GSA LLM contract clause 552.239-7001 takes effect
GSA clause 552.239-7001, Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems, issued September 28, 2026, took effect on October 19, 2026. In its final, narrowed form it applies only where LLM functionality is a material feature of the procurement and Government Data is submitted directly to or produced by the LLM.
The clause bars use of Government Data for training, advertising or sale, requires encryption and audit logging, and protects contractors' pre-existing intellectual property.