New thresholds in public procurement in Poland (2026–2027)

Role of EU thresholds

EU thresholds in public procurement define the contract values from which the mandatory application of the Polish Public Procurement Law (PPL) and EU-based procedures applies. They determine:

• whether a contract is awarded under national or EU procedures, and
• the scope of procedural and compliance obligations imposed on contracting authorities and contractors.

 

Legal framework

Pursuant to Article 3 of the PPL, EU thresholds correspond to the values set out in:

• Directive 2014/24/EU (classical procurement),
• Directive 2014/25/EU (utilities procurement),
• Directive 2009/81/EC (defence and security),

as periodically updated by European Commission implementing acts adopted under the respective directives.

 

Thresholds applicable as of 1 January 2026

As of 1 January 2026:

• new EU thresholds apply for the 2026–2027 period, and
• a new average PLN/EUR exchange rate is used for contract value calculations:
  • 2024–2025: EUR 1 = PLN 4.6371
  • 2026–2027: EUR 1 = PLN 4.31

The change in the exchange rate directly affects the classification of procedures as national or EU-level procurements.

Below we publish the new EU thresholds for the 2026-2027 period: 

 

 

Increase of the national PPL application threshold

In parallel, from 1 January 2026:

• the national threshold for the application of the PPL has increased from PLN 130,000 to PLN 170,000,
• the PPL applies to classical procurement procedures and design contests with an estimated value equal to or exceeding PLN 170,000.

Procurement procedures initiated before 1 January 2026 (i.e. where the contract notice or invitation was published by 31 December 2025) remain subject to the previous legal regime.

 

Practical impact on the PPL system 

The changes effective from 2026 are two-way in nature. 

For one thing, the EU thresholds have been lowered, which means more contracts with a relatively higher value are now EU-level procurements.

On the other hand, the national threshold for the application of the Public Procurement Law has been raised to PLN 170,000, which excludes some lower-value contracts from the formal regime of the Act.

In practice, these changes mean, firstly, an increase in formal requirements for contracts of significant value, which will more often be classified as EU-level procurements, with a full range of procedural obligations. At the same time, contracting authorities gain greater flexibility in lower-value contracts, which are not subject to the Act.

Secondly, these changes do not lead to a lowering of substantive standards. On the contrary, the Public Procurement Law is increasingly serving as a tool to strengthen the application of ESG regulations. This applies in particular to obligations related to compliance with labour law, environmental protection, equal treatment principles and mechanisms for verifying the reliability of contractors.

Thirdly, a key practical effect is the strengthening of the role of the Public Procurement Law as a regulatory benchmark. Although some contracts are not directly subject to the Act, the standards developed on the basis of the Public Procurement Law – including transparency, proportionality and ESG requirements – are increasingly being transferred to simplified procedures, internal regulations and contracts below the national PPL application thresholds. As a result, the Public Procurement Law sets a real level of due diligence in the spending of public funds, regardless of its formal scope of application.

As a result, lowering EU thresholds and simultaneously raising the national PPL application threshold does not weaken the significance of the Act, but leads to its functional evolution. The Public Procurement Law ceases to be merely a procedural framework and becomes a systemic reference point for the entire public procurement market, strengthening responsible, sustainable and ESG-compliant spending of public funds.