horak.
RECHTSANWÄLTE PARTNERSCHAFT MBB /
SPECIALIST LAWYERS / PATENT ATTORNEYS /

horak Rechtsanwälte – Vergaberecht

Public procurement for contracting authorities and bidders

EU procurement thresholds for 2026 and 2027

The thresholds applying from 1 January 2026 are lower than those for 2024/2025. Select the correct authority and contract category, then compare the estimated total value excluding VAT. National direct-award limits are a separate question.

Main thresholds

For ordinary supplies and services, the threshold is EUR 140,000 for the relevant central government authorities and EUR 216,000 for other public contracting authorities. Utilities supplies and services generally use EUR 432,000. Works and concessions use EUR 5,404,000. Social and other specific services have special thresholds, including EUR 750,000 in the classical regime and EUR 1,000,000 in utilities.

Estimate the complete requirement

Under the applicable rules, include relevant options, renewals, premiums and aggregated lots. A framework requires assessment of the intended overall value. The first invoice or annual budget is not necessarily the contract value. Artificial splitting to avoid procurement rules is prohibited. Record quantities, term, pricing assumptions and the timing of the estimate.

Special cases need separate analysis

Mixed contracts, planning services, recurring requirements and special service categories require the relevant valuation rules. A value cannot safely be copied from a table without classification. National procedural relaxations depend on the authority and implemented rules; being below an EU threshold does not automatically permit a direct award.

Practical consequences

The classification affects publication, procedure and potential GWB review. A later market-price change does not automatically invalidate a reasonable original estimate, but it also does not excuse a deliberately incomplete calculation. Authorities and bidders should use dated, official sources and examine the law applicable to the particular procedure.

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: Renewal included

A municipal service costs EUR 190,000 plus a EUR 40,000 renewal option. Include the relevant option in the estimate. Looking only at the initial term would miss the total value.

Example 2: Central authority

A covered central government body plans a EUR 150,000 service. The ordinary EUR 216,000 sub-central figure is not the right comparison. The authority category changes the result.

Example 3: Several lots

A single requirement is split into four regional lots. Apply the aggregation rules and any specific small-lot exception. Separate lot prices do not automatically avoid the EU framework.

Example 4: No guaranteed orders

A framework guarantees no minimum purchases but anticipates substantial demand. The estimate is not zero. Expected use, maximum volume and duration must be assessed coherently.

Related topics

Framework agreements and call-off contracts · Choosing a public procurement procedure · German and EU public procurement law

Discuss your procurement

For a review, please identify the authority, contract or lot, current procedural stage and any deadline. We can then clarify the scope of the requested work. Contact our team. An enquiry does not itself create a retainer or preserve a legal deadline.

Legal sources

Official legislation and materials, some in German: § 106 GWB · § 3 VgV

Updated 13 November 2026. Illustrative guidance on German and EU procurement law.

Deutsche Fassung

Scroll to top