The new administrative review route in plain terms
If you have just lost a Ugandan government tender and believe the award was flawed, you are not without recourse. The process changed in 2024: you no longer petition the PPDA itself; you complain first to the Accounting Officer of the procuring entity, then appeal directly to the PPDA Appeals Tribunal. The route is designed to be quick, but it is unforgiving on time. Most challenges in the 2025 cases were struck out not because they lacked merit, but because they missed a statutory window by days.
The legal framework sits in the Public Procurement and Disposal of Public Assets Act, Cap. 205, and the Administrative Review Regulations 2023 (Statutory Instrument 106 of 2023), in force 5 February 2024. Before the reform, a bidder petitioned the PPDA and then went to the Tribunal. The 2023 regulations removed the PPDA from the review chain to cut delays; now the complaint goes to the Accounting Officer, and an appeal goes straight to the Tribunal. If your challenge turns on how bids were submitted or evaluated, being current with Uganda's e-GP 2.0 requirements will help you speak the same language as the procuring entity.
Step one: complain to the Accounting Officer — and expect a decision fast
File your complaint with the Accounting Officer of the entity that ran the tender. The law requires the Accounting Officer to make and communicate a decision within 10 calendar days of receiving your complaint. That is ten days, not working days. This compressed window is why preparation matters: have your grounds, documents, and the specific relief you want ready before you file. Before you file, it is worth reviewing the common procurement mistakes Ugandan businesses make when contesting an award, because procedural missteps at this stage can be fatal.
At the same time, confirm you have standing. Under s.115(1)(b), bidders and non-bidders whose rights are adversely affected may apply directly to the Tribunal. You do not have to have submitted a bid if you can show that the procurement decision adversely affects your rights. While the complaint is pending, the procurement or disposal process is suspended, and the Accounting Officer must not enter into a contract.
Step two: appeal to the PPDA Appeals Tribunal within the right window
If you are dissatisfied with the Accounting Officer's decision, or if the Accounting Officer simply fails to decide, your next move is the PPDA Appeals Tribunal. Your filing window depends on which situation applies.
- Accounting Officer made a decision: file within 10 working days after service.
- Accounting Officer failed to decide: file within 10 calendar days of the date the decision was due.
- Alleging a conflict of interest against the Accounting Officer: file within 10 days of the impugned act or omission.
These deadlines are jurisdictional: late filing leads to automatic striking-out, regardless of how strong your case is. In FY2024/25, the Tribunal disposed of all 33 applications within the statutory 15 working days, with no backlog. That speed is good for business, but it means there is no informal grace period. You are either in time or you are out.
The High Court appeal does not keep the process frozen
A further appeal to the High Court must be filed within 30 days and only on questions of law. Unlike administrative review, it does not suspend the procurement process. By the time you litigate, the contract may already be signed.
What the Tribunal can order
The Tribunal has real remedial power. It can confirm, vary or set aside the Accounting Officer's decision, set aside a Best Evaluated Bidder notice, and order a fresh evaluation. This is not a symbolic review; when filings are timely, the Tribunal has set aside a Best Evaluated Bidder notice and ordered fresh evaluation — as in Dentons Advocates v Uganda Electricity Transmission Company Ltd (UETCL). For context on how such disputes can escalate, see the separate look at UETCL procurement litigation risk.
The 2025 cases: late filing kills most challenges
The Tribunal's 2025 decisions published on ULII show a consistent pattern. Goldstar Insurance Co Ltd v Uganda National Oil Company was dismissed as time-barred for failing to apply within the 10-day period. Subamu Investment Ltd v Iganga Municipal Council was struck out for filing after the 10-working-day limitation. Ttumuka General Auctioneers Ltd v Pader District Local Government was dismissed as time-barred for missing statutory deadlines. Gamose Holdings Ltd v Lira University was struck out for late filing after the Accounting Officer failed to decide within the statutory timeframe. These are not procedural flukes; the Tribunal's FY2024/25 annual report identifies applicants failing to file within statutory timelines as one of the two most common issues, alongside procuring entities failing to properly evaluate bids.
Administrative review first: a precondition you cannot skip
In Fafa Glass Industries Ltd v Ministry of Works & Transport, the Tribunal barred jurisdiction because the party failed to lodge the statutory administrative review first. This is a reminder that the Tribunal is an appeal body, not a first-instance court. If you skip the Accounting Officer complaint and go straight to the Tribunal, you may lose before you start — no matter how compelling your technical or commercial arguments are.
Practical checklist before you lodge a challenge
- Confirm the date the Accounting Officer received your complaint. Your first deadline runs from that moment.
- Identify which filing window applies: 10 working days after service of a decision, 10 calendar days after the due date if no decision, or 10 days for a conflict-of-interest allegation.
- Preserve evidence that the procurement process was suspended and that no contract was signed while the review was pending.
- Decide whether the relief you need is one the Tribunal can grant — such as setting aside a Best Evaluated Bidder notice or ordering a fresh evaluation.
- Diarize the 30-day High Court appeal window now, even though it is only on questions of law and does not keep the procurement suspended.
Where this leaves you as a decision-maker
Challenging a tender award in Uganda is not a soft inquiry; it is a formal, time-bound legal process with real downside if mishandled. The 2024 reforms made the route more direct, but they did not make it forgiving. Treat the deadlines as fixed, keep your filing evidence, and understand what the Tribunal can and cannot order before you spend money on advocacy. If the decision depends on your specific facts — and it usually does — get independent advice before committing. As an independent, vendor-neutral advisory, our role is to help you evaluate the decision landscape, not sell you a particular outcome.