Estonia Drops Its National Procurement Tier from 1 November: What Changes for an SME Bidder

Estonia is removing an entire tier of its public procurement system. From 1 November 2026 the national threshold disappears, and on the Finance Ministry's estimate 49 percent of domestic procurements shift into the lighter lihthange procedure. The thresholds had not moved since 2017, and the bill's memorandum says inflation had left them so low that small purchases were forced through the full procedure. The Riigikogu adopted the Public Procurement Act and Other Acts Amendment Act (riigihangete seaduse ja teiste seaduste muutmise seadus) on 16 June 2026 with 61 votes in favour, and it appeared in Riigi Teataja on 3 July. The government's January press release had aimed for 1 September; any procedure started before 1 November finishes under the old rules.

Quick answer: Three tiers become two: the national threshold ("riigihanke piirmäär") is abolished and the simplified thresholds rise, so for ordinary public-sector goods, services and works everything from the new simplified line to the EU threshold is a simplified procurement (lihthange). Bid windows get longer, and a bidder gets one guaranteed chance per procedure to cure a tax debt. Separately, the fee for a challenge to the Public Procurement Disputes Committee (VAKO) doubled on 1 January 2026. For suppliers, the biggest change is how these smaller tenders are run, not the size of the market.

The story in five numbers

• €50,000 and €100,000: the new simplified thresholds for goods and services and for works from 1 November 2026, up from €30,000 and €60,000
• €60,000 and €150,000: the national threshold for goods and services and for works that disappears; above it the buyer had to use the full procurement-procedure regime
• 49 percent of domestic procurements, but about 10 percent of contract value, move to the simpler procedure on the ministry's estimate
• 87 days to about 50: the ministry's reform estimate for the affected procedures; its 2025 statistics put open procedures at 72 days on average and simplified ones at 47
• €1,280 and €2,560: the state fee for a VAKO challenge since 1 January 2026, below and at or above the EU threshold, doubled from €640 and €1,280; a court appeal costs the same

What the act actually changes

The middle tier is gone. Section 14(2) of the Public Procurement Act, which set the national thresholds, is repealed, and rules that referred to it now point to the simplified or international threshold. From 1 November a public-sector buyer runs a simplified procurement from €50,000 (goods and services) or €100,000 (works) up to the EU threshold, put by the ministry's 2026 to 2027 table at €140,000 for state authorities, €216,000 for other buyers and €5,404,000 for works. Network-sector and defence buyers get €100,000 and €500,000.

Simplified does not mean short for the bidder. The minimum bid window rises from 10 to 15 days for goods and services and from 15 to 25 days for works, the minimums the open procedure already used above the national line. The standstill before signature grows from five to seven working days.

Several checks a losing bidder could lean on become optional below the EU line. The buyer no longer has to justify not splitting a procurement into lots unless the value reaches the EU threshold; the Chamber of Commerce notes this also removes the bidder's indirect route to challenge a bundled tender. In works, the mandatory review of abnormally low bids (under the act's price-gap tests) and subcontractor checks apply only from €500,000. The buyer may also pick which optional exclusion grounds to apply and, in price- or cost-only tenders, limit the conformity check to the offer it intends to award.

Tax debt is where the rules tighten. Today a buyer must give a bidder time to pay or defer a tax debt, and the law does not say how many times; the memorandum says buyers have had to pause procedures repeatedly when the same company ran up new debt between decisions. From 1 November the chance comes once, and again only for a good reason the bidder must argue. Hence the August business-press headline that tax arrears can no longer be smoothed over at the last minute.

From 1 January 2027 every buyer must also publish its procurement plan in the national register, not on its own website. For scale, 2025 saw 9,137 procurements in Estonia, estimated at over €8 billion, 4.4 bidders per tender on average, and 87 percent of awards decided on lowest price or total cost.

What a challenge now costs

The fee doubled under a separate act in force since 1 January 2026, the government reasoning that fees set in 2007 covered only about half of VAKO's staff costs as its caseload grew. A challenge below the EU threshold now costs €1,280, at or above it €2,560, and the same again if you take the committee's decision to the administrative court. VAKO received 299 challenges in 2025, 16 percent more than in 2024, and decided them in 22 days on average. The act also moves the deadline for challenging tender documents to five working days before the bid deadline in procurements at or above the simplified threshold, replacing lihthange's two-working-day rule.

The response

Finance Minister Jürgen Ligi framed the bill as a new balance: rules that guarantee fair competition cannot be very simple, but paperwork should not deter participation unduly. Kaur Kajak, Deputy Secretary General for administrative policy at the ministry, said in June the state wants to be a fast and reliable partner to business, not a source of unjustified bureaucratic obstacles.

The construction industry pushed back in consultation. Reimo Ehrstein, board member and head of construction at YIT, told EhitusEST in September 2025 that builders did not think it a good plan, because transparency would fall and buyer competence, above all among municipalities, is very uneven. Contractors proposed raising the €150,000 works line to €300,000 to €400,000 instead, keeping contracts above a million euros in the open procedure.

Estella Põllu, head of public procurement at the ministry, answered that simplified procurements must still be published in the register, that contract-value estimation rules do not change and bidders keep the right to challenge at VAKO. On 2024 data, she said, 229 works procurements, 10 percent by count and 2 percent by value, would lose the publication duty, and buyers increasingly publish small purchases voluntarily: 1,220 in 2020, 1,681 in 2024.

The Baltic picture

Latvia is moving the same way, later and further. Amendments that entered into force on 9 June 2026 will raise the full-procedure thresholds from 2028 to €140,000 for goods and services, €750,000 for social and other special services and €1 million for works. Below them come small purchases (up to €20,000 for goods and services, €30,000 for works) and simplified ones, whose only mandatory formality is publishing basic information in the Procurement Monitoring Bureau's system at least five days ahead. On paper that is lighter than Estonia's lihthange, which keeps register publication, bid minimums and a standstill.

What is still open

How buyers will use the register's procurement-plan module from January 2027 remains to be seen; the ministry runs a webinar on the new rules on 14 October 2026. The new simplified award procedure for network-sector buyers (section 152¹) requires only a "reasonable" bid deadline set by the buyer, so the time they allow will show only in practice. An older idea, folding VAKO into the administrative court, floated by minister Jaak Aab in 2019, is not part of this act.

What to do now

• Bidding on a procedure that started before 1 November? Check the notice date: it finishes under the rules in force on 31 October, old challenge deadlines included.
• Carrying a tax debt while a tender is running? Clear or defer it before the buyer asks: from 1 November you get one guaranteed chance, and a second only with a reason the buyer accepts.
• Thinking of challenging a bundled tender or a suspiciously low rival price below the EU threshold? Check whether the buyer applied those checks in the tender documents, and budget €1,280 for VAKO and the same again for court.

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