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ARTICLE · 21 OCTOBER 2026

Recent GAO And COFC Decisions Reinforce Strict Deadlines

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Greenberg Traurig
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GAO bid protest deadlines are strictly enforced, and even minor delays can be fatal to a protest. That principle also applies at the proposal submission stage, where a missed proposal deadline can lead to exclusion from the competitive range that a later protest cannot overcome. Recent GAO decisions reaffirm that protesters and offerors bear the risk of ensuring timely receipt of submissions, including where electronic delivery is affected by email filters, cybersecurity controls, or other transmission issues beyond a contractor’s control.

United StatesGovernment, Public Sector
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  •  The U.S. Government Accountability Office (GAO) and the U.S. Court of Federal Claims (COFC) strictly enforce filing deadlines for bid protests.
  • Recent GAO and COFC decisions reaffirm that strict bid protest deadlines apply to proposal submissions via email that must pass through the Government’s own security systems, which may prevent proposals from being submitted on time.
  • Contractors should file early and confirm actual receipt before the submission deadline. If the submission is delayed, blocked, or not delivered to the designated inbox a proposal may be excluded despite proof of timely transmission under the “late-is-late” rule.

GAO bid protest deadlines are strictly enforced, and even minor delays can be fatal to a protest. That principle also applies at the proposal submission stage, where a missed proposal deadline can lead to exclusion from the competitive range that a later protest cannot overcome. Recent GAO decisions reaffirm that

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