The amounts in force
For the purposes of the code the EU thresholds are as follows. The amounts are exclusive of value added tax.
| Subject | Threshold |
|---|---|
| Public works contracts and concessions | 5,404,000 euros |
| Supplies, services and design contests awarded by central government authorities | 140,000 euros |
| Supplies, services and design contests awarded by sub central administrations | 216,000 euros |
| Supplies, services and design contests in the utilities sectors | 432,000 euros |
| Works in the utilities sectors | 5,404,000 euros |
| Social services and other specific services listed in the dedicated annex | 750,000 euros |
One point deserves flagging because it runs against intuition: compared with the previous two year period the thresholds have been slightly lowered. The works threshold falls from 5,538,000 to 5,404,000 euros, the central authority threshold from 143,000 to 140,000 euros, and the sub central threshold from 221,000 to 216,000 euros.
The practical effect is that a greater number of awards falls above threshold than in the previous period, with the procedures and EU publicity that follow. The procedural burden therefore grows at unchanged award values.
Why two thresholds for services and supplies
The distinction between central government authorities and sub central administrations is the most frequent source of classification error, and it is worth clarifying. Municipalities, provinces and regions are sub central administrations.
Central government authorities are those listed in an annex to the EU public procurement directive, and comprise the organs of the State. Sub central administrations are defined residually: all public administrations other than the former, so regions, municipalities, universities and public bodies.
The consequence is that the same services award falls above or below threshold depending on who runs it. A commission worth 180,000 euros put out by a ministry is above threshold; the same commission put out by a municipality is below.
For an economic operator this means the classification is not derived from the value but from the pair of value and nature of the contracting authority, and that checking the nature of the authority precedes any procedural assessment. The nature of the body is checked against the list annexed to the EU rules.
The updating mechanism
The thresholds are not set by the national legislature and are not negotiable. They are fixed by delegated regulation of the European Commission, and revised every two years.
The calculation is an automatic conversion, made on the basis of the average daily value of the euro against special drawing rights, and serves to maintain alignment with the international standards of the agreements on public procurement. The Commission has no discretion, and the variations reflect only exchange rate movements.
That mechanism explains two things. Why the thresholds can fall and not only rise, as has happened for the current period. And why any document stating threshold amounts must identify the two year period concerned, without which the information is not usable.
Calculating the estimated value
Where an award sits relative to the threshold depends on the estimated value of the contract, and the calculation basis is set by the code. The basis is single and does not vary with the nature of the service.
The calculation takes account of the maximum estimated value, including any form of option or renewal of the contract expressly provided in the tender documents. Options not exercised are still included in the calculation.
Three implications follow from that wording. They concern options, renewals and the duration of the contract.
The first concerns options. A contract of 120,000 euros with a renewal option of the same value has an estimated value of 240,000 euros, and its position relative to the threshold must be assessed on that value.
The second concerns framework agreements. The reference is the maximum estimated value of the agreement rather than that of the individual call off contracts.
The third concerns recurring requirements. The assessment considers the substantive requirement rather than its fragmentation into successive awards.
The prohibition on splitting
The code prohibits using division into lots relating to the same categories or product sectors to circumvent the EU thresholds. Division remains lawful where it answers demonstrable technical needs.
The prohibition is the system's defence, and the test is functional. What matters is not the existence of several distinct awards but whether they are attributable to a single substantive requirement. Splitting is artificial where the division answers not to a technical or organisational reason but to the aim of placing the awards below a threshold.
It should be distinguished from lawful division into lots, which the code not only permits but encourages as a means of access for small and medium enterprises. The difference lies in the reason: division serving market access is lawful, division serving threshold avoidance is not.
The relationship with the internal below threshold bands
One point causes recurring confusion and deserves isolating, because it concerns technical services directly. It concerns the double threshold applying to services.
The EU thresholds are one thing, the internal thresholds the code sets for the below threshold bands are another. The numerical coincidence between the direct award threshold for services and supplies and the EU central authority threshold is not a conceptual identity.
The effect shows on a services award put out by a municipality. Up to the direct award threshold that arrangement applies. Between that threshold and the EU sub central threshold the below threshold negotiated procedure applies. Above it, open procedures with EU publicity apply.
For sub central administrations there is therefore an intermediate below threshold band that does not exist for central authorities, and a substantial share of medium sized technical commissions falls within it. It is the band into which most municipal commissions fall.
The relationship with qualification of contracting authorities
A second system of thresholds operates in parallel with the EU one and produces effects an operator observes directly. These are the qualification thresholds applying to contracting authorities.
The code requires contracting authorities to be qualified in order to run awards from defined values. For the design and award of works, qualification is required for tender values of five hundred thousand euros or above; for services and supplies it is required from the direct award threshold.
The two threshold grids do not coincide and answer to different rationales. The EU grid determines the procedural regime, the qualification grid determines who may run the procedure.
Their combined effect explains a phenomenon an operator meets constantly: medium value awards put out not by the using authority but by a central purchasing body or an aggregating entity. It is not an organisational choice of the authority but a consequence of its qualification.
For an operator the practical consequence is that the commercial catchment does not coincide with the list of local authorities: it also includes the aggregating entities through which those authorities run procedures, and identifying them is part of mapping the market. Central purchasing bodies must be monitored like the using authorities.
The most frequent errors
Using threshold amounts without checking the two year period they belong to is the first, and is the error the biennial updating cycle makes systematic. The amounts change every two years and the superseded text remains online.
Applying the central authority threshold to a municipal award is the second, and moves the boundary between below and above threshold by seventy six thousand euros. The gap between the two thresholds is the intermediate band described above.
Calculating estimated value without including options and renewals is the third, and places the award in the wrong band. The consequence is a procedure lighter than the one required.
Confusing the EU thresholds with the internal below threshold thresholds is the fourth, and produces the belief that above one hundred and forty thousand euros a service is always above threshold, which does not hold for sub central administrations. The two sets of thresholds serve different purposes and should not be overlaid.
What to check on a notice
Three checks allow a procedure to be classified correctly. They concern the estimated value, the nature of the body and procedural consistency.
The nature of the contracting authority, to identify which of the two services thresholds applies. The check is done once per body and remains valid.
The estimated value stated in the documents, checking that it includes options and renewals. An estimated value that does not is an indication of irregularity.
The consistency between the procedure adopted and the resulting band, because a procedure lighter than the one required is contestable while a more structured one is lawful but must be reasoned. A challenge must be brought before the tender deadline expires.
Note: the amounts stated in this page apply from 1 January 2026 to 31 December 2027 and were set by the European Commission's delegated regulations of 22 October 2025. The thresholds are revised every two years: the values in force at the date of consultation should be checked before any operational use.