The Government Accountability Office's recurring bid-protest report — Bid Protests: Key Features and Trends (GAO-25-108652) — sets the FY2025 baseline for federal protest activity. The numbers are the starting point for any FY2026 protest strategy decision, especially given NDAA Section 875's incumbent payment-withholding and the Federal Circuit's CICA stay-override decision. Coverage from GAO.
What this report covers
- Total protests filed at GAO in the fiscal year
- Sustain rate (protests where GAO formally agreed with the protester)
- Effectiveness rate (protests resulting in some form of relief, including voluntary corrective action)
- Top agencies by protest volume
- Most common sustained-protest grounds (unequal treatment, evaluation flaws, source-selection-decision errors)
Why FY2026 will look different
Three forces are reshaping the protest landscape going into FY26: incumbent payment-withholding under §875, the easier CICA-stay-override standard, and the Revolutionary FAR Overhaul shifting more discretion to COs. Expect fewer thin protests, more meaningful override challenges, and more sustains turning on agency justification quality.
What to do
- Pull the GAO report and benchmark your win/loss against the sector averages
- Train bid-defense teams on the most common sustained grounds — unequal treatment leads the list
- If you're an incumbent: re-evaluate your protest playbook before §875 implementation rules drop in June 2026