Procurement law in 2026 brings the most extensive changes in years. New EU thresholds, much higher value limits in the VOB/A (Construction Contract Procedures, Part A) and the UVgO (Sub-threshold Procurement Regulation), the NRW reform of municipal procurement and the Vergabebeschleunigungsgesetz (Procurement Acceleration Act), in force since July 1, 2026, fundamentally change how public contracts are awarded, and how bidders find and win them. This article explains each change in detail, puts the legal bases in context and shows what the new rules mean for your company.
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New EU thresholds from January 1, 2026: The legal basis in detail
Every two years, the European Commission adjusts the thresholds above which public contracts must be tendered EU-wide. The legal basis is Delegated Regulations (EU) 2025/2150, 2025/2151 and 2025/2152 of October 22, 2025, published on October 23, 2025 in the Official Journal of the European Union (OJ L, 2025/7079). The new values have applied since January 1, 2026 and remain in force until December 31, 2027.
Why are the thresholds going down?
The thresholds are set in Special Drawing Rights (SDR) of the International Monetary Fund and then converted into euros. Because the euro recently gained slightly in value against the SDR currency basket, the regular conversion produces lower euro amounts. So the reduction is not a political decision but an automatic currency effect, with real consequences for procurement practice.
Comparison table: Old and new EU thresholds
| Contract type | Threshold until 12/31/2025 | Threshold from 01/01/2026 | Reduction |
|---|---|---|---|
| Supplies and services (central government authorities) | €143,000 | €140,000 | -2.1% |
| Supplies and services (states/municipalities) | €221,000 | €216,000 | -2.3% |
| Works | €5,538,000 | €5,404,000 | -2.4% |
| Concessions | €5,538,000 | €5,404,000 | -2.4% |
| Sector contracting entities (supplies/services) | €443,000 | €432,000 | -2.5% |
| Defense and security (supplies/services) | €443,000 | €432,000 | -2.5% |
| Social and other specific services (Section 130 GWB) | €750,000 | €750,000 | unchanged |
The threshold for social and other specific services under Section 130 GWB (German Act against Restraints of Competition) stays unchanged at €750,000, because this value is set directly in EU Directive 2014/24/EU and is not subject to the conversion mechanism.
What the reduction means for bidders in practice
At first glance, the average reduction of 2 to 2.5 percent looks moderate. Taken together, however, it brings a considerable number of additional procurement procedures into scope. Especially for supplies and services at state and municipal level, where the value fell by €5,000 to €216,000, many contracts that were previously only published nationally now move into the EU-wide range.
For bidders, this means three things:
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More contracts visible on TED: Procurements tendered EU-wide must appear on TED (Tenders Electronic Daily) and can be researched there in one place. The more contracts fall under the EU obligation, the fewer procurements disappear into hard-to-find local portals.
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Stricter procedural rules apply: Procurements above the EU threshold are subject to Part 4 of the GWB (Sections 97 et seq.), the VgV (Public Procurement Ordinance) and, for works, the VOB/A-EU. This means stricter transparency, equal treatment and documentation obligations for contracting authorities, which gives bidders more legal certainty.
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Public procurement tribunals (Vergabekammern) become responsible: Above the EU threshold, bidders can seek review through the public procurement tribunals (Sections 155 et seq. GWB). Lowering the thresholds therefore also broadens legal protection.
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VOB/A 2026: New value limits below the threshold for construction work
Alongside the EU thresholds, the German Committee for Construction Contract Procedures (DVA) has fundamentally revised the value limits in Section 3a VOB/A. The new version was published in the Bundesanzeiger (Federal Gazette) on December 16, 2025 and applies without a time limit to all procurement procedures launched from January 1, 2026.
The new value limits at a glance
| Award type | Value limit until 12/31/2025 | Value limit from 01/01/2026 |
|---|---|---|
| Direct award | up to €3,000 (VOB/A 2019) | up to €50,000 |
| Negotiated award (Freihändige Vergabe) | up to €100,000 (varies by state) | up to €100,000 |
| Restricted tender without a call for competition | up to €50,000 to €150,000 (depending on trade) | up to €150,000 (uniform) |
Trade-by-trade distinction made uniform
A change with particular practical relevance: the previous three-way split of value limits by trade for restricted tenders without a call for competition is dropped completely. Until now, different value limits applied depending on the type of construction work (for example, finishing trades vs. civil engineering). From 2026, a single value limit of €150,000 net applies, regardless of trade. This makes procurement practice much simpler and reduces sources of error when choosing the procedure.
What this means for construction companies
The most striking change is the huge increase of the direct award limit from €3,000 to €50,000. Public contracting authorities can now award construction work up to €50,000 net directly, without a formal tender procedure. The consequences for bidders cut both ways:
Opportunity: faster awards. Direct awards mean shorter decision cycles. If the contracting authority knows you as a reliable provider, you benefit from much shorter award periods. This applies especially to maintenance and repair work, which is often in the range up to €50,000.
Risk: fewer public notices. Direct awards do not require a public notice. Contracts up to €50,000 are no longer published on procurement platforms. If you have mainly found work through portal searches so far, you need to rethink and actively approach contracting authorities.
Recommendation: Keep your presence up to date in relevant prequalification databases (for example PQ-VOB) and in the bidder databases of contracting authorities. For restricted tenders up to €150,000, contracting authorities invite specific companies to bid. Being listed in these databases greatly increases your chances of an invitation.
UVgO changes: Value limits for federal supplies and services
Besides the VOB/A for construction work, the rules of the Unterschwellenvergabeordnung (UVgO, Sub-threshold Procurement Regulation) apply to supplies and services below the EU threshold. Key things have changed here in 2026 too.
Direct award limit raised to €15,000
On December 17, 2025, the federal cabinet decided to extend the temporary increase of the value limit for direct awards under Section 14 UVgO from €1,000 to €15,000 net. The corresponding deviating administrative regulations were published in the Bundesanzeiger on December 29, 2025 and apply until the Procurement Acceleration Act enters into force, but no later than December 31, 2027.
Comparing value limits: VOB/A vs. UVgO (federal)
| Award type | VOB/A (construction work) | UVgO federal (supplies/services) |
|---|---|---|
| Direct award | up to €50,000 | up to €15,000 (temporary) |
| Negotiated award | up to €100,000 | up to €25,000 |
| Restricted tender without call for competition | up to €150,000 | depends on the state |
Impact on IT service providers, consultants and suppliers
For companies supplying goods and services to federal authorities, the €15,000 direct award limit is relevant. Federal authorities can now award contracts up to this value directly, without a formal procedure. Here too: proactively maintaining contact with federal purchasing offices becomes more important than passive portal searches. For IT services and consulting projects, which are typically above €15,000, little changes in procurement practice. Negotiated award or public tender still apply here.
NRW reform: The new Section 75a GO NRW changes municipal procurement
With the new Section 75a of the North Rhine-Westphalia Municipal Code (GO NRW) as of January 1, 2026, North Rhine-Westphalia has fundamentally reformed municipal procurement practice. The change goes much further than a simple increase in value limits.
What has changed
Until now, NRW municipalities were bound by the state's "procurement principles" (a circular of the Ministry of Economic Affairs) to fixed value limits that determined which procurement procedure applied from which contract value. These statewide rules are dropped completely. They are replaced by the new Section 75a GO NRW with the following key points:
- Below the EU thresholds, NRW municipalities are no longer required to apply the UVgO or the VOB/A.
- Municipalities can adopt their own procurement bylaws that govern the procurement procedure locally.
- The municipal umbrella associations (Städtetag NRW, Landkreistag NRW, Städte- und Gemeindebund NRW) have drafted model bylaws that municipalities can use as a guide.
- Above the EU thresholds, the GWB, VgV and VOB/A-EU continue to apply unchanged.
Practical consequences for bidders in NRW
Procurement practice can now vary considerably from one municipality to the next. While some municipalities adopt the model bylaws and so keep value limits similar to before, others can introduce much more flexible rules, or stricter ones.
Recommended actions for bidders:
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Check the procurement bylaws of your target municipalities: Actively find out whether your target municipalities have adopted procurement bylaws and which ones. The bylaws are usually published in the official gazette of the municipality.
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Maintain direct contact: Because municipal contracting authorities now have more leeway, personal relationships with purchasing offices become more important. Get listed in municipal bidder databases.
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Ensure bid quality: More flexibility for contracting authorities also means that quality criteria can be weighted more heavily alongside price. Invest in convincing references and proof of qualifications.
A signal for other states
The NRW reform is being watched closely across Germany. Several Bundesländer are considering similar approaches to cut red tape in municipal procurement. Bidders active in several states should follow developments in each of their target markets. A tool like procuris helps you keep track of procurements across all platforms and states, no matter how fragmented local procurement practice becomes.
Procurement Acceleration Act: The major GWB reform is in force
The "Act to Accelerate the Award of Public Contracts" (Vergabebeschleunigungsgesetz, Procurement Acceleration Act for short) is the central procurement law reform of this legislative term. The federal cabinet adopted the draft bill on August 6, 2025. The Bundestag passed the act on April 23, 2026, and the Bundesrat followed on May 8, 2026. It was promulgated on May 18, 2026 (Federal Law Gazette 2026 I No. 137) and has been in force since July 1, 2026. Procedures that started before July 1, 2026 continue under the old rules (Section 187 subsection 2 GWB).
Key points of the draft bill
The Procurement Acceleration Act amends Part 4 of the GWB (Sections 97 et seq.) and numerous ordinances (VgV, SektVO, KonzVgV). The most important changes according to the draft bill:
Simpler procurement procedures: - Raising the value limit for federal direct awards to €50,000 (previously a temporary €15,000 under the UVgO) - For innovative services from start-ups: direct awards up to €100,000 - Fewer proofs of suitability and documentation obligations - Easier division into lots while protecting small and mid-sized companies
Faster review procedures: - No more suspensive effect of immediate appeals against decisions of the public procurement tribunals - New jurisdiction of the regional courts (Landgerichte) for secondary legal protection below the thresholds - Shorter deadlines in review procedures
Digitalization: - Expanding e-procurement as the mandatory standard - Better data standards for notices - Interoperability between procurement platforms
Expected economic effects
The Federal Ministry for Economic Affairs puts the expected relief at around €100 million a year for businesses and €280 million for the administration. Most of the savings are expected to come from less red tape around proof of suitability and simpler procedures.
What bidders can do now
The Procurement Acceleration Act has applied to newly started procedures since July 1, 2026. Factor the changes into your business development strategy:
- Standardize your suitability documents: Prepare a modular set of suitability evidence that you can quickly adapt to different procedures. Use the European Single Procurement Document (ESPD) as a basis.
- Document your level of innovation: If your company counts as a start-up or offers innovative services, prepare evidence for the direct award limit of €100,000 provided for in the draft bill.
- Reassess review procedures: The removal of suspensive effect for appeals provided for in the draft bill changes the risk calculation for applications for review. Get advice on this in good time.
eForms and digitalization: Better data, better search
Since October 2023, the eForms standard (based on EU Implementing Regulation 2019/1780) has applied to all EU-wide contract notices. eForms replaces the previous standard forms and structures tender data in a machine-readable XML format.
What eForms means for data quality
The switch has measurably improved data quality on TED and connected platforms. In concrete terms:
- Structured fields instead of free text: Information such as subject matter, CPV codes, suitability criteria and award criteria is captured in standardized fields. This makes tenders searchable with more precision.
- Uniform coding: All EU member states use the same data format. For bidders searching across borders, format-related search problems go away.
- Better filtering and analysis options: AI-powered search tools like procuris benefit directly from the improved data structure. Semantic search delivers more precise results because the input data is more uniform.
Extension to below-threshold procurement under discussion
At federal and state level, there is currently discussion about extending the eForms standard to procurements below the EU thresholds as well. In Austria, this step is already planned in the proposed Federal Procurement Act 2026. In Germany there is no binding timetable yet, but the Procurement Acceleration Act is speeding up the discussion.
If the extension happens, it would be a major step forward for finding below-threshold procurements, an area that has so far been extremely hard to search because of fragmented data formats and inconsistent platforms. SMEs that depend on regional below-threshold contracts in particular would benefit greatly.
E-procurement as the standard
Alongside the introduction of eForms, the federal government and the states are pushing end-to-end digitalization of procurement procedures. The Ordinance on Electronic Invoicing in Public Procurement is being implemented consistently. Electronic bid submission, digital communication with contracting authorities and automated notifications are already standard for EU-wide procurements and are increasingly becoming mandatory below the threshold too.
Practical impact by type of company
The 2026 procurement law changes affect different companies in different ways. Here is an overview by type of company:
Small construction companies (up to 20 employees)
The higher VOB/A direct award limit of €50,000 directly affects the typical contract range of small trade businesses. Many contracts that used to be tendered publicly will now be awarded directly. Strategy: Maximum presence with local contracting authorities, registration in municipal bidder databases, personal contact with municipal works depots and facility management.
Mid-sized IT service providers
The UVgO direct award limit of €15,000 is too low for typical IT projects to have a noticeable impact. More relevant is the increase to €50,000 provided for in the draft of the Procurement Acceleration Act. Strategy: Focus on EU-wide procurements (lower thresholds = more opportunities) and use the eForms data quality through specialized search tools.
Large construction groups
Lowering the EU threshold for works from €5,538,000 to €5,404,000 has little impact on the typical contract volume of large construction groups. More relevant is the acceleration of review procedures through the Procurement Acceleration Act. Strategy: Review your legal protection strategy, especially regarding the removal of suspensive effect provided for in the draft bill.
Start-ups and innovative companies
The direct award limit of €100,000 for innovative services provided for in the draft Procurement Acceleration Act is especially interesting for start-ups. Strategy: Document the innovative character of your services, approach public contracting authorities proactively and take part in innovation partnerships.
Outlook: Trends and upcoming developments
The EU procurement transformation package
The European Commission is working on a broad procurement transformation package to modernize the EU procurement directives 2014/24/EU, 2014/25/EU and 2014/23/EU. The focus is on giving more weight to sustainability criteria, promoting strategic procurement and further digitalization. A legislative proposal is expected for 2026/2027.
Open data in public procurement
A growing trend is making procurement data available as open data. In its new Federal Procurement Act, Austria plans to require that metadata on awarded contracts be made available in an open, machine-readable format for at least five years. In Germany, civil society and business associations are making similar demands. For bidders, more open data means better market analysis, a more transparent competitive landscape and data-driven business development strategies.
AI-powered tender search as a competitive advantage
The growing volume and quality of data from eForms, lower thresholds and increasing digitalization make AI-powered search tools more and more valuable. While manual research across individual portals reaches its limits given the fragmentation, tools like procuris can search hundreds of sources at once and identify relevant tenders automatically. Explore all features or start right away with the free plan.
Frequently asked questions about the 2026 procurement law changes
Do the new EU thresholds apply immediately to all procurements?
The new EU thresholds have applied since January 1, 2026 and affect all procurement procedures launched from that date. Procedures already underway whose contract notice was published before January 1, 2026 are handled under the previous thresholds (for example €221,000 for supplies/services). The legal basis is Delegated Regulations (EU) 2025/2150, 2025/2151 and 2025/2152.
Are the new VOB/A value limits uniform across Germany?
The VOB/A itself, as a set of rules issued by the DVA, applies nationwide. The value limits in Section 3a VOB/A (direct award up to €50,000, negotiated award up to €100,000, restricted tender up to €150,000) therefore generally apply in all states. However, the states can set supplementary or deviating rules through their own procurement laws, decrees or administrative regulations. NRW has already done so with the new Section 75a GO NRW. So always check the state-specific rules as well.
What does the NRW reform of Section 75a GO NRW mean for bidders outside NRW?
The introduction of Section 75a GO NRW directly affects only municipalities in North Rhine-Westphalia. Bidders from other states who compete for contracts from NRW municipalities must, however, follow the municipal procurement bylaws that apply in each case. The NRW reform also sends a signal: several other states are considering similar models to make municipal procurement more flexible.
When did the Procurement Acceleration Act enter into force?
The Procurement Acceleration Act was promulgated on May 18, 2026 (Federal Law Gazette 2026 I No. 137) and has been in force since July 1, 2026. Procedures that started before July 1, 2026 are completed under the previous rules (Section 187 subsection 2 GWB).
Do I need to change anything in my processes as a bidder?
The threshold changes do not create any immediate new obligations for bidders. However, you should adjust your search strategy and business development: more procurements now appear on TED, eForms data quality makes systematic searches more productive, and below the threshold, proactive relationship building becomes more important than passive portal searches. A tool like procuris helps you capture the additional opportunities efficiently. Pricing starts with the free plan.
This article is for general information only and does not constitute legal advice. For binding information on procurement law, consult a lawyer who specializes in it. Status: March 2026, information on the Procurement Acceleration Act updated in October 2026.