GAO's FY25 Bid Protest Report to Congress Shows Protests are Down, Effectiveness Remains Steady
- Joshua Duvall
- Dec 23, 2025
- 3 min read
On December 12, the U.S. Government Accountability Office ("GAO") published its Bid Protest Annual Report to Congress for Fiscal Year 2025. Required under the Competition in Contracting Act ("CICA"), GAO's bid protest report is noteworthy because it provides a peek into GAO's protest function, including key statistics and GAO's most prevalent grounds on which it sustained bid protests during FY25. [1]
Below is a snapshot of the report, including four takeaways. Government contractors and industry professionals that become familiar with the report – as well as takeaways from GAO's bid protest decisions – will likely gain confidence in their "go/no-go" protest calculus and the efficacy of the bid protest process overall.
Notable Statistics
Number of Cases – 1,688 cases (down, 1,803 in FY24)
Sustain Rate – 14% (down, 16% in FY24)
Effectiveness Rate – 52% (same, 52% in FY24) [2]
Task Order Protests – 359 (up, 346 in FY24)
Alternative Dispute Resolution – 53 (down, 76 in FY24)
Most Prevalent Grounds For Sustaining Protests
Unreasonable technical evaluation [3]
Unreasonable cost or price evaluation [4]
Unreasonable rejection of proposal [5]
Takeaways
First, GAO heard fewer protests, just 1,617 in the last fiscal year (down from 1,740 in FY24). [6] Interestingly, while the number of bid protests at GAO has been trending downward, the opposite is happening at the U.S. Court of Federal Claims ("COFC"), where the number of protests is trending upward. In fact, over the last three fiscal years, the COFC has averaged over 200 protests per year – a considerable uptick from prior years. [7]
Second, GAO's report shows that its sustain rate decreased from 16% to 14%. In FY 24, GAO sustained 61 bid protests, while in FY25 it sustained just 53. At first blush, the difference does not appear to be too significant, as the sustain rate is still around the 15% mark of years past. Given the effectiveness rate, discussed next, protesters should still take comfort in knowing that they will recieve some form of relief in a bid protest at GAO.
Third, protesters still have a 52% chance of obtaining some form of relief at GAO (voluntary corrective action or sustain). This "effectiveness rate" is great news – as it has been for several years now – and indicates that GAO's bid protest process works. It also shows that procuring agencies are willing to take corrective action to fix errors that were brought to light in a bid protest.
Fourth, GAO continued to see a significant number of protests involving task orders. FY25's total, 359, was a slight increase from the 346 task order protests that GAO heard in FY24. As the chart shows, when looking at the past decade, the numbers show an upward trajectory, though the numbers appear to be flattening. Given this trend, and that the FY25 NDAA increased DOD's task order threshold to $35 million, it will be interesting to see how these figures take shape in years to come.
Conclusion
Overall, the FY25 statistics paint an interesting picture. While much has been said in the halls of Congress about protests stymying the procurement process, the data tell a different story –– at GAO, protests are down. And despite seeing a fewer number of bid protests, GAO's effectiveness rate is still above 50%. This is welcome news for government contractors because it shows that GAO's bid protest process works. For task order protests, it will be interesting to see how the numbers take shape over the next couple of years and whether DOD's higher jurisdictional threshold will have any meaningful impact on the data. Time will tell. Finally, as noted above, unlike GAO, the COFC has seen an uptick in protest activity in recent years. It will be interesting to see how this, too, unfolds over the next couple of years.
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[1] See 31 U.S.C. § 3554(e)(2).
[2] The "effectiveness rate" is based on a protester obtaining some form of relief, either as a result of voluntary agency corrective action or GAO sustaining the protest.
[6] GAO's data is based on "B-" numbers and does not the reflect the total number of procurements that were challenged. In other words, if a protester files a supplemental protest, it adds to the "B-" number assigned to the protest. Thus, the number of procurements challenged is often less than the number of protests filed.
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