EU procurement thresholds 2026/2027: when does a transport service have to be tendered EU-wide?

Since 1 January 2026 the threshold for public supply and service contracts stands at EUR 216,000 net where the contracting authority belongs to the übrige öffentliche Auftraggeber. That group includes the federal states, districts, municipalities and municipal bodies. Upper and supreme federal authorities sit at EUR 140,000 net. Works contracts and concessions carry a value of EUR 5,404,000. Behind all three figures stand Commission Delegated Regulations (EU) 2025/2150, 2025/2151 and 2025/2152 of 22 October 2025.

All figures are net amounts. § 106 paragraph 1 GWB explicitly refers to the estimated contract or agreement value excluding VAT, and paragraph 2 points to the EU directives for the actual amounts. The German legislator therefore does not set the numbers at all. They come from Brussels and reach into national law through that reference.

One value stayed put. The thresholds for social and other specific services under Annex XIV of Directive 2014/24/EU are not covered by the WTO Government Procurement Agreement and were therefore left unchanged. They remain at EUR 750,000 for public contracting authorities and EUR 1,000,000 for utilities. For pure transport work that rarely helps, and the reason follows further down.

The three delegated regulations of 22 October 2025 were published in the Official Journal of the EU on 23 October 2025 and apply from 1 January 2026. Each of them amends exactly one directive.

• Delegated Regulation (EU) 2025/2152 amends the classic procurement directive 2014/24/EU. It cuts EUR 5,538,000 to EUR 5,404,000, EUR 143,000 to EUR 140,000 and EUR 221,000 to EUR 216,000.
• Delegated Regulation (EU) 2025/2150 amends the utilities directive 2014/25/EU. It cuts EUR 443,000 to EUR 432,000 and EUR 5,538,000 to EUR 5,404,000.
• Delegated Regulation (EU) 2025/2151 amends the concessions directive 2014/23/EU from EUR 5,538,000 to EUR 5,404,000.

For municipal transport contracts, 2025/2152 is therefore the relevant reference. Summaries occasionally cite 2025/2151 at this point, which is wrong.

Why the values fell at all is set out in the recitals of the regulations. The thresholds are tied to the WTO Agreement on Government Procurement, which fixes the amounts in special drawing rights. Every two years the Commission checks whether the euro figures in the directives still match the agreement and resets them with effect from 1 January. It is an exchange rate calculation rather than a political decision, and it can swing either way.

To classify a specific procedure, the start of the procedure is what counts. The new values apply to procurement procedures started on or after 1 January 2026 and remain applicable until 31 December 2027. Under § 3 paragraph 3 VgV the decisive day is the one on which the contract notice is dispatched or the procedure is otherwise initiated. Neither the award nor the contract start date matters.

A transport contract has to be tendered EU-wide as soon as the estimated total net contract value reaches the applicable threshold, so EUR 216,000 for municipal contracting authorities. The calculation rules sit in § 3 VgV (the German regulation on the award of public contracts). That is also where most of the mistakes happen.

Five rules from § 3 VgV

• Options count. Under § 3 paragraph 1 VgV any options and contract extensions must be taken into account, even where it is entirely open whether they will ever be exercised.
• Lots are added together. Where a service leads to a contract split into several lots, § 3 paragraph 7 VgV requires the estimated total value of all lots to be used. If that total reaches the threshold, the VgV governs the award of every lot, the small ones included.
• Splitting to circumvent the rules is not allowed. § 3 paragraph 2 VgV prohibits both the choice of calculation method and the subdivision of a contract where the intention is to escape EU procurement law.
• Without a total price, the 48-month cap applies. For service contracts with no stated total price, an indefinite term or a term beyond 48 months means 48 times the monthly value must be used (§ 3 paragraph 11 VgV).
• Recurring contracts are rolled forward. For regularly recurring contracts, § 3 paragraph 10 VgV allows the actual total value of the previous year to be used, adjusted for expected changes in volume and cost.

Worked example: school transport in four lots

A district awards freigestellter Schülerverkehr (school transport exempted from the public transport licensing regime) to the special-needs schools in its area across four lots. The base term runs two school years, with an option to extend twice by one school year each.

1. 1Set the annual value per lotLot A EUR 95,000, lot B EUR 70,000, lot C EUR 45,000, lot D EUR 30,000, each net per school year. Total EUR 240,000 a year.
2. 2Extrapolate the base termTwo school years give EUR 480,000. That figure alone sits well above EUR 216,000.
3. 3Add the option yearsWith both extension options the contract spans four school years and an estimated total value of EUR 960,000 net. This is the figure that decides the type of procedure.
4. 4Check the de minimis exemption for small lotsUnder § 3 paragraph 9 VgV a single lot may be awarded nationally if its estimated net value stays below EUR 80,000 and the sum of these small lots does not exceed 20 per cent of the total value. Lot D reaches EUR 120,000 over four years and therefore breaks the EUR 80,000 limit, even though its annual value is only EUR 30,000.

Why the de minimis limit almost never holds

The last step is where things go wrong most often. The EUR 80,000 in § 3 paragraph 9 VgV refers to the value of the lot across the entire term, not to a single contract year. In multi-year contracts with option years, practically every serious lot drops out of the exemption. A contracting authority that builds its procedure on it risks having the whole thing reopened after a complaint.

If the estimated total value stays under EUR 216,000, Part 4 of the GWB does not bite. National sub-threshold law applies instead, and for supplies and services that mainly means the Unterschwellenvergabeordnung (UVgO), the procurement rules below the EU thresholds. The UVgO is not a directly binding legal norm, though. It takes effect through budgetary application orders issued by the federal government and the states, and those differ, sometimes even within one state between state and municipal authorities.

Whether a contracting authority in your district has to obtain three quotes from EUR 25,000 or only runs an open tender from EUR 50,000 is therefore not written in the UVgO but in the procurement rules of the state in question. Anyone bidding across several states should know these value limits state by state.

The differences are tangible. Federal contracting authorities initially worked with a temporary limit of EUR 15,000 net for Direktauftrag (direct award without a competitive procedure), departing from § 14 UVgO; the Vergabebeschleunigungsgesetz (procurement acceleration act), in force since 1 July 2026, raised it to EUR 50,000 net. States and municipalities set their own, sometimes markedly different limits for Direktauftrag, Verhandlungsvergabe (negotiated award) and beschränkte Ausschreibung (restricted invitation to tender). On top of that come the Landesvergabegesetze (state procurement acts) with collective-agreement compliance, minimum pay and evidence requirements, which in some states apply below the EU thresholds too and hang on their own value limits.

Movement has been announced for the coming months. On 30 June 2026 the Federal Ministry for Economic Affairs and Energy presented a draft for a fundamental revision of the UVgO, currently being coordinated between the federal government and the states. Until the states update their application orders, the current state rules remain decisive.

Above the thresholds there is no way around Tenders Electronic Daily (TED), the supplement to the Official Journal of the EU. § 40 VgV sets out an order of publication that matters in practice for market monitoring. National publication may only follow once the EU Publications Office has published the notice, or once 48 hours have passed since the confirmation of receipt. It may also contain no information that was not sent to Brussels as well. Finding a notice first on a state platform therefore gives you no head start over European competitors.

Alongside that, oeffentlichevergabe.de, the notice service of the Datenservice Öffentlicher Einkauf at the Beschaffungsamt des BMI (the procurement office of the federal interior ministry), pools EU-wide and national notices from federal, state and municipal bodies. The search is open without registration. For EU-wide notices, the standardised eForms have been mandatory since 25 October 2023. The procedure itself, with tender documents, bidder questions and submission, then runs on the relevant state platform.

For searching, the CPV code is the most usable filter. School, disabled passenger and sheltered-workshop journeys are overwhelmingly published under [60130000-8 (special-purpose road passenger transport)](https://ted.europa.eu/en/simap/cpv). A standing filter on that code plus the districts in your own catchment area catches live tenders and, alongside them, the award notices for contracts already placed. Their contract terms tell you when the next round is due.

Code 60130000-8 does not appear in Annex XIV of Directive 2014/24/EU. The lighter regime for social and other specific services under § 130 GWB, which carries the EUR 750,000 figure, therefore does not apply to pure transport work. The EUR 216,000 stands. The picture changes where a contract combines transport with care and supervision. Then § 110 GWB makes the main subject matter decisive, and that is determined by whichever part of the service carries the higher estimated value.

If even a mid-sized school transport award with option years almost inevitably lands above the threshold, the EU-wide procedure with formal deadlines and documented suitability checks becomes the normal case. An operator can plan around that.

More important than the type of procedure is the length of the commitment. It runs across the full term including options, four school years in the example above. Anyone checking a lot against the vehicle and driver capacity available today is answering the wrong question. What matters is whether that capacity still holds in year four, and at what cost. It only becomes reliable with actual operating data, meaning real route times, empty kilometres, waiting times and cancellation rates. Dispatch and route planning systems produce these numbers anyway; the question is whether the last twelve months are available in a form you can analyse or have to be reconstructed from paper logbooks. How that turns into a defensible rate per kilometre is something we worked through in a separate piece on cost per kilometre in minibus operations.

On suitability evidence, things eased on 1 July 2026. For awards above the EU thresholds, the Vergabebeschleunigungsgesetz makes self-declarations the default; the actual evidence is generally requested only from the company set to receive the award. That shortens bid preparation noticeably. You still have to keep the documents ready, because once the award recommendation is out there is little time for follow-up requests.

• Calculate the total value of a lot across the full term including all option years, never the annual value on its own.
• Check whether vehicle and driver capacity still holds in the final option year, including replacement vehicles and cover arrangements.
• Keep Führungszeugnisse (police clearance certificates), passenger transport driving permits, insurance certificates and tax clearance certificates continuously up to date.
• Draw your costing basis from the actual data of the last twelve months, meaning kilometres, hours, empty runs and cancellation rates.
• Set up CPV 60130000-8 as a standing filter on TED and oeffentlichevergabe.de and read the award notices alongside the live tenders.
• Check the Landesvergabegesetz of the contracting authority in question, because collective-agreement and minimum pay requirements shift the staff costs in your calculation.

On the other side of the table the reverse applies. A lot structure that artificially pushes individual lots below EUR 80,000 will usually not survive scrutiny under § 3 paragraphs 2 and 9 VgV. Anyone wanting to reach the market of smaller transport operators gets further with a sensible lot structure and proportionate suitability requirements than with the choice of procedure. What that involves from the perspective of a Schulträger (the public body responsible for the school) is set out in our overview for schools and school authorities.