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MV-2026-03
Issued June 18, 2026
MEMORANDUM FOR GSA CONTRACTING ACTIVITIES
FROM AND DIGITALLY SIGNED BY: Jeffrey A. Koses, Senior Procurement Executive, Office of Acquisition Policy
SUBJECT: GSA Project Labor Agreement Procedures
1. Purpose
This Acquisition Letter (AL) provides new flexible procedures GSA acquisition teams must use when managing Project Labor Agreement (PLA) requirements on large-scale federal construction project procurements. The procedures allow for:
2. Background
Executive Order (E.O.) 14063, Use of Project Labor Agreements for Federal Construction Projects (February 4, 2022) as implemented by RFO FAR 22.5, requires agencies to use PLAs on large-scale construction projects to promote economy and efficiency in Federal procurement.
The Office of Management and Budget (OMB) issued two memos to provide further direction. The more recent, Memorandum M-25-29 (June 12, 2025), reaffirms that:
In subsequent litigation, the Court of Federal Claims (COFC) found that requiring PLAs can violate the Competition in Contracting Act (CICA), and emphasized that agencies need to consider the potential detriments of PLAs including higher costs and limited competition.
The PLA Playbook expands upon the guidance provided in M-25-29, through a broader framework that produces the project-specific price evidence the COFC said agencies need to consider.
3. Effective Date
This AL is effective immediately and remains in effect until rescinded or incorporated into the GSA Acquisition Handbook.
4. Applicability
If you need clarification, you may email the GSA Acquisition Policy Division at GSARPolicy@gsa.gov. This AL applies to new solicitations for large-scale construction contracts and task orders (see RFO FAR 22.501 ($35 million or more)) issued on or after the effective date.
Contracting Officers may, at their discretion, amend current solicitations prior to award to implement this guidance. Legal counsel must be consulted prior to issuing an amendment to a solicitation.
This AL does not apply to projects below the $35 million threshold or to projects for which an exception under RFO FAR 22.502-2(d) has otherwise been granted.
5. Requirements
Contracting officers must follow the paired-proposal procedure and best value tradeoff procedure detailed in the GSA PLA Playbook located on the Acquisition Portal for all applicable large-scale construction contracts and task orders. A summary of the requirements are as follows:
To support GSA’s semi-annually report to OMB on use of PLAs, contracting officers must report large-scale construction procurements to the SPE upon award.
See the Project Labor Agreement topic page on the GSA Acquisition Portal for more details and resources.
_____________________________________________________________________________________________________________________________________________
1 PLA proposal means an offer that includes a PLA meeting the requirements of RFO FAR 22.502-2(b) and FAR provision 52.222-33 and clause 52.222-34.
2 Non-PLA proposal means a paired offer for the same scope of work, identical to the offeror’s PLA proposal except for the absence of PLA and any cost effects of that difference.
6. Point of Contact
For support using and implementing these new procedures and the PLA Playbook, email GSAPILOTS@gsa.gov. PILOTS can provide you with a dedicated coach, best practices for implementation, guidance on the new flexibilities, and additional resources.
Any questions regarding this AL may be directed to GSARPolicy@gsa.gov.
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