Public procurement from 01.11.2026: the national threshold goes, simplified procurement thresholds rise

From 01.11.2026 the national procurement threshold (riigihanke piirmäär) disappears from the Public Procurement Act, and the simplified procurement (lihthange) threshold rises from 30 000 to 50 000 euros for supply and service contracts and from 60 000 to 100 000 euros for works contracts (RHS § 14 lg 1) [1] [2]. A public sector contracting authority now applies simplified procurement up to the international threshold (RHS § 15 lg 1) [3].

What changes

• Thresholds: the simplified procurement threshold is 50 000 euros for a supply or service contract; 100 000 euros for a works contract, a service concession, a defence and security supply or service contract (except services procured under the simplified regime) and a supply or service contract of a utilities contracting entity; 500 000 euros for a defence and security works contract and a works contract of a utilities contracting entity (RHS § 14 lg 1) [1]. Until now these amounts were 30 000, 60 000 and 300 000 euros (RHS § 14 lg 1) [2]. For special services contracts and concessions and design contests the simplified procurement threshold is 100 000 euros, for social services contracts and concessions 500 000 euros (RHS § 14 lg 1 p 4–5) [1].
• The international threshold replaces the national one: until now there was a national procurement threshold (60 000 euros for supply or service contracts, special services contracts and concessions and design contests, 150 000 euros for works contracts, 300 000 euros for social services contracts and concessions and for defence and security services procured under the simplified regime) (RHS § 14 lg 2) [2], and from that threshold a public sector contracting authority applied the procedure of Chapter 2 of the Act (RHS § 15 lg 2) [4]. Now a public sector contracting authority applies simplified procurement (Chapter 3, Division 1) when the estimated value is at least the simplified procurement threshold but below the international threshold, and Chapter 2 from the international threshold (RHS § 15 lg 1–2) [3]. In that range a utilities contracting entity applies the simplified award procedure (RHS § 15 lg 9¹, § 152¹) [3] [5].
• Simplified procurement time limits: the time limit for tenders may not be shorter than 15 days for supply or service contracts and 25 days for works contracts from submission of the contract notice to the register (RHS § 125 lg 4) [6]; until now 10 and 15 days [7]. Consent to conclude the contract may not be given before seven working days have passed since notice of the decision (RHS § 125 lg 9) [6], instead of five working days [7].
• Abnormally low tenders: the contracting authority must ask for an explanation in a works contract with an estimated value of at least 500 000 euros when at least three tenders were submitted and the price of the tender it intends to accept is at least 10 percent below the next one or at least 20 percent below the average (RHS § 115 lg 2) [8]. Until now the duty applied to works contracts and works concessions from the national threshold, and also when the average wage of the tenderer's or its subcontractor's employees in the reference period was below 70 percent of the average wage in the field (RHS § 115 lg 2) [9]. In simplified procurement, for a works contract of at least 500 000 euros the contracting authority also follows RHS § 115 and § 122 (RHS § 125 lg 5) [6].
• Misdemeanours: the misdemeanours of modifying a contract in breach of the requirements, concluding it on terms different from the procurement documents and concluding it without the required procedure, and the provision on their proceedings (RHS § 213–216), apply until 31.10.2026 [10] [11] [12] [13].

Who is affected

Contracting authorities and tenderers, above all in procurements with an estimated value between the simplified procurement threshold and the international threshold (RHS § 15 lg 1) [3]. Procedures started before 01.11.2026 „viiakse lõpuni, lähtudes käesoleva seaduse 2026. aasta 31. oktoobrini kehtinud redaktsioonis sätestatud nõuetest“ (translation: “are completed under the requirements of this Act as in force until 31 October 2026”) (RHS § 219³) [14].

What to do

• For procurements started from 01.11.2026, contracting authorities should compare the estimated value with the new thresholds (RHS § 14 lg 1) [1] and choose the procedure under RHS § 15 [3].
• Simplified procurement timetables must allow at least 15 or 25 days for tenders and a standstill period of seven working days (RHS § 125 lg 4 and 9) [6].
• Procedures started before 01.11.2026 continue under the previous wording (RHS § 219³) [14].