# Federal Circuit Limits IDIQ Awardee Protest Standing

On September 16, 2026, the U.S. Court of Appeals for the Federal Circuit held that a contractor already selected as an awardee under a multiple-award IDIQ solicitation lacks interested-party standing to challenge awards made to other awardees. The ruling affects post-award protest strategy: successful IDIQ offerors may not be able to use this standing theory to contest a competitor’s award, although the decision did not resolve other potential protest grounds or procedural routes.

- Contractors should assess protest standing before challenging another award under a multiple-award IDIQ, since an awardee’s challenge on this basis may be dismissed.
- Procurement teams and counsel should distinguish this ruling’s specific standing holding from other possible grounds or procedures, which the decision did not address.
- The decision concerns the multiple-award IDIQ procurement in *Island Creek Associates, LLC v. United States*; it does not establish that every protest by an existing awardee is barred.

**Jurisdictions:** federal
**Topics:** Contracting Vehicles
**Published:** September 29, 2026

### Government Entities
- U.S. Court of Appeals for the Federal Circuit (Federal Circuit)
- U.S. Court of Federal Claims (COFC)

### Vendors
- Island Creek Associates, LLC (IDIQ awardee and protester)
- National Air Cargo Group, Inc. (IDIQ awardee that litigated standing)
- Aero Spray, Inc. (IDIQ awardee that litigated standing)
- International Business Sales & Services Corp. (IDIQ awardee that litigated standing)

### Sources
- [Federal Circuit Resolves Court Split Over IDIQ Awardee Standing: Key Takeaways | Crowell & Moring | Crowell & Moring LLP](https://www.crowell.com/en/insights/client-alerts/federal-circuit-resolves-court-split-over-idiq-awardee-standing) - Crowell & Moring LLP