Contract assessment
Record whether 552.239-7001 is present, the clause version, contract reference, source page, and the team's applicability review.
Deadline Shield for Federal AI Contractors
Manage GSAR 552.239-7001 without running your AI contract from a spreadsheet.
Turn contract requirements into owned work, tracked AI systems and subcontractors, evidence status, change events, and protected deadlines.
Start a Federal Contracting workspace Run the local clause screen
Deadline Shield is not a law firm, does not determine legal applicability, and does not certify compliance.
The clause is not a blanket rule for every contractor using AI
GSA's current September 2026 class-deviation language targets procurements where an LLM, generative assistant, chatbot, agentic system, LLM-enabled document or productivity tool, or similar system has LLM functionality as a material feature and Government Data is submitted directly to or produced by the LLM. The clause also contains self-deleting language for certain contractor-internal/back-office uses and incidental or ancillary LLM functionality.
From clause language to contract operations
AI system inventory
Map model providers, cloud services, integrators, monitoring vendors, and other components supporting each covered engagement.
Subcontractor flowdowns
Track which systems or subcontractors require review, flowdown treatment, attestations, and supporting evidence.
Change and incident clocks
Record model changes, provider deprecations, material degradation, incidents, and other events that may start a notice workflow.
Evidence status
See what is received, missing, requested, or reviewed without claiming that Deadline Shield itself certifies the evidence.
Protected due dates
Send time-sensitive GSAR events into the normal Deadline Shield reminder engine with the same ownership, plan, and history safeguards.
Free local GSAR clause screen
Paste text from a public/unclassified or otherwise unrestricted contract excerpt. This screen runs in your browser and looks for the clause identifier and common timing phrases. It does not upload the pasted text and it does not make a legal applicability decision.
The clocks worth operationalizing
The current clause includes several timing concepts that can become operational work, including a contract-specified or default 120-day disclosure period, 72-hour timing for certain material incidents or violations, advance notice for certain material changes, short timing for uncontrolled third-party model deprecation, and notice for specified safety or performance degradation. Whether a particular clock applies depends on the facts and contract.
Keep the security boundary clear
This module does not change Deadline Shield's government-contracting security posture. Do not upload CUI, nonpublic Federal Contract Information, classified information, export-controlled information, or other restricted government material. Use approved systems for restricted source documents and record only unrestricted operational metadata in Deadline Shield.
GSAR 552.239-7001 questions
Does the clause apply to every company using ChatGPT on a federal contract?
No. Presence, prescription, self-deleting language, the procured functionality, and the actual Government Data flow matter.
Does Deadline Shield replace the contracting officer or counsel?
No. It is an operational tracking and evidence-organizing layer. Your contracting officer, counsel, and authorized compliance team remain responsible for legal and contractual conclusions.
Can I create Deadline Shield reminders from a GSAR event?
Yes. The authenticated ClauseOps workspace can route a recorded notification or action date through the normal Deadline Shield protected-item flow.
What is the effective date of the September 2026 Part 552 deviation?
GSA's current RGO materials list October 19, 2026 for Part 552. Existing-contract treatment depends on contracting action and should be confirmed against the actual contract.
Make the contract operational
Create your Federal Contracting workspace
Deadline Shield is not affiliated with or endorsed by the United States Government.