The Data
The analysis is based on WIPO applications filed in Q1 2025 (January, February and March), chosen specifically because it gave every application enough time to complete the full examination cycle in each of its designated countries. The final dataset covers a total of 15,187 trademark applications.
Across this sample, the average number of office actions per application was 2.07, meaning the typical WIPO filing doesn't sail through unopposed. It picks up objections in at least two of its designated countries during the examination phase.
How many office actions does a typical application receive?
Roughly a quarter of applications (24.94%) clear examination without a single office action. But that also means three out of four don't:
Office actions (OA) received | Applications | Share of total |
|---|---|---|
0 | 3,788 | 24.94% |
1 | 4,300 | 28.31% |
2 | 2,725 | 17.94% |
3 | 1,596 | 10.51% |
4 | 997 | 6.56% |
5 | 623 | 4.10% |
6 | 362 | 2.38% |
7 | 242 | 1.59% |
8 | 175 | 1.15% |
9 | 108 | 0.71% |
10 | 79 | 0.52% |
11+ | 192 | 1.26% |
Nearly half of all applications (46.25%) receive two or more office actions, each one requiring its own local response, often through local counsel, before the application can move forward.
Designating more countries multiplies the risk
The more countries an application designates, the more independent examinations it's exposed to, and the numbers scale accordingly:
Countries designated | Applications | Average OA count |
|---|---|---|
1 | 2,025 | 0.45 |
2 | 1,946 | 0.78 |
3 | 1,754 | 1.04 |
4 | 1,658 | 1.29 |
5 | 1,273 | 1.72 |
6-10 | 3,460 | 2.38 |
11-20 | 2,087 | 3.96 |
21+ | 956 | 6.63 |
An application designating a single country averages fewer than one office action. Push that to 21+ countries and the average climbs to 6.63, each one representing a separate procedural hurdle.
Office action risk by country
For business owners deciding whether WIPO is the right choice for their expansion strategy, this data paints a clear picture. Based on the same dataset, here is the share of WIPO applications designating each country that received at least one office action from that country's IP office:
Country | Risk of office action |
|---|---|
United States | 100.0%* |
Canada | 77.9% |
Belize | 73.9% |
China | 68.3% |
Namibia | 60.6% |
Japan | 52.4% |
Philippines | 50.7% |
South Korea | 49.7% |
Israel | 46.1% |
Colombia | 44.2% |
Jamaica | 41.7% |
New Zealand | 40.0% |
Sweden | 36.3% |
Tajikistan | 36.1% |
Singapore | 35.3% |
Russia | 35.1% |
Australia | 33.6% |
Finland | 32.9% |
Norway | 32.8% |
Cuba | 29.2% |
Ireland | 27.8% |
Armenia | 27.5% |
Moldova | 26.9% |
Chile | 26.5% |
Vietnam | 26.1% |
Iran | 25.6% |
Brazil | 24.9% |
Cambodia | 22.6% |
Trinidad and Tobago | 22.1% |
Mongolia | 21.1% |
Malaysia | 19.9% |
European Union | 19.1% |
Democratic People's Republic of Korea | 18.9% |
Kazakhstan | 18.3% |
Albania | 18.1% |
Algeria | 16.7% |
Germany | 16.5% |
Turkey | 16.2% |
Portugal | 15.3% |
Iceland | 14.1% |
Azerbaijan | 14.0% |
Denmark | 13.1% |
Egypt | 12.7% |
United Kingdom | 12.7% |
India | 12.5% |
Poland | 12.5% |
Uzbekistan | 12.3% |
Mozambique | 12.2% |
Bulgaria | 12.0% |
Ukraine | 11.6% |
Spain | 11.5% |
Austria | 11.0% |
Indonesia | 10.9% |
Cyprus | 10.8% |
Switzerland | 10.5% |
Slovenia | 10.1% |
Bhutan | 10.0% |
Estonia | 8.8% |
Madagascar | 8.0% |
Latvia | 7.7% |
Hungary | 7.6% |
Kyrgyzstan | 7.6% |
Lithuania | 7.1% |
Mexico | 7.0% |
Slovak Republic | 6.2% |
Benelux | 6.1% |
Thailand | 6.1% |
France | 6.0% |
Georgia | 6.0% |
Czech Republic | 5.7% |
Serbia | 5.7% |
Romania | 5.6% |
Rwanda | 5.3% |
Mauritius | 4.0% |
Oman | 3.6% |
Croatia | 3.5% |
Italy | 3.5% |
Morocco | 3.4% |
Bahrain | 2.5% |
Pakistan | 2.5% |
Liechtenstein | 2.3% |
United Arab Emirates | 2.1% |
Cape Verde | 2.0% |
Laos | 1.8% |
Turkmenistan | 1.8% |
Kenya | 1.4% |
Sao Tome and Principe | 1.2% |
Monaco | 1.0% |
Montenegro | 1.0% |
OAPI | 0.9% |
Tunisia | 0.6% |
Qatar | 0.6% |
Bosnia and Herzegovina | 0.5% |
North Macedonia | 0.5% |
Ghana | 0.0% |
Grenada | 0.0% |
Afaghaistan | 0.0% |
Botswana | 0.0% |
Liberia | 0.0% |
Lesotho | 0.0% |
Malawi | 0.0% |
Sudan | 0.0% |
Sierra Leone | 0.0% |
Eswatini | 0.0% |
*Why the United States is effectively a guaranteed office action
The raw figure for the US in this dataset is 93.3%. We've reported it here as 100%. Here’s why:
The remaining 6.7% of US-designated applications in the sample never technically received an office action, but not because they cleared the examination independently. In every one of those cases, the applicant made a change of representative before any office action was issued. Once that's accounted for, every single US-designated application in the dataset that ran the full course was met with at least one office action.
The underlying reason has to do with the specifics of the US trademark system. The United States Patent and Trademark Office (USPTO) requires that any applicant without a US domicile be represented by a US-licensed attorney. A WIPO application, by design, is typically filed and managed by a representative in the applicant's home country, which by definition doesn't meet that requirement for the US designation. As a result, the USPTO routinely issues an office action citing the lack of a qualifying US representative, independent of whether the mark itself has any substantive issues.
In practice, this means a WIPO filing alone is not sufficient to secure protection in the US. Applicants designating the United States through the Madrid System should expect an office action, and should plan from the outset to engage US-licensed counsel to respond to it. For businesses with US on their expansion list, that's a call worth making before filing, not after the office action lands.
What this means for your filing strategy
The data points to a straightforward conclusion: the WIPO system does not spare applicants from local examination risk, and that risk is highly uneven across countries. High-risk, high-priority markets like the US, Canada, China, and Japan should be budgeted for office action responses from the start. Applications designating a long list of countries should expect to manage multiple responses, each with its own local rules and often its own local representative requirement.
While WIPO offers a centralized route, it’s not always the best fit for businesses targeting just a few countries or lacking legal support. In many cases, filing directly with national trademark offices can be simpler, more cost-effective, and legally safer.
For companies looking for more tailored trademark protection, Trama provides tools and legal support aimed at simplifying the process while maintaining global reach. Unlike traditional WIPO filings, Trama uses direct national filings, making sure your applications meet each country’s legal standards from day one. With a 96.90% success rate and over 35,000 trademarks registered, Trama is the trusted trademark partner for businesses scaling across borders.
