Select-then-differentiate: Solving Bilevel Optimization with Manifold Lower-level Solution Sets

We study optimistic bilevel optimization when the lower-level problem has a non-isolated manifold of minimizers. In this setting, the hyper-objective may be non-differentiable because the upper-level criterion must choose among multiple lower-level solutions. Under a local Polyak--Lojasiewicz (PL) condition, we show that differentiability does not require the lower-level solution set to be a singleton: uniqueness of the optimistic selection is sufficient. This yields an explicit pseudoinverse-based hyper-gradient formula extending the classical singleton-minimizer result. We further characterize the regularity of the hyper-objective: non-degeneracy of the selected minimizer along the solution manifold yields local smoothness, while failure of uniqueness can create many non-differentiable points and failure of non-degeneracy can destroy all positive H"older regularity of the hyper-gradient. Motivated by this theory, we propose HG-MS, a select-then-differentiate method combining explicit optimistic selection with efficient pseudoinverse-based hyper-gradient computation. Despite the nonconvex nature of optimistic selection over the lower-level solution manifold, we show that HG-MS converges to a stationary point of the optimistic objective with complexity governed by the intrinsic dimension of the solution manifold rather than its ambient dimension. Empirically, we test a practical variant of HG-MS for matched-budget LLM source reweighting. This variant preserves the select-then-differentiate principle and obtains the best GSM8K/MATH scores across the tested backbones, along with competitive or best MT-Bench instruction-following results.