1. Four things to watch
In order of importance.
The adopted consolidated text of the law, which is the only binding source and whose publication should be watched for. Overviews carry no legal weight.
Practice after 1 September, including how authorities interpret the new thresholds.
International thresholds, which change on a two year cycle, the next change falling in 2028.
Challenge practice, which shows which of the new conditions prove contestable.
The first is the sharpest at present, because this guide and every other overview rest on published information, not on the consolidated text. The binding text is the one adopted.
2. What already changed in 2026
Two changes have already taken effect but are less widely reported. They concern challenges.
According to Ministry of Finance information, new state fee rates for challenging public procurements took effect on 1 January 2026. According to institutional sources the fees were doubled.
| Size of procurement | Until 31.12.2025 | From 01.01.2026 |
|---|---|---|
| Below the international threshold | €640 | €1,280 |
| Above the international threshold | €1,280 | €2,560 |
The justification given was that the fees, in place since 2007, covered only around half of the labour costs of the review committee. Costs have risen since.
The practical consequence is that the barrier to challenging has risen, which affects smaller tenderers most: €1,280 is a different order of magnitude against a €150,000 procurement than against a €5,000,000 one. Fewer challenges are brought.
International thresholds also fell on 1 January 2026, covered in the article on the international threshold. 2026 has therefore brought three separate changes, only one of which takes effect in September.
3. One planned restructuring
A longer perspective, not yet decided.
According to professional sources the Ministry of Finance has prepared a statement of intent aimed at restructuring the system for resolving procurement disputes. Its substance is to abolish the four tier dispute system by merging the public procurement review committee into the court system.
A statement of intent is not a bill, and a bill is not a law. This guide does not treat it as law in force but flags it as worth watching. No timetable is known and it must be checked with the ministry.
4. When practice will settle
Three time horizons. The first procurements launched under the new rules appear in September and October.
The first challenges to the new conditions reach proceedings later in the autumn. Decisions follow in winter.
A settled interpretation forms over months, not weeks.
The third means that in autumn 2026 a more complex case is worth asking about rather than assuming. The Ministry of Finance advises in the field of public procurement, and that service is underused.
5. What to watch as a construction firm
Three concrete things, the third of which becomes clear quickly. It concerns how the deadlines are applied.
Whether authorities use the new reverse procedure option, which affects the logic of preparing a tender. The first procurements will show.
Whether subcontractor data is still required through the procurement documents, even though the statutory duty is reduced. Practice will differ by authority.
Whether the longer deadline is actually applied, or authorities continue to give the minimum. Register data will show this quickly.
The third shows whether the change reaches practice or stays on paper. If authorities continue to give 15 days in September where the law allows more, the relief is nominal.
In summary, and four practical rules
2026 has brought three separate changes: international thresholds fell and challenge fees doubled on 1 January, and the threshold system changes on 1 September. Challenge fees rose from €640 to €1,280 and from €1,280 to €2,560, which raises the barrier to challenging particularly for smaller tenderers. Restructuring of the dispute system is at the statement of intent stage and is not law in force.
Four rules: rely on the adopted consolidated text, not on overviews, including this one. Allow for the higher challenge fees, which already apply. Ask for official advice on a more complex case in autumn 2026. Watch practice in procurement documents, which shows whether the statutory relief reaches actual procurements.
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.