The U.S. Government Accountability Office’s (GAO) new enhanced pleading standard, enacted in July 2025, essentially amounts to a “show your work” rule. If you file a protest, you need to come in with credible allegations that are supported by evidence—or GAO may dismiss the case without even considering the merits. The decisions GAO has issued since announcing the standard offer a roadmap for what that looks like in practice.
GAO’s bid protest regulations state that a protest must include “a detailed statement of the legal and factual grounds of protest including copies of relevant documents.” 4 C.F.R. § 21.1(c)(4). For years, GAO has read that to mean the protest must “provide, at a minimum, either allegations or evidence sufficient, if uncontradicted, to establish the likelihood that the protester will prevail in its claim of improper agency action.” IT Objects, LLC, B-418012.3, Apr. 9, 2020. If a protest didn’t meet that baseline, GAO would dismiss it.
