Every public procurement regime in the European Union descends from the same three directives. Directive 2014/24/EU for the public sector, 2014/25 for utilities, 2014/23 for concessions, plus the remedies directives. One rulebook, twenty-seven transpositions. So a reasonable question is: how much does each country layer on top of the shared base?
We spent a day answering it from primary national sources — acts, ordinances and, where that is the operative instrument, official circulars, rather than summaries — for all twenty-seven member states. The answer turned out to be more interesting than the question, because the shared base stops at the EU thresholds. Below them the directives do not apply at all: no procedures, no time limits, no award-criteria rules, no remedies directive. That space is governed entirely by national law, and it is where most contracts by count live.
So the real variation is not gold-plating above the line. It is that below the line, in a significant group of member states, there is no line.
1. How to read the chart
The bars answer one question: at what value must a public contract be advertised, so that a supplier not already on the buyer’s list can find it and bid? Sorted low to high, in euros.
The four orange bars are countries with no such national value at all. They sit at the EU threshold because that is where their first advertising duty arrives. Germany is a grey range, because it has no single national figure: six Länder compel an advertised procedure from €100,000, nine compel nothing below the EU threshold, and one is unresolved.
The strip beneath each bar is the second measure: whether national law restricts awarding on price alone, in four steps.
The darkest squares cluster at the low end. Seven of the eight countries with a hard percentage floor sit among the thirteen lowest thresholds: Spain has nearly the lowest threshold in the EU and a 51% quality floor. The exception is Italy, which reaches the right of the chart only by having no threshold at all. Luxembourg has the highest national threshold and no restriction whatever.
2. In four member states, no contract value forces advertising
This is the finding we did not expect, and it is the one that matters most if you sell to European public buyers.
In the Netherlands, no rule anywhere ties a duty to advertise to the value of a contract. The Aanbestedingswet's obligations attach to what a buyer chooses to do — article 1.11 applies where an authority has published a notice "uit eigen beweging", of its own accord. The first mandatory advertisement is the EU threshold itself.
In Slovakia, the act applies from €50,000, but all it requires is inviting three operators through the electronic platform. Publishing an open call is described in the statute as dobrovoľne — voluntary. For supplies and services the first duty to tell the wider market a contract exists arrives at €216,000. Works are the exception: § 110(1) makes publication to an unlimited circle compulsory for works from €800,000.
In Denmark, there is no value trigger at all. The duty attaches to any contract with clear cross-border interest, at any value, and the alternative regime above DKK 500,000 can be satisfied by a market survey plus a single quotation.
Italy was the biggest surprise, because it is the EU's third-largest procurement market and it looks mid-table until you read the next provision along. Direct award runs to €140,000 — expressly available "anche senza consultazione di più operatori economici", without consulting more than one operator. Above that, the route is a procedura negoziata senza bando, a negotiated procedure without a notice, with at least five operators drawn from market surveys or the authority's own lists. What gets published is the launch of a consultation, on the authority's own website, and afterwards the names of the operators already chosen.
Three more come close without quite qualifying. Croatia delegates everything below its €26,540 ceiling to each contracting authority's own internal rulebook, so a threshold exists but no common rule sits beneath it. Hungary exempts works below HUF 300,000,000, where five firms can be invited instead of publishing the notice and only invitees may bid, but its supplies and services floor is a conventional HUF 20,000,000, about 23% of the EU threshold. And nine of Germany's sixteen Länder compel nothing below the EU threshold, though one of the nine is a borderline case and a tenth is unresolved. Germany as a country has no single answer either way.
Where there is no threshold at all, the EU threshold is not where extra rules begin. It is the first moment anyone outside the buyer's chosen shortlist finds out the contract exists.
3. The number everyone compares is usually the wrong number
Comparative tables of European procurement thresholds circulate widely. Having built one from primary law, we think most of them are wrong, and we can be specific about how.
The mistake is to record the point at which a buyer must stop awarding directly as though it were the point at which a contract becomes visible. Those are different numbers, and between them sits a middle rung that reads like advertising in a summary table and is not.
- Italy publishes the launch of a consultation on the buyer's own site — but the invited set is drawn from the buyer's lists.
- Romania requires a listing in the national catalogue or a notice, and the catalogue discharges it. A catalogue inverts the direction of publicity: suppliers post standing offers and the buyer shops among them. Nothing the buyer does is visible as a solicitation.
- Hungary requires publication in the national e-procurement system — and then provides that only invited operators may bid.
- Denmark forces a formal procedure at DKK 3m for works, but one permitted form is a restricted tender with no public notice, and the choice of form is the buyer's.
We applied one test to all twenty-seven: a direct-award ceiling is a valid advertising floor only if the very next rung up compels publication to an unlimited audience.
4. Where the national threshold is not the whole story
Germany has no binding federal rule below the EU threshold for municipal buyers. The relevant ordinance only applies where each Land's own budget law adopts it, so sixteen states decide separately. Direct-award ceilings run from €3,000 in Bremen to €100,000 in several states — a 33-fold spread inside one member state. North Rhine-Westphalia abolished its municipal value limits outright on 1 January 2026.
And the ceiling is the wrong axis for Germany anyway. Nine Länder did not merely raise the direct-award limit; they raised the ceiling on invitation-only procedures with no public call all the way to the EU threshold. Bremen has a €3,000 direct-award ceiling but compels an advertised procedure from €100,000; Saarland's ceiling is €100,000 and it compels nothing below the EU threshold at all. On the ceiling alone Bremen looks far stricter. On what actually reaches the market, they invert over part of the range.
Portugal's €75,000 threshold is displaced entirely for EU-funded and recovery-plan contracts, where a separate 2021 law permits inviting at least five named entities with no public notice. That route covers the whole of the range this article measures. You would not find that by reading the procurement code, because it is not in the procurement code.
Sweden has no advertising floor at all for social and other specific services, where direct award runs all the way to the separate and much higher EU threshold that applies to them. Cyprus has a separate, higher regime for contracts meeting needs outside the Republic.
5. Is a low threshold good or bad?
It is tempting to read the left of the chart as heavy regulation and the right as light. That is not quite what the numbers say.
A low threshold buys visibility. In Latvia a €12,000 contract is findable by a supplier who has never worked for that buyer. In Luxembourg the same contract can go to a chosen shortlist and nobody else need ever know it existed.
The objection is burden — running a full tender for a €12,000 purchase can cost more in staff time than the contract is worth, on both sides. But that objection is about the procedure, not the publication, and in the data the two come apart. Latvia’s €10,000 does not trigger a tender: section 9 of its act is headed “Procurements to which the Procurement Procedures Laid Down in this Law shall not Apply”, and what it requires above the threshold is a notice with ten working days to respond. Spain is similar — in the band above its €15,000 floor and up to €60,000, intellectual services excepted, sits a stripped-down procedure with no solvency evidence, no guarantee and a single envelope.
So the low-threshold states have largely answered the burden objection by pairing a low visibility floor with a light procedure. A low threshold attached to a heavy procedure would be the bad combination, and it is not the common one.
The Netherlands argues the other side deliberately: no value trigger at all, and a duty of proportionality instead — match the procedure to the contract rather than tender everything above an arbitrary number. Whether that is the most sophisticated regime in Europe or a transparency gap depends on your priors, and both readings are defensible.
What this study cannot settle is which produces better outcomes. Procedural burden and remedies are precisely the dimensions we did not measure.
6. Where award on price alone is restricted
Under the directive, price-only award is lawful. Article 67(1) requires the "most economically advantageous tender", but recital 89 makes that a pure umbrella term and recital 90 confirms assessment may rest on price or cost effectiveness alone. The third subparagraph of Article 67(2) then lets member states prohibit price-only award or restrict it to certain authorities or contract types.
Fifteen of twenty-seven have used that power. Twelve have not. But only eight impose an actual number:
- Croatia — price may not exceed 90% of the weighting, i.e. a hard 10% quality minimum, with a closed list of exceptions.
- Spain — quality must be at least 51% for intellectual services and Annex IV services.
- Romania — the broadest of the numeric caps: lowest price is unavailable for any contract at or above the EU thresholds, and price is capped at 40% for three named categories: intellectual services, trans-European transport infrastructure and county roads, and designated environmentally-impactful product categories.
- Greece — price carries exactly 30% and other criteria 70% for studies and technical and related scientific services. It may be set lower by reasoned decision after the Technical Council's opinion, never higher.
- Hungary — price capped at 70% for construction, and at no more than the other criteria combined when selecting designers and engineers.
- Italy — the economic score is capped at 30% for labour-intensive contracts and 10% for IT procured in a nationally strategic context.
- Poland — price may not exceed 60% of the weighting, and this binds municipalities. There is an escape where quality requirements are set out in the specification.
- Lithuania — structurally unlike any other: each individual contract may still be awarded on price alone, but the total annual value of price-only awards may not exceed 50% of the authority's procurement. Low-value purchases are excluded, so everything below €70,000 sits outside the cap entirely. A portfolio cap, not a contract rule.
France already restricts price-only award by contract type, and from 21 August 2026 it goes further, by an unusual route. A climate law commences on that date requiring every public contract to carry at least one environmental award criterion. It does not prohibit price-only award; it makes it arithmetically impossible.
7. Method, and what this does not measure
Every figure is the position in force on 4 August 2026, read from the national act or its official consolidation, with the article recorded. The comparison is fixed to one cell throughout: a sub-central contracting authority buying supplies or services, VAT-exclusive. Thresholds differ by contract type and by authority type, and mixing them silently would make the comparison meaningless.
EU thresholds are the 2026–27 revision (Regulation (EU) 2025/2152, applying from 1 January 2026): €216,000 for sub-central supplies and services, €140,000 for central government, €5,404,000 for works. Note these went down this cycle. Several EU institutional pages still publish the previous figures.
For the five non-euro member states that set a value, ratios are computed entirely in national currency, against the EU threshold as denominated in that currency by Commission Communication C/2025/5732 — so no exchange rate enters any comparison. Converting one side at a market rate and leaving the other in euro puts two different rates inside one fraction; it moved our Czech figure by 1.6 points and our Swedish figure by 1.4 before we caught it.
Thresholds are reported as amounts, not converted into an index. No composite score is involved: the two measures are shown separately so that neither hides the other.
The restriction strip has four steps, anchored to the directive’s own gradations: none where the Article 67(2) power is unused; must justify where price-only is lawful subject to a duty to give reasons; restricted by contract type where it is confined to certain authorities or contract categories; hard percentage floor where it is prohibited outright or subject to a numeric minimum weighting.
Where the evidence is weaker, we say so. Three cells rest on sources we could not fully close. Romania's figures were verified against a consolidation in force 17 November 2024 and not re-verified for 2025 or 2026 amendments, because the official Romanian portal was unreachable from every route we tried; a Romanian commentary on the 2026 revision states the national direct-award tiers were unchanged, which supports the threshold but not the 40% cap. Malta's figure is confirmed against a consolidation current to 27 June 2025, without a check for later Legal Notices. Two of the German Länder figures rest on secondary sources because the official gazettes were unreachable or corrupted.
What this does not measure: utilities and concessions (the concessions directive has no equivalent provision, so it cannot be compared on this measure); exclusion and vetting grounds; and remedies. That last omission matters more than it looks — Cyprus's floor sits in primary legislation, but its Tenders Review Authority has no jurisdiction below the EU thresholds, so the duty exists and the specialised remedy does not. Ireland's floor is the mirror image: a real and enforced administrative rule that is not statute at all, but a departmental circular.
8. The EU-27 reference table
The national publication threshold is the lowest value at which a duty to advertise to an unlimited audience is forced by the value of the contract.
| Country | Publication threshold | % of EU | Procurement, % of GDP | Price-only restricted | Weighting rule |
|---|---|---|---|---|---|
| Austria | €140,000 | 64.8% | 15.6% | Yes — by contract type | — |
| Belgium | €140,000 | 64.8% | 15.3% | No | — |
| Bulgaria | €25,565 | 11.8% | 10.1% | No | — |
| Croatia | delegated | — | 15.0% | Yes — near-blanket ban | quality ≥ 10% |
| Cyprus | €80,000 | 37.0% | 10.2% | Yes — services | — |
| Czechia | CZK 3,000,000 | 55.7% | 14.0% | Yes — procedure + contract type | — |
| Denmark | none | — | 12.6% | No | — |
| Estonia | €30,000 | 13.9% | 14.9% | Yes — gate + procedure ban | — |
| Finland | €60,000 | 27.8% | 19.6% | Justification duty only | — |
| France | €60,000 | 27.8% | 16.1% | Yes — blanket from 21 Aug 2026 | — |
| Germany | varies by Land | 46.3–100% | 18.5% | No | — |
| Greece | €30,000 | 13.9% | 12.2% | Yes — authority + contract type | price = 30% |
| Hungary | HUF 20,000,000 | 23.4% | 14.1% | Yes — contract type | price ≤ 70% / 50% |
| Ireland | €50,000 | 23.1% | 8.2% | No | — |
| Italy | none | — | 11.8% | Yes — seven categories | price ≤ 30% / 10% |
| Latvia | €10,000 | 4.6% | 14.5% | Yes — contract type | — |
| Lithuania | €15,000 | 6.9% | 11.0% | Yes — annual portfolio cap | 50% of annual value |
| Luxembourg | €144,987 | 67.1% | 12.5% | No | — |
| Malta | €10,000 | 4.6% | 11.5% | No | — |
| Netherlands | none | — | 20.5% | Motivation duty only | — |
| Poland | PLN 170,000 | 18.3% | 13.7% | Yes — authority category | price ≤ 60% |
| Portugal | €75,000 | 34.7% | 9.9% | No | — |
| Romania | RON 270,120 | 25.1% | 12.8% | Yes — banned above EU thresholds | price ≤ 40% |
| Slovakia | none | — | 13.0% | No | — |
| Slovenia | €40,000 | 18.5% | 14.6% | Yes — four service families | — |
| Spain | €15,000 | 6.9% | 11.0% | Yes — plural criteria default | quality ≥ 51% |
| Sweden | SEK 700,000 | 28.6% | 17.1% | No | — |
Spend figures: Eurostat gov_10a_main (S13, P.2 + P.51G + D.632PAY) over nama_10_gdp B1GQ at market prices, 2024. These reproduce the OECD's published series to three thousandths of a percentage point.
9. A caveat about the spending figures
The standard definition of government procurement spend includes a component called D.632 — government paying private providers to deliver services to households, overwhelmingly healthcare. It is not competitively tendered procurement in any ordinary sense, and it ranges from 5.9% of the total in Romania to 51.9% in Belgium.
Remove it and the ranking changes sharply. The Netherlands is first in the EU on the headline measure and fourteenth without it. Belgium falls from seventh to twenty-fifth. The countries that fall are the social-health-insurance systems; the countries that rise are tax-funded ones with public providers. On the headline measure you are partly ranking how a country organises health financing.
Ireland sits last on both measures partly for an unrelated reason: Irish GDP is inflated by multinational contract manufacturing and intellectual-property relocation, which is why Ireland's own statistics office publishes an alternative aggregate. Luxembourg has a milder version of the same distortion.
10. We tried to measure how much is visible EU-wide. The data cannot support it.
We had intended to publish, for each country, the share of its procurement that reaches TED, the EU-wide notice database. We dropped it, and the reason is itself a finding.
The raw sum of 2024 award values on TED is €186,997 billion — because 0.5% of notices carry 99.7% of the total. One Swedish notice reports SEK 2.1 quadrillion, about €185 trillion, larger than world GDP and 99.95% of Sweden's national total on its own. A Portuguese notice reports 2.5 times Portugal's GDP. These sit unflagged in the Commission's own public database.
And value reporting is wildly uneven. Across the EU, 82.6% of award notices carry a value at all — but Germany, the largest procurement market in Europe, records one on 48.2%, against 99.3% in Croatia. A ranked "visibility" column would put Germany near the bottom of Europe, and the honest reading of that is that Germany does not fill in the field.
Every member state publishes to the same database under the same directives. The EU's own procurement data cannot presently support a comparison of how much procurement is visible EU-wide.
11. A new EU Procurement Act is coming, and it stops at the same thresholds
A draft of a new EU Public Procurement Act leaked in July 2026, and is a Regulation rather than a directive — directly applicable, no transposition margin. It would make best price-quality ratio the standard award method with a minimum 30% quality weighting, rising to 50% for labour-intensive contracts.
Two things about it are not being widely reported. First, the same article permits a buyer to derogate from both the method and the percentage floor wherever quality "can be ensured by" specifications or contract performance clauses — so a buyer who writes adequate specifications can, on the face of the draft, return to price-only award. A 30% floor subject to that derogation is a materially weaker rule than the headline suggests.
Second, and more relevant here: the draft does not regulate below-threshold procurement at all. Its scope article applies it to contracts at or above the same thresholds. Even as a directly applicable Regulation, everything described in this article stays national.
Meanwhile, in May 2026, a group of member states including Germany formally asked the Commission to abandon the Regulation and keep directives instead. Nothing has been tabled; the Commission's current target is September 2026.
12. Changes already scheduled
Four of these rows have a known expiry date. This article states the law in force on 4 August 2026.
- France, 21 August 2026 — the climate law in section 6 commences, and price-only award becomes arithmetically impossible.
- Croatia, 1 September 2026 — the ceiling rises from €26,540 to €50,000, but a statutory mandatory public call appears at €25,000 and the regime below it changes from delegated to statutory. The nominal threshold rises while the effective floor falls.
- Hungary, 31 December 2026 — the national thresholds are set annually in the budget act and lapse on that date.
- Luxembourg, 1 January each year — €144,987 is the 2026 value. It is re-indexed automatically against inflation, with no legal instrument required.
Conclusion
One directive, twenty-seven answers to a question the directive never asks: when does a public contract become visible to someone who was not already invited?
For a large group of member states, the honest answer is: not until Brussels says so. And the reform now being drafted would not change that, because it stops at the same thresholds.
If you bid across borders, the practical consequence is that the threshold table you are working from is probably measuring the wrong thing — and that in a good part of Europe, the contracts below the EU threshold were never going to appear on any list you were watching.
All figures state the law in force on 4 August 2026, read from national primary sources. Tendergate encodes several of these national regimes in its procurement analysis.