Alert
12.22.25
On December 12, 2025, the Government Accountability Office (GAO) published its Bid Protest Annual Report to Congress for Fiscal Year 2025. The GAO’s report, which is mandated by the Competition in Contracting Act, lists its key statistics for FY 2025 bid protest activity. The report also includes a chart providing similar bid protest statistics for fiscal years 2021–2025. This five-year snapshot provides some valuable insight into current bid protest trends and developments at the GAO.
Most notably, the GAO’s report reveals that the protest statistics continue to remain near the levels seen prior to the anomalous statistics experienced in FY 2023. The GAO’s protest statistics for 2023 were inflated due to an usually high number of protests challenging a single procurement as discussed in a previous client alert, but the FY 2025 report indicates that the most recent statistics have decreased to reflect the percentages from FY 2024 and years prior to FY 2023. With that said, the report indicates that contractors filed 1,617 protests in FY 2025, which represents a 7 percent decline from the 1,740 protests filed in FY 2024.
The GAO’s FY 2025 sustain rate of 14 percent decreased from 16 percent in FY 2024. However, the GAO’s FY 2025 effectiveness rate, which includes protests that resulted in either voluntary agency corrective action or a GAO decision sustaining the protest, remained at the FY 2024 rate of 52 percent.
The GAO also reported that the number of cases which the GAO attempted to settle through alternative dispute resolution (ADR) decreased substantially to 53 in FY 2025 from 76 in FY 2024. The GAO continued its trend of minimizing the number of hearings it conducted to only three hearings in FY 2025 and one hearing in FY 2024 after conducting a total of 37 hearings in FY 2021–2023.
Finally, the report shows that the most prevalent reasons for the GAO to sustain a protest in 2025 were (1) unreasonable technical evaluation, (2) unreasonable cost or price evaluation, and (3) unreasonable rejection of proposal. Notably, the first two of the protest grounds on this FY 2025 list were among the three most highly successful protest grounds in FY 2024.