From 1 January 2026, new European thresholds for public procurement contracts will come into force, defining the point at which EU procurement rules become mandatory. These thresholds, now reflected in Article 474 of the Portuguese Public Contracts Code (CCP), apply to all contracts falling within the scope of the relevant EU Directives.
According to AICCOPN, the thresholds apply to all procedures where the decision to contract is made on or after 1 January 2026, regardless of when the announcement is published or the tender procedure is launched. As such, contracting authorities and businesses must already take the new figures into account during the planning phase.
The EU thresholds determine when a public contract is subject to the harmonised rules of the EU Directives, including mandatory publication in the Official Journal of the European Union (OJEU), minimum time limits, the use of regulated procurement procedures, cross-border competition, and increased formal and documentary requirements. In essence, they set the line between contracts governed by national law and those requiring compliance with EU-level procedures.
The updated thresholds for the classical sector, as stated in Article 474(3) of the CCP, are as follows:
- Public works contracts: €5,404,000
- Contracts for goods and services awarded by central government authorities: €140,000
- Contracts for goods and services awarded by other contracting authorities: €216,000
- Social and other specific services (Annex IX of the CCP): €750,000 (unchanged)
For concessions of works and services, a single threshold of €5,404,000 is established under Article 474(2). Contracts exceeding this amount will fall under Directive 2014/23/EU, requiring enhanced transparency and competitive procedures.
In special sectors—such as water, energy, transport and postal services—the thresholds have also been updated under Article 474(4) of the CCP:
- Works contracts: €5,404,000
- Contracts for supplies, services and design contests: €432,000
- Social and other specific services: €1,000,000
These adjustments result from the publication of Delegated Regulations (EU) 2025/2150, 2025/2151 and 2025/2152 in the Official Journal of the European Union, which amend the thresholds in Directive 2014/24/EU (classical sector), Directive 2014/25/EU (special sectors), and Directive 2014/23/EU (concessions). The objective is to keep EU procurement rules aligned with market developments and international trade agreements.
The applicability criterion is clear: the new thresholds apply strictly to procedures where the internal decision to launch the contract is taken from 1 January 2026 onwards. The publication date or launch of the procedure is irrelevant.
When the estimated value of a contract exceeds the applicable threshold, the contracting authority must follow EU procedures, such as the open procedure, restricted procedure with prior qualification, competitive dialogue or innovation partnerships, depending on the context. These procedures include stricter publication requirements, mandatory use of electronic platforms, and higher technical and administrative demands.
For economic operators, this means longer timeframes, stricter formalities, increased international competition, and a need for technically robust bids. Internal preparation and knowledge of the EU legal framework will become increasingly important.
Contracting authorities are advised to update their procurement guidelines, reassess the estimated value of contracts, align upcoming procedures with the new thresholds, and raise awareness among internal teams to ensure legal compliance and avoid procedural invalidity.
The 2026 threshold update signals a significant shift in public procurement practices in Portugal. Both public entitiesand private bidders will be required to act with greater legal precision, technical capacity, and readiness to compete in an increasingly European-wide procurement landscape.
