lot of time, but it’s enough to submit a comment that could shape how AI regulation works in federal contracting for years to come.
This isn’t about being anti-regulation or pro-AI. It’s about making sure the people who actually do the work — the ones pulling wire, running pipe, and managing crews on federal jobsites — have a voice in how these rules get written.
Big defense contractors have teams of lobbyists and compliance officers. You’ve got 20 minutes and a regulations.gov account. Use them.
This article discusses a proposed federal acquisition rule and provides general information only. It does not constitute legal advice. Consult with a qualified government contracts attorney regarding your specific situation and obligations.