2025 GAO Bid Protest Annual Report: Where Have All the Protests Gone?
Client Alert | 19 min read | 12.18.25
On December 12, 2025, the U.S. Government Accountability Office (GAO) released its annual report on bid protests for fiscal year 2025, containing the full statistics shown below:
Bid Protest Statistics for Fiscal Years 2021-2025
The total number of cases filed (1,688) and sustained (53) decreased from FY 2024. While the number of sustains was the lowest it has been in over two decades, the 14% sustain rate remains comparable to recent years (the 31% sustain rate in FY 2023 was an anomaly owing to an unusually high number of protests challenging a single procurement). Additionally, GAO’s “effectiveness rate”—the percentage of cases in which the protester received relief, including GAO sustains and voluntary corrective actions—remained above 50%, likewise resembling previous years.
Importantly, the number of merit decisions (380) represents a multi-year low, continuing a downward trend seen in FY 2024.
The most prevalent grounds upon which GAO sustained protests in FY 2025 were (1) unreasonable technical evaluations; (2) unreasonable cost or price evaluations; and (3) unreasonable rejection of proposal. The first two categories have frequently been identified as among the most common grounds for protest sustains, while the third—unreasonable rejection of proposal—was identified for the first time in recent history. The most prevalent grounds for sustained protests over the past ten years (according to GAO’s corresponding annual reports) are shown in the table below:
Key Takeaways
- The number of protests filed continues a notable downward trend we’ve been monitoring and tracks anecdotal reports that protesters are increasingly turning to the Court of Federal Claims (when available) as an initial protest forum. It will be interesting to watch whether, and how significantly, GAO protest filings continue to dip in FY 2026, particularly given the government shutdown, during which GAO and large parts of the federal government were closed for over a month.
- Notwithstanding the lower number of cases filed, the effectiveness rate remaining above 50% demonstrates that bid protests continue to be an effective and efficient oversight mechanism for the federal procurement system.
- GAO’s report accompanying the statistics highlights the importance of early action in bid protests. Specifically, GAO noted that “a significant number of protests filed with our Office do not reach a decision on the merits because agencies voluntarily take corrective action in response to the protest rather than defend the protest on the merits.” This is an important reminder (1) to protesters to craft strong initial filings; and (2) to awardees to promptly intervene and defend their rights. Sitting on the sidelines and waiting is often not a viable option when so many protests are resolved via early corrective action.
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