1. Where the threshold comes from
Three levels are connected, and the third is the one most used in practice. They are the national, simplified and international levels.
| Level | Role | Usability in practice |
|---|---|---|
| European Parliament and Council directives | set the threshold system | legal basis |
| European Commission delegated regulations | update the values | official source |
| Ministry of Finance table | collects the values in force | most usable |
The third source is the most useful for authorities and tenderers, because it gathers all values in one place. Thresholds are stated excluding VAT.
2. The two year cycle
The values are not permanent. The Commission updates the thresholds every two years.
According to Ministry of Finance information, the European Commission adopted updated public procurement thresholds for 2026 to 2027 in December 2025. The new values apply from 1 January 2026 to 31 December 2027.
This means the threshold must be checked per two year cycle, and a value taken from an earlier project may be out of date. The update is not a political decision but the result of a calculation based on exchange rates and international agreements, which is why its direction cannot be predicted in advance.
3. What happened in 2026
Here is the observation that surprises: according to professional sources the thresholds fell, they did not rise. They move on a two year cycle.
| Threshold | Until 31.12.2025 | From 01.01.2026 | Change |
|---|---|---|---|
| Classic construction works | around €5,538,000 | around €5,404,000 | − €134,000 |
| Utilities sector construction works | fall of the same order | fall of the same order | fall |
| Concession contracts | fall of the same order | fall of the same order | fall |
| Supplies and services | fell | fell | fall |
Thresholds for supplies and services fell too, for central government and other authorities alike. Precise values must be taken from the table published by the Ministry of Finance, since the figures given here are orders of magnitude.
The fall means slightly more procurements come under the international regime than before. For construction works the effect is small, since a change of €134,000 at €5.4 million is around 2.4 %.
4. The opposite movement
One observation links this article to the September reform. The reform leaves the international threshold untouched.
| Line | Direction | Date |
|---|---|---|
| International threshold | fell | 01.01.2026 |
| Domestic simplified threshold | rises | 01.09.2026 |
The simplified regime therefore widens from below and narrows from above. For medium sized procurements this means the band in which simplified rules apply is different at the end of 2026 than it was at the start.
The practical conclusion is that both lines must be checked separately, because they move for different reasons and at different times: one through a European calculation in January, the other by a decision of the Estonian legislator in September. They change at different times.
5. What it means for construction procurement
Three consequences. The international threshold for construction works is high, €5,404,000, so most Estonian construction procurements fall below it.
The domestic rules therefore apply to them, and those change on 1 September. The international rules do not.
Very large construction procurements exceed the threshold and are governed by rules derived from the directives, which do not change. The procedure is stricter there.
The reform therefore affects most construction procurements but not the largest. For a construction firm operating at ordinary scale the international threshold is in practice a theoretical figure; it becomes relevant only on large infrastructure or hospital projects.
In summary, and four practical rules
The international threshold derives from European Union directives, is updated by Commission delegated regulations every two years, and is published for practical use in the Ministry of Finance table. In 2026 it fell: for classic construction works from around €5,538,000 to €5,404,000, and the new values apply until 31 December 2027.
Four rules: take the value in force from the Ministry of Finance table, not from an earlier project. Check which two year cycle the procurement falls into. Bear in mind that this line moves independently of the September reform. Do not assume thresholds only ever rise, because in 2026 they fell.
This article serves professional orientation at the date of checking. It does not replace the Public Procurement Act or information published by the Ministry of Finance.