GSA Announces Major Revisions to Its Standard Lease and Request for Lease Proposal

The General Services Administration (GSA) in February published new versions of its standard lease template forms – the Global Lease (L100) and Request for Lease Proposal (RLP or R100) – along with updated versions of the Small, Airport, FEMA, SLAT and Warehouse templates. With major organizational changes and a reduction in length of approximately 20 pages for the L100 form, these updates represent the first significant modernization to GSA's templates after nearly a decade in circulation.

Overall, the revised templates provide more straightforward terms and remove outdated and redundant clauses, making them more readable to lessors and less susceptible to multiple interpretations. That said, there are several new representations and compliance obligations, and lessors should closely review the new lease forms for any surprises. Below are some of the more significant changes.

New Exhibit Add-Ons

Previously, many of GSA's standard lease and RLP clauses were project-specific and applicable only in certain situations. For example, multiple paragraphs addressed requirements that kicked in when the tenant agency requested a net-of-utilities lease, where the agency pays utilities directly, or when the lessor offered to construct an entirely new building for the government's lease. According to GSA's data, these kinds of clauses were rarely applicable, but it was common for the language to sneak into the final lease anyway.

Now, GSA has removed hyper-specific clauses and moved them to optional "Exhibits," attachments with extra clauses that can be added on to a lease as needed. This change reduces confusion about whether certain clauses apply and removes extraneous language that is not needed in the vast majority of GSA leases. Currently, GSA offers five exhibit options for leases and RLPs: Broker Project, Net Utilities, New Construction, Prospectus and Swing Space.

Elimination of Succeeding and Superseding Language

In the past, many of GSA's lease and RLP requirements did not apply to superseding leases that replace an existing lease before its scheduled expiration for the same space or succeeding leases that begin immediately after an existing lease expires for the same space. In other words, though GSA may change or tighten its lease standards for certain building services or materials each year, a lessor's existing leased space that was compliant with previous standards was "grandfathered in" when the government signed a succeeding or superseding lease in the same space. The rationale behind this was a mutually beneficial tradeoff: The government enjoyed significant cost savings and convenience to stay in the same space, and the lessor wouldn't have to make burdensome changes to its interior finishes, vestibules, telecommunications closets and certain plumbing specifications, to name a few.

This is no longer the case. GSA's new changes mean that superseding and succeeding leases no longer get a pass on certain lease standards. Now, these lease clauses apply to all new lease procurements regardless of whether the government is staying in the same place. Landlords trying to secure a succeeding or superseding lease procurement should read the lease language carefully and keep in mind that they may have to make costly upgrades to certain lease services and building materials.

Note: Superseding and succeeding leases are different from lease extensions and renewals, which usually use the same lease terms already in place.

New Security Requirements in the General Clauses

In December 2025, GSA added a new general clause incorporating certain cybersecurity requirements and supply-chain restrictions under Executive Order (EO) 14275, "Restoring Common Sense to Federal Procurement." These new requirements – previously introduced through an interim rule and a class deviation – prohibit lessors from using services, equipment or software from banned entities in the performance of the lease, including Kaspersky Lab, TikTok, ByteDance, specific Chinese telecom firms and certain drone manufacturers. As a result, lessors should review their building systems, vendors and service providers to ensure none involves prohibited entities or technologies. For specified telecommunications and video surveillance equipment and services, the clause prohibits use regardless of whether such use is in the performance of the lease. This could necessitate operational changes to a lessor's property management system or security infrastructure, even if those systems are not directly supporting the leased government space.

The entire clause flows down to a lessor's subcontracts when those subcontractors provide equipment, services, systems or other supplies used in the performance of the lease. Lessors must make a "reasonable inquiry" to ascertain whether any prohibited products or services exist and promptly report to GSA any known violations of the clause by their employees or subcontractors.

Removal of Cyclical Carpet and Repainting Requirements

After many years, GSA has removed its cyclical repainting and carpet replacement requirements. Previously, lessors were required to repaint common areas every three years and recarpet and repaint all other areas on a cyclical basis as determined by the agency prior to award, usually ranging from every three to five years. With the new GSA lease templates, these tedious, fixed-schedule maintenance requirements have been eliminated, allowing for a more flexible approach to repainting and recarpeting that can adapt to different factors such as usage, material quality, wear and tear, and maintenance practices.

It's important to note that these changes do not mean that GSA cannot demand carpet or repaint during a lease term. The lease's basic maintenance standards still apply and require carpet replacement when there is noticeable damage and repainting on an "as necessary" basis. However, this change eliminates needless cost of are placing carpet and paint on an arbitrary timeline when doing so may be wasteful if the carpet or paint is still in good shape. This change also brings GSA's lease standards into alignment with modern commercial leases that typically do not require cyclical carpet and paint replacement on such a frequent basis, reflecting the fact that newer carpet materials and paint are generally more durable than they were years ago.

Efficiency and Readability Improvements

Based on industry and customer feedback, GSA made various changes to the lease and RLP wording and structure. These changes improve readability and incorporate plain language but do not affect any substantive obligations in the lease. For example, the 2026 templates replace the word "shall" with "must," consistent with current plain language guidelines.

Some paragraphs were also consolidated for clarity. For example, prior versions of the L100 contained four separate "Doors" clauses for tenant improvement specifications (suite entry, interior, hardware and identification). The new L100 contains just one "Doors" clause for tenant improvements with simplified requirements. The new L100 also includes a consolidation of clauses relating to pricing evaluations in the design, construction and post-award phase, including negotiations, price preferences and evaluation criteria, reducing the total from 10 separate paragraphs to five.

Though the core pricing methodology remains unchanged, the consolidation of these paragraphs makes it significantly easier for prospective lessors to understand how their offers will be evaluated and reduce the risk of submission errors that previously arose from lessors having to navigate multiple interrelated paragraphs.

What Hasn't Changed?

GSA emphasized that the core business elements of the L100 – such as how GSA pays rent, how risk is allocated between GSA and a lessor, and the standard for defaults and deficiencies – remain materially unchanged. Additionally, lease requirements grounded in statute or regulation, such as the Energy Independence and Security Act and U.S. Environmental Protection Agency emission standards, are still present and enforced.

GSA's stated goal with its changes is to simplify the lease process and better align GSA's global lease and RLP with commercial practice without adding substantive requirements.

GSA Leasing Policy Moving Forward

In a February 5, 2026, Leasing Alert, the Office of Leasing announced that it will no longer issue Leasing Alerts and Lease Acquisition Circulars and that all future policy updates will come through GSA's Office of Government-wide Policy. This change aligns with GSA's mandate under EO 14275, which directed agencies to remove regulatory barriers and centralize policy procedures for maximum efficiency.

Moving forward, it appears that GSA Leasing will update its lease forms and templates on an as-needed basis, noting that GSA's use of these tools is "discretionary" and will be maintained for "guidance." Whereas GSA previously updated its standard Lease and RLP templates on an annual basis each October through a Lease Acquisition Circular issuance, the templates now exist on a new "Templates" tab on GSA's Leasing Policy page. Lessors should check this section on a regular basis to identify any significant changes made to the lease and RLP clause, though GSA notes the templates are provided "for informational purposes only" and that use of the templates and clauses in a given procurement is entirely discretionary.

For questions about GSA's updated lease and RLP templates, new security requirements and related leasing policy changes, please contact the authors or your Holland & Knight relationship attorney.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.