Strict Compliance With Proposal Formatting Instructions

Preparing a proposal for a federal government contract can take a great deal of effort. While contractors sometimes focus primarily on preparing a compelling technical narrative, a series of recent GAO bid protest decisions offer a timely reminder of the importance of strictly adhering to the solicitation’s instructions for formatting proposals. As these cases show, no matter how strong a contractor’s technical solution, missing a formatting requirement could cause the proposal to be excluded from the competition.

• In FI Consulting, Inc., B-423274 (2025), the solicitation allowed offerors to display pictures on the cover pages of their proposals, but prohibited any text. A contractor put its logo–a picture that spelled out the company’s name–on the cover page. The GAO held that the agency properly excluded the company for failing to comply with the prohibition on cover-page text.
• In Horizons Youth Services, B-423202 (2025), the solicitation included page limits for different volumes of the proposal and required proposals to be in one of four fonts: Times New Roman, Arial, Garamond or Calibri. The GAO held that the agency properly excluded an offeror for using Arial Narrow, noting that the use of this font allowed the offeror to include more information in its proposal than would have been possible using the four listed fonts.
• In Supplying Demand, LLC, B-423810; B-423810.2 (2025), the solicitation required offerors to use a Microsoft Excel spreadsheet, attached to the solicitation as an addendum, to submit their pricing proposals. The GAO held that the agency appropriately excluded an offeror that provided its pricing information in a different format.
• In Hive Group, LLC, B-423677 (2025), the solicitation required a “cover page” submission containing certain mandatory information and limited that portion of the proposal to two pages. The GAO held that the agency properly excluded an offeror that included a “standalone graphic title page” with its two-page submission, causing the total submission to be three pages.
• In Landscape Management System, Inc., B-423523.5, B-423523.6 (2026), the solicitation limited offerors’ safety narratives to two pages. After an offeror originally submitted a two-page safety narrative, the agency initiated discussions and accepted revised proposals. The GAO held that the agency properly excluded the offeror for adding two new pages to its revised narrative, saying that it was reasonable for the agency to continue to apply the original page limit to revised proposals.

These cases demonstrate that it can be very dangerous for government contractors to make assumptions about formatting requirements, such as assuming that a certain type of content surely wouldn’t count against a page limit. When possible, it is wise for contractors to verify their assumptions with the agency during a formal Q&A process. Otherwise, the only completely safe approach may be to comply with the strictest reading of the formatting requirements.