How to appeal procurement results: deadlines and procedure

Author — Azat Masaurov. Checked against the law on 19.10.2026.

Below is the procedure under the current Law "On Public Procurement" No. 106-VIII and the Public Procurement Rules (Order of the Ministry of Finance No. 687), which have applied since 2025.

What can be appealed

A supplier who took part in a procurement can appeal actions, inaction and decisions of the customer, organiser, single organiser, expert commission or expert if they violate the supplier's rights (Art. 25, para. 1 of the Law). Most often these are:

• a rejection of your bid that you disagree with;
• the admission of a competitor who does not meet the requirements;
• errors in evaluating and comparing bids;
• procedural violations that changed the outcome.

A complaint is filed only after the results: the deadline runs from the results protocol of the open tender or auction.

What cannot be appealed under this procedure

• Requests for quotations. The portal determines RFQ results automatically (para. 419 of the Rules), and results where the winner is determined by the portal cannot be appealed under Art. 25 (Art. 25, para. 7 of the Law).
• Open tenders using the rating and scoring system (para. 297 of the Rules).
• Procurement under a special procedure (Art. 25, para. 5 of the Law).

The new Law has no separate body such as an appeals commission.

Deadlines step by step

1. Filing — within 3 working days of the results protocol being posted (Art. 25, para. 1 of the Law; para. 588 of the Rules). You can also file on the day of publication. A complaint filed later is not considered (para. 599 of the Rules).
2. Formal check — if the complaint does not meet the requirements or is not signed, it is returned without consideration within 2 working days (para. 598 of the Rules).
3. Decision — within 3 working days after the filing deadline ends: the complaint is upheld or rejected (Art. 25, para. 2 of the Law; para. 592 of the Rules).
4. Review of results — if the complaint is upheld, the commission reviews the results within 2 working days (para. 594 of the Rules).
5. Rejection — published on the portal with a detailed description of the reasons (para. 595 of the Rules).

The Law does not explain how exactly to count "three working days of posting". It is safer to file in the first two working days after the protocol rather than leave it to the last day.

The contract during review. The period for signing the contract is suspended until the complaint review period ends (Art. 25, para. 1 of the Law). According to the portal's instructions, once a complaint is sent, the system suspends contract signing automatically.

How to file a complaint on the portal

According to the goszakup.gov.kz knowledge base:

1. Open the announcement and under "Available actions" ("Доступные действия") choose **"File a complaint" ("Подать жалобу")**. The button only appears in lots where you submitted a bid.
2. Select the lots: you can file one complaint for several lots or a separate one for each.
3. Fill in the required fields and attach files — up to 5 files, each up to 10 MB.
4. Click "Save" ("Сохранить"), "Generate" ("Сформировать"), "Sign" ("Подписать") and "Send" ("Отправить"). The status will change to "Filed" ("Подана").

You can see your complaints under "Workspace" ("Рабочий кабинет") → "My complaints" ("Мои жалобы"). All complaints and decisions on them go into the public register of complaints on the portal (Art. 8, para. 12 of the Law).

What to write in the complaint and what to attach

Under para. 596 of the Rules, the complaint states:

• whom you are appealing against: the name and location of the customer, organiser or expert;
• who is filing the complaint;
• which procurement it concerns;
• the specific facts of the violations and which actions or decisions you are appealing.

Attach documents that support your arguments: screenshots, extracts, references to clauses of the documentation. If a representative files the complaint, a power of attorney is required (para. 597 of the Rules).

Stick to the point and refer to a specific clause of the documentation or the Rules. The complaint is considered within the limits of the arguments stated (para. 590 of the Rules). Anything you leave out will not be checked.

If you disagree with the documentation

It is better to challenge disputed requirements in the documentation before bids are submitted. Comments on draft open tender or auction documentation are sent via the portal no later than 2 working days from the date of the announcement (paras. 170 and 353 of the Rules). Within 2 working days after the discussion ends, the customer makes changes, rejects the comments with reasons or gives clarifications (paras. 172 and 355). The response is published in the protocol of the preliminary discussion.

If the complaint is rejected

• Court. The customer's or organiser's decision on a complaint can be appealed in court (Art. 25, para. 3 of the Law). You must first go through the pre-trial procedure, that is, file a complaint via the portal (Art. 25, para. 6). A claim in administrative court proceedings does not suspend the procurement.
• Authorised body. The Law provides for control based on a supplier's complaint about actions of the customer, organiser or commission (Art. 23, para. 3, subpara. 1 of the Law). Arguments that are checked as part of desk control are not considered under the Art. 25 procedure (para. 591 of the Rules).

What this means in practice

Three working days go by quickly. Check the results protocol on the day it is published, and prepare your arguments and documents right away. If the documentation contains a disputed requirement, it is cheaper to challenge it at the discussion stage than after the results.

How not to miss relevant tenders

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