Our 2026 coverage connects legislative developments and selected CJEU decisions with practical procurement questions. The English summaries below link to detailed German reports. They distinguish the event date from the later editorial retrospective prepared on 13 November 2026.
January: new EU thresholds
The 2026–2027 thresholds require updated value checks and templates. The full estimated net value, including relevant options, matters. Detailed January report (German).
February: defence procurement
Changes to German defence procurement require attention to the covered buyers, contracts and specific conditions. Acceleration is not a general exemption for every public purchase. Detailed February report (German).
March: AESTE and social criteria
C-210/24 concerns additional remuneration for staff performing a social-services contract and the relevant collective-bargaining framework. Its scope should not be expanded to unrestricted company-wide social scoring. Detailed March report (German).
April: Sof Medica and specifications
C-568/24 examines technical characteristics of a surgical robot. Restrictions can arise through dimensions and design features as well as through brand names. Detailed April report (German).
May: federal tariff compliance
The BTTG entered into force on 1 May. Scope, statutory conditions and the role of branch ordinances need separate assessment; no branch ordinances setting concrete conditions were in place when checked on 13 November. Detailed May report (German).
June: start-up procurement rules
The federal administrative rules published in June and effective from July facilitate specified innovative purchases under defined conditions. Undertaking age, value and scope remain important. Detailed June report (German).
July: lot formation and infrastructure
The lot principle now appears in section 97a GWB. The additional time-related exception concerns defined infrastructure projects and conditions; ordinary scheduling pressure is not sufficient by itself. Detailed July report (German).
August: AI procurement
Certain transparency obligations apply from August 2026, while central high-risk obligations follow later under the July amendment. Classification, contractual roles and implementation dates need separate review. Detailed August report (German).
September: current VgV working practices
Updated examination and document-request rules call for revised procedures and templates. Requests for missing evidence remain distinct from improving a scored tender after the deadline. Detailed September report (German).
October: I-Sete and interim protection
The retrospective examines the CJEU judgment of 17 September in joined cases C-266/25 and C-267/25. EU funding pressure does not remove hearing and meaningful balancing requirements in the Portuguese suspension mechanism examined. Detailed October report (German).
Four practical examples
The following scenarios are illustrative, not reports of actual client matters. The outcome depends on the documents and circumstances of the individual procurement.
Example 1: Template update
A buyer checks whether thresholds and procedural references in its standard documents reflect the applicable 2026 law.
Example 2: Case-law application
A team compares Sof Medica’s facts with its own technical restrictions before changing a specification.
Example 3: Funding urgency
A project manager considers funding deadlines together with the actual rules for effective review, rather than assuming automatic priority.
Example 4: AI timetable
A buyer distinguishes a system’s transparency requirements from later high-risk obligations and allocates contractual responsibilities accordingly.
Related topics
Public procurement reforms in 2026 · Public procurement case law · Procurement legislation and official sources · AI in procurement and purchasing AI systems
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Updated 13 November 2026. Illustrative guidance on German and EU procurement law.