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Disqualified for Using a Company Logo? GAO Reminds Contractors That Formatting Rules Matter

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In FI Consulting, Inc., B-423274 (April 11, 2025​), FI Consulting, Inc. (FIC) protested its elimination from a procurement for U.S. Department of Agriculture (USDA) program support services after the agency rejected its proposal for including a company logo (a picture containing text) on its cover page—an act the agency deemed noncompliant with explicit formatting instructions in the solicitation.

The Decision
GAO denied the protest in part and dismissed the protest in part, ruling that:

  1. Strict Formatting Rules Matter: GAO sided with the agency, finding that the solicitation clearly prohibited images containing text and warned that failure to follow formatting instructions would render a proposal “deficient” and ineligible for award​.
  2. Q&A Response Reinforced the Rule: A pre-award question explicitly asked if the rule applied to cover pages and logos. The agency responded: “Do not include branding information as a picture if it includes text.” Because FIC ignored that clear warning, GAO held that it was properly removed from the competition​.
  3. No Ambiguity Found: GAO rejected FIC’s claim that the rule was unclear. It found the protester’s interpretation—that company logos were exempt—to be unreasonable in light of the solicitation’s plain language and the Q&A response.
  4. No Waiver Required for Minor Errors in FAR Part 8 Procurements: FIC argued in the alternative that the error should have been waived as a minor informality pursuant to FAR 14.405. GAO dismissed this argument, noting that FAR 14.405 was not applicable to the federal supply schedule procedures used for this FAR Part 8 procurement.

Key Takeaways for Contractors

  1. Read Formatting Instructions Closely, Including the Q&As: Even seemingly harmless elements like a company logo can violate formatting rules if they conflict with the solicitation.
  2. Assume “Shall” Means “Shall”: If a solicitation says “shall be ineligible for award” due to formatting errors, GAO will take that seriously.
  3. No Guarantee of Leniency Under Federal Supply Schedule Contracts: Under federal supply schedule procedures, agencies have broad discretion and are not obligated to waive minor mistakes—even those that don’t affect the agency’s evaluation.
  4. This Case Is a Cautionary Tale: FIC didn’t lose on price or merit, but rather on a branding choice on the cover page. This case should serve as a costly reminder that formatting can be just as important as substance.