When an agency conducts a multiple-award indefinite delivery, indefinite quantity (IDIQ) competition, successful awardees often wonder whether they can protest the agency’s award to other companies at the U.S. Court of Federal Claims. For over a decade, the answer has been a murky “maybe” with various Court of Federal Claims decisions divided over the issue. But in a precedential September 16, 2026, decision, the U.S. Court of Appeals for the Federal Circuit in Island Creek Associates, LLC v. United States resolved this split, holding that IDIQ contract awardees lack standing to challenge the IDIQ awards to fellow competitors.

To have standing to bring a bid protest at the court, a protester must be an “interested party,” meaning an “actual or prospective bidder whose direct economic interest would be affected by the award of the contract.” American Federation of Government Employees v. United States, 258 F.3d 1294, 1302 (Fed. Cir. 2001). While this is commonly understood to refer only to unsuccessful offerors, over a decade ago, in National Air Cargo Group, Inc. v. United States, 126 Fed. Cl. 281 (2016), the court held that an IDIQ awardee has standing to challenge the IDIQ awards to other companies, reasoning that diminution of value in the task order pool is adequate economic harm to demonstrate “interested party” standing.  

But a series of more recent court decisions have declined to follow National Air Cargo. In Aero Spray, Inc. v. United States, 156 Fed. Cl. 548 (2021) (as we discussed in more detail here), the court held that the “veritable tsunami of Federal Circuit decisions” all support the holding that an awardee is not an “interested party” to challenge awards of fellow IDIQ awardees, reasoning that a protester filing a post-award protest must establish a “substantial chance of award,” which is something an awardee cannot do. The Aero Spray court further explained that increased competition at the task order level cannot confer interested party standing because awardees are “not guaranteed anything more than the mandatory minimum contract amount and the opportunity to compete” but “does not include a guaranteed level of competition.” The court in Island Creek Associates, LLC v. United States, 172 Fed. Cl. 729 (2024) followed Aero Spray’s reasoning, holding that an awardee lacked interested party standing to challenge modifications an agency made to an IDIQ contract that expanded the competitor pool. And earlier this year, in International Business Sales & Services Corp. v. United States, 181 Fed. Cl. 584 (2026), the court again concurred with Aero Spray, emphasizing that a protester only has standing when it “is an actual, but disappointed, offeror for that award.”

In resolving this split, the Federal Circuit in Island Creek ruled that a protester lacks interested party standing to challenge the award of another IDIQ contract holder. Citing to its recent en banc decision in Percipient.ai, the Federal Circuit explained that only “a disappointed bidder” qualifies as an “actual or prospective bidder” for interested party standing purposes. And, therefore, where a company “was a successful bidder” for an IDIQ award, it “could not have been an actual or prospective bidder for the contract awarded” to another offeror and cannot have standing to challenge that award. In so doing, the Federal Circuit’s decision provides much needed clarity to the government contractor community about the ability to bring post-award challenges in multiple-award IDIQ procurements.