01
The decision determines the remedy.
First identify the decision being challenged and the procurement procedure. Not every disagreement can be challenged, and not every remedy falls within the CGR’s jurisdiction.
Objection
Challenges the solicitation document before bids are submitted. Potential bidders and legally constituted organizations meeting Article 95’s conditions may file.
Appeal
Challenges an award or a decision declaring a major tender deserted or unsuccessful, subject to the applicable participation, standing and substantiation requirements.
Revocation
Seeks review of the final decision by the administration in the cases provided by law and regulation. It is not an appeal to the CGR.
Law No. 9986, Arts. 86, 95, 97 and 99; Regulations, Arts. 241 and 270.
02
Timing is part of the strategy.
These are ordinary filing deadlines, not decision-making deadlines. Check the decision, publication or communication, notification to all parties and applicable calendar before establishing the due date.
Objection · major tender
Decided by the Comptroller General’s Office (CGR).
Following publication of the solicitation document.
Ley N.º 9986, art. 95 a)
Objection · minor tender
Decided by the contracting administration.
Following communication of the solicitation document.
Ley N.º 9986, art. 95 b)
Objection · reduced tender
Decided by the contracting administration.
Following communication of the solicitation document.
Ley N.º 9986, art. 63 n); Reglamento, art. 255
Appeal · major tender
Decided by the CGR; participation and standing are required.
Following communication of the final decision.
Ley N.º 9986, art. 97
Revocation · minor tender
Decided by the issuing body; a decision by its head may be requested as provided in Article 99.
From the day following communication of the final decision, applying business-day counting rules.
Ley N.º 9986, art. 99
Revocation · reduced tender
Decided by the contracting administration.
Following communication of the final decision.
Ley N.º 9986, art. 63 l); Reglamento, art. 270
Counting starts on the business day after all parties have been notified (Law, Art. 86; Regulations, Art. 242), taking account of the trigger for each remedy. This overview does not cover every special regime, amendment to a solicitation or special cases within reduced procedures. Do not automatically apply these deadlines to another tender.
03
Disagreement is not enough.
A challenge must connect verifiable facts, a material legal infringement and appropriate evidence. Grounds must accompany the initial filing; do not rely on completing them later.
- Identify the infringement
Specify the clause or part of the decision challenged, the rule or principle infringed and the relief sought.
- Provide technical evidence
When challenging a technical requirement, supply supporting studies and evidence. A commercial preference does not establish a legal infringement.
- Establish standing and a better entitlement
For challenges to final decisions, assess your eligibility and ability to obtain the award where required. Challenging another bid does not alone establish your entitlement.
- Check preclusion
An argument that should have been raised earlier may be precluded. Distinguish an established clause from a subsequent amendment that can still be challenged.
Law No. 9986, Arts. 87, 88 and 90; Regulations, Arts. 245, 246 and 256.
04
The law, applied to the record.
Read decisions in full: facts, the subject of the contract, procedural stage and applicable rules define the scope of each principle.
R-DCP-SICOP-02004-2026 · 3 November 2026
Clarity in monthly service acceptance
In an objection concerning CCSS security services, the CGR partly upheld the claim only to require clear deadlines and conditions for monthly service acceptance. Other alleged infringements concerning payment commencement and deductions were not established. This case-specific correction is not a general prohibition on deductions. Source: full decision, p. 3.
Read decisionR-DCP-SICOP-02001-2026 · 3 November 2026
Evidence and a better entitlement must be established
In an appeal concerning paint for MOPT, the CGR summarily rejected the challenge as manifestly unfounded. The appellant did not provide formal expert or documentary evidence technically refuting the disputed certification. Its potential score of 86.5% also remained below the awardee’s 87.4%. Challenging a competing bid alone did not establish a better entitlement. Source: full decision, pp. 3–4.
Read decisionA previous decision does not guarantee the same outcome in another procedure.
05
A document alone does not complete a filing.
Article 87 requires filing through the unified digital system. The Regulations require the designated electronic form, with attachments providing evidence for the arguments made.
- 01Review the record
Gather the tender number, solicitation and amendments, final decision, notifications, bids and relevant evaluations.
- 02Use the appropriate form
Set out the arguments in SICOP’s designated remedy fields. An attachment or email is not a substitute for the required form.
- 03Verify representation and signature
Confirm the filer’s authority and required signature. Check every attachment for completeness and relevance.
- 04Retain proof of filing
Confirm successful submission, retain the receipt and monitor notifications and hearings. Uploading a file does not by itself establish that a remedy has been filed.
Law No. 9986, Art. 87; Regulations, Arts. 243 and 244. All hours of the deadline day are valid for filing; do not wait until the last moment.
06
Sources and editorial scope
- General Law on Public Procurement No. 9986
Arts. 63 and 86–99. Statutory text consulted in the supplied consolidated edition updated to October 2026, pp. 122–138.
- Regulations to Law No. 9986 · Decree No. 43808-H
Arts. 241–271. Regulatory text consulted in the same edition, pp. 422–451.
- Reference edition: Sofía Espinoza Salas · EDNASSS / CCSS, 2026
Ley General de Contratación Pública y su reglamento: concordada y comentada. This original overview summarizes statutory provisions and does not reproduce the author’s commentary.
- CGR criteria · ITLEX Insights
Repository for consulting decisions of Costa Rica’s Comptroller General’s Office.
This guide provides preliminary general information only. It is not legal advice, does not guarantee an award or outcome, and does not create an ITLEX-client relationship. Check current rules, the procurement record and deadlines for your specific circumstances. English text is explanatory; the Spanish legal texts govern.
© 2026 ITLEX. Original editorial writing and presentation. The cited public laws and decisions remain public; no exclusive rights over them are claimed.
