Shortly after taking office in 2025, President Donald Trump directed the Pentagon to develop a missile defense shield for the United States. President Trump announced that the system would cost $175 billion and should be operational by the end of his term in January 2029.[1] Despite skepticism from critics regarding the feasibility and cost of the project, the Department of Defense (DoD) is moving forward with a major procurement to satisfy the President’s directive.
DoD’s procurement is called the Scalable Homeland Innovative Enterprise Layered Defense or “SHIELD.” The government intends to establish a flexible contract vehicle under which numerous qualified companies will compete to provide aspects of the defense system under future task orders.
On December 2, 2025, the government announced an initial set of awards under the SHIELD procurement.[2] In what it described as the first phase in a series of staggered awards, DoD made awards to over 1,000 qualifying offerors. In its announcement, DoD noted that it had received offers from 2,463 companies.
Below, we explore critical issues that companies interested in competing for future SHIELD work—either as a prime, subcontractor, or team member—should consider. First, we introduce the SHIELD procurement and examine unique aspects of its structure. Second, we analyze the complicated posture that disappointed SHIELD offerors will face if they want to challenge the government’s actions by filing a bid protest.
Background
On January 27, 2025, President Trump issued Executive Order 14186, “The Iron Dome for America.”[3] The Executive Order asserted that potential attacks by ballistic, hypersonic, and cruise missiles, and other advanced aerial attacks constitute “the most catastrophic threat facing the United States.”
To address this threat, the Executive Order explained that the United States would defend the country by deploying a next-generation missile defense shield. DoD’s Missile Defense Agency (MDA) began conducting market research to assess industry capabilities with respect to developing a missile shield. It also decided to rename the program as the “Golden Dome for America.”[4]
Several months later, MDA announced that SHIELD would be the first major procurement in furtherance of the Golden Dome initiative. After issuing a draft solicitation, MDA released a public request for proposals (RFP) on September 10, 2025.
SHIELD Procurement
The final SHIELD RFP established a full and open competition for a multiple award indefinite-delivery, indefinite-quantity (IDIQ) contract. The goal of the IDIQ is to ensure continuous, layered protection against air, missile, space, cyber, and hybrid threats “originating from any vector—land, sea, air, space, or cyberspace.” The solicitation also noted that the contract will support both classified and unclassified programs.
MDA intends to award IDIQ contracts to numerous companies as part of a broad and flexible acquisition approach that will be used by MDA and other DoD entities. In this regard, after the overarching IDIQ contract is established, defense agencies will be able to conduct competitions among IDIQ recipients and award task and delivery orders for aspects of the SHIELD. With a 10-year ordering period and a maximum value of $151 billion, the SHIELD procurement will be one of the largest acquisitions in U.S. history.
Award Process
The government’s methodology for making SHIELD awards is relatively straightforward, which is interesting for a procurement of this size, duration, and complexity.
The RFP states that the contracting officer intends to make awards to all qualified offerors. The RFP defines qualified offerors as an offeror that (i) is determined to be a responsible source, (ii) submits a technically acceptable proposal, and (iii) the contracting officer has no reason to believe would offer other than fair and reasonable pricing.[5]
To determine whether a proposal is technically acceptable, the government will evaluate an offeror’s corporate experience and assign a rating of either acceptable or unacceptable. The RFP invites offerors to demonstrate their experience in at least two areas of the overall SHIELD scope of work.
The RFP lists a total of 19 scope of work areas. The broad range of the SHIELD effort includes, for example, research and development (R&D), prototyping, architecture development, systems engineering, test and evaluation (T&E), and weapon design and development.
The RFP does not establish a maximum number of awardees for the various scope of work areas or under the IDIQ. Thus, offerors do not appear to be competing with each other to secure awards under the IDIQ contract. Moreover, to promote flexibility, the government plans to allow additional companies to join the procurement mid-contract (on-ramp) while also permitting companies to relinquish their contracts (off-ramp).
As demonstrated by MDA’s initial award to more than 1,000 companies, the government’s award procedures suggest that there will be a relatively low bar to receiving an award under the overarching IDIQ contract. At present, there does not appear to be a definite timeline as to when additional IDIQ contract awards will be made.
Bid Protest Considerations
Although (and perhaps because) MDA is making a large number of awards at the IDIQ level, the competition at the task order level—when the government will select a single awardee—is likely to be intense. This is especially true given that some of the task orders are likely to be significant in terms of scope, dollar value, and competitive positioning for future task orders.
When there are close competitions and large dollar values at stake, bid protests are likely to occur. Bid protests are generally recognized as a vital feature of the federal procurement system, as they reinforce confidence in the fairness of the competitive process. In particular, the bid protest process is effective both in reigning in arbitrary government action as well as preventing private companies from engaging in improper competitive practices.
Most government contractors are generally familiar with the process for filing a formal challenge to an agency’s procurement actions, whether it is filed at the Government Accountability Office (GAO) or at the Court of Federal Claims (COFC). What is less known are the nuances of the Federal Acquisition Streamlining Act of 1994 (FASA)[6] and subsequent statutes that restrict bid protest jurisdiction for task order procurements.
The FASA Task Order Bar
Under FASA, the GAO has exclusive jurisdiction over bid protests involving the issuance of a task order, but only for those task orders that exceed certain dollar thresholds. Subsequent legislation has provided GAO jurisdiction to consider protests of task orders issued by civilian agencies in excess of $10 million and task orders issued by DoD in excess of $35 million.[7] These rules create what is generally referred to as the FASA task order bar.
Notably, FASA provides an exception to the bar for a protest alleging that the order increases the scope, period, or maximum value of the contract under which the order is issued. Such protests can be brought at either GAO or the COFC.
Because the SHIELD procurement contemplates awards at both the IDIQ and task order levels, the landscape for potential protests is complicated. Accordingly, both experienced defense contractors and potential new entrants into the defense space should carefully consider issues related to jurisdiction and standing at the two primary protest forums.
IDIQ Level Protests
Offerors that do not receive an award of the SHIELD IDIQ contract may file a bid protest at GAO or COFC. This is because, under GAO and COFC case law, challenges to the government’s awards in an overarching IDIQ procurement are not considered to be subject to the FASA task order bar.[8] Accordingly, disappointed offerors may contest the government’s award decisions. For instance, a company could challenge adverse determinations made by MDA with respect to its technical capability or responsibility as a source.
Companies that receive an IDIQ award may want to challenge IDIQ awards made to other companies in an effort to reduce competition for future task order awards. Putting aside the skepticism that generally greets offerors using the protest process to limit competition, the viability of such a protest would depend on the chosen forum. For its part, GAO takes the position that an IDIQ awardee does not have standing to contest an agency’s decision to consider or make additional awards to companies in an IDIQ contractor pool.[9] In contrast, COFC has held that an IDIQ awardee has standing to challenge the government’s award of another IDIQ contract under the same solicitation to a different offeror.[10]
Task Order Level Protests
Given the size and complexity of developing and building a nationwide missile defense system, there is a substantial chance that the majority of the task orders will exceed the $35 million threshold and thus be subject to protest at GAO. Thus, in light of the task order bar, the primary forum for SHIELD-related protests at the task order level will be GAO.
It is nevertheless possible that SHIELD competitors could find themselves before the COFC. For instance, a contractor could invoke the exception to the FASA task order bar and challenge the scope, period, or maximum value of a SHIELD task order. The scope of the IDIQ is broad, and thus a protester would have difficulty demonstrating that a particular task order is not reasonably encompassed within the RFP’s 19 scope of work areas. That said, given the ambitious goals and substantial scale of the Golden Dome initiative, there is a genuine risk that the completion of the effort could exceed the $151 billion ceiling or may extend beyond the 10-year ordering period.[11]
Conclusion
Although more than 1,000 SHIELD IDIQ awards have been made, the government has not established a timeline for further IDIQ contract awards or the solicitation of follow-on task orders.
The procurement’s structure may reduce bid protests by disappointed offerors with respect to IDIQ contract awards. More fights are likely to come in later rounds of task or delivery order awards, and potential offerors must recognize the restrictions applicable to such potential SHIELD task order protests.
In short, although SHIELD presents significant business opportunities, interested companies must know their protest rights to preserve remedies available for addressing improper procurement actions.
[1] Trump selects $175 billion Golden Dome defense shield design, appoints leader | Reuters
[2] U.S. Department of Defense, Contracts for Dec. 2, 2025.
[3] Exec. Order No. 14186, 90 Fed. Reg. 8767 (Feb. 3, 2025).
[4] Missile Defense Agency, Request for Information Amendment 3, Feb. 24, 2025. https://sam.gov/opp/32d6b477622640e588bb5bbcf89ae646/view
[5] Notably, the government did not request that offerors submit cost or pricing data to be eligible for an IDIQ contract. Instead, the government intends to evaluate price or cost as an evaluation factor for each order—effectively deferring any meaningful analyses of these issues until it conducts task order competitions.
[6] Public Law 103-355 (Oct. 13, 1994).
[7] 41 U.S.C. § 4106(f) (civilian agencies); 10 U.S.C. § 3406(f) (DoD).
[8] See Fluor Intercontinental, Inc. v. United States, 147 Fed. Cl. 309 (2020); Delta Risk, LLC, B-416420, Aug. 24, 2018, 2018 CPD ¶ 305.
[9] Aegis Defense Services, LLC, B-412755, Mar. 25, 2016, 2016 CPD ¶ 98.
[10] National Air Cargo Grp., Inc. v. United States, 126 Fed. Cl. 281, 295 (2016).
[11] In May 2025, the Congressional Budget Office estimated that the Golden Dome could cost as much as $831 billion over two decades. P. Swagel, Dir. CBO, Effects of Lower Launch Costs on Previous Estimates for Space-Based, Boost-Phase Missile Defense, at 2 (available at https://www.cbo.gov/system/files/2025-05/61237-SBI.pdf). It is currently unclear to what extent other procurement vehicles will be used in connection with the Golden Dome initiative.