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Distinguishing procurement above and below EU thresholds

📐 Article6 min read

What you will learn Which thresholds have applied since 2026, how they are arrived at, how the contract value must be estimated, what differs above and below, and what changed in legal protection at the start of 2026.

The estimated contract value determines which procurement law applies. Above the EU thresholds the EU-derived regime governs; below them, the national one.

The line is no formality. Procurement routes, periods, publication duties and legal protection differ considerably on either side of it.

The thresholds since 2026

The current figures have applied since 1 January 2026 and are binding until 31 December 2027. They are adjusted on a fixed cycle rather than case by case.

Type of contract Threshold, net previously
Construction works €5,404,000 €5,538,000
Supplies and services, supreme federal authorities €140,000 €143,000
Supplies and services, other clients €216,000 €221,000
Supplies and services, utilities €432,000 €443,000
Works and services concessions €5,404,000 €5,538,000

The direction is notable: the figures have fallen. That widens the reach of European procurement law, because contracts previously just below are now caught.

The difference between the second and fourth rows matters for design practices. Architects' and engineers' services carry the low figure, because they are services. A design commission reaches the threshold considerably earlier than the construction project it serves.

How the figures are arrived at

Adjustment occurs every two years through delegated regulations of the European Commission, each taking effect on 1 January of odd-numbered years. The figures are therefore known well before they take effect.

The basis is purely arithmetical: the figures are aligned with the World Trade Organization agreement on government procurement, whose reference values are expressed in special drawing rights of the International Monetary Fund. The purpose is to offset exchange rate movements between signatory states.

The figures therefore do not rest on political decisions. That explains why they can fall as well as rise, and why the next adjustment falls predictably on 1 January 2028.

How the contract value is estimated

What governs is the estimated contract value net of tax, and the estimate is subject to its own rules. It must be recorded, because it carries the choice of the whole procedure.

The maximum likely total value applies. Options and extensions are included; for framework agreements the maximum achievable volume across the whole term governs.

For construction contracts the value of the whole project governs, including all supplies and services necessary for construction and provided by the client.

Lots are aggregated. Dividing a project into lots does not reduce the governing value.

The calculation must not aim at avoiding the threshold. An estimate manifestly serving circumvention is impermissible.

The last point matters most in practice. An incorrect estimate produces a defective procedure open to challenge, and that exposure exists whether the understatement was deliberate or negligent.

What differs above and below

Above threshold Below threshold
Legal basis GWB, VgV, VOB/A section 2 VOB/A section 1
Publication EU-wide national
Periods minimum periods prescribed shorter and more flexible
Procurement routes formally regulated open and restricted tendering, negotiated procedure, direct award
Documentation comprehensive lighter
Legal protection procurement tribunals restricted

The last row changed at the beginning of 2026. Since 1 January 2026 an amendment to the courts constitution act has assigned the regional courts a jurisdiction for secondary legal protection below the thresholds.

For tenderers that improves the avenues available below the thresholds, where procurement tribunals have no jurisdiction. The detail should be assessed legally.

National thresholds are something else

A confusion recurs and carries consequences. It concerns the relationship between the EU thresholds and the national thresholds of the VOB/A.

The EU thresholds determine which legal regime applies. They are set at European level and apply uniformly across Germany.

The national thresholds determine, within the below-threshold regime, which procurement route is permissible without particular justification. They are set by federal and state governments and can differ considerably.

Anyone working across several federal states therefore checks two levels: the uniform EU threshold and the state rule in force. The article on procurement routes and thresholds covers the national figures.

What to check

Four steps establish the classification of a project. They must be taken in that order, since each presupposes the result of the last.

  1. Estimate the contract value, following the valuation rules and net of tax.
  2. Determine the type of contract, because construction works and services carry entirely different figures.
  3. Use the threshold of the current period, not the preceding one.
  4. Below threshold, check the state rule, because it governs the permissible route.

The second step deserves attention on mixed contracts. Where a project contains both works and services elements, classification follows its own rules and should be assessed legally in case of doubt.

This article reflects the position of the rules at the date of checking and serves professional orientation. It does not constitute legal advice and does not replace assessment of the individual case.

Frequently asked questions

The contract value relative to the European thresholds. Above them, European procurement law applies.

They are fixed periodically at European level. The article gives the position since 2026.

Under the rules of procurement law, without artificial splitting. The article describes the approach.

Something different from the thresholds: they steer the procedure below the threshold. States and municipalities may deviate.

Tendering and procurement under the VOB: a guide