Challenging Procurement Results: How to File a Complaint with the FAS

If your rights or the rules of competition have been violated in the course of a government procurement, you may challenge those actions before the Federal Antimonopoly Service (FAS). Below, we walk through the procedure step by step.

Step 1. Assess Whether a Challenge Is Worthwhile

Before investing your time, calculate whether the potential outcome justifies the effort. The FAS reviews a complaint within no more than 5 business days of filing, with a decision issued within an additional 3 business days. Information regarding complaints and decisions is published on www.zakupki.gov.ru in the complaints registry.

Step 2. Identify the Violation

A complaint may be directed against:

  • Procurement documentation (unlawful requirements, form violations)
  • Actions or inaction of the contracting authority, authorized body, or procurement commission
  • The electronic trading platform operator

Step 3. Observe the Deadlines

The law imposes strict time limits that vary depending on the subject of the complaint. Missing the deadline results in the complaint being returned without review.

Step 4. Draft the Complaint Correctly

The complaint must include:

  • Name and contact information of the respondent (contracting authority, operator, etc.)
  • Your name, address, email, and telephone number
  • A reference to the specific procurement (procurement number on zakupki.gov.ru)
  • A description of the challenged actions, with explanation of the alleged violation
  • A list of attachments and the attachments themselves

Step 5. Submit to the Proper Authority

Complaints are assigned to FAS regional offices according to jurisdictional rules. A misdirected complaint may be forwarded — without any adverse consequence to the complainant. However, identifying the competent authority at the outset is preferable.

Step 6. Prepare for the Hearing

Within 2 business days of filing, you will receive notice of the date and location of the hearing. At the hearing, you may:

  • present additional arguments
  • supplement the complaint
  • withdraw the complaint before a ruling is issued

Drafting a well-grounded FAS complaint is a task for an attorney with government procurement experience. An imprecise framing of the issue or a missed deadline may forfeit your right to protection. Contact us — we will prepare the complaint and represent your interests at the hearing.

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