1. The transitional rule
According to information published by the government the rule is unambiguous: ongoing procurement procedures are completed under the existing rules. The date the procedure started is decisive.
This means a procurement launched before 1 September 2026 is completed under the old rules, regardless of when tenders are submitted or the contract is signed. What is decisive is the launch of the procedure, not its completion.
The logic is the same as in other procedural reforms: a procedure already begun is not changed midway, because that would defeat the parties' expectations. The exact wording of the rule must be checked against the adopted text of the law, since this article rests on published information.
2. What it means in practice
| When the procurement was launched | Which thresholds | Which deadline for construction works |
|---|---|---|
| Before 01.09.2026 | simplified €60,000, public procurement €150,000 | 15 days |
| From 01.09.2026 | simplified €100,000, public procurement threshold abolished | 25 days |
Through autumn 2026 two sets of rules are therefore in circulation at once. Procurements launched before September carry the old thresholds and deadlines; those launched after carry the new ones.
A third consequence affects tenderers directly: two procurements open at the same time may fall under different regimes. The practical conclusion is that the type of procedure must be read from the contract notice, not inferred from a date.
3. The authority's timing decision
Here is a decision that is live in August and early September. It concerns the timing of the launch.
A procurement in preparation in August can be launched before or after 1 September. Launching earlier means the old, lower thresholds and shorter deadlines. Launching later means the new, higher thresholds and longer deadlines.
Which is preferable depends on the value of the procurement. Where the value falls between the old and the new threshold, the difference is fundamental.
| Construction procurement value | Before 01.09.2026 | From 01.09.2026 |
|---|---|---|
| €80,000 | simplified procedure | simplified procedure, no change |
| €120,000 | full procedure | simplified procedure |
| €6,000,000 | international regime | international regime, no change |
Timing is therefore a legitimate consideration, provided the procurement is actually ready. Rushing a half prepared procurement to launch for the sake of a date is a risk, because the gaps surface during the procedure and cost more than the fortnight gained.
4. What a tenderer must check
Three things for every procurement in autumn 2026. Which type of procedure the contract notice names. That is the only reliable source.
What the tender submission deadline is, since it differs between regimes. In a construction procurement launched under the old rules the deadline may be 15 days, under the new rules 25.
What obligations the procurement documents contain, since some construction requirements disappear in September, including evidence of subcontractors' average wages. The documents must be read in full.
The second point is the most practical. Planning resources across two different deadlines requires attention, particularly where a firm is bidding for several procurements at once: a ten day difference between two parallel tenders changes which one is finished first.
5. How long the transition lasts
Three observations giving a sense of the time frame. The old rules persist longer than expected.
Simplified procedures finish quickly, so the number of old simplified procurements falls quickly, probably within a few months.
Larger procedures can run for months, so the old rules persist longer in those. Two regimes therefore run in parallel.
Framework agreements and the mini competitions run under them can extend for years, which is a separate and the least clear question: the date a framework agreement was concluded and the date a mini competition is run may fall under different regimes. Their effect is the most long lasting.
The third point requires clarification against the adopted text of the law and, if necessary, from the Ministry of Finance. This article does not resolve it, and it is not worth resolving by assumption.
In summary, and four practical rules
Ongoing procurement procedures are completed under the existing rules, and what is decisive is the date of launch, not completion. Two sets of rules are therefore in circulation in autumn 2026, and two procurements open at the same time may fall under different regimes.
Four rules: read the type of procedure from the contract notice, do not infer it from a date. Check the deadline for each procurement separately in autumn 2026. As an authority, consider the timing of launch where the value falls between the old and the new threshold, but only where the procurement is ready. Clarify the treatment of framework agreements and mini competitions, which is the least clear point.
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.