How below-threshold procurement works
Below the EU thresholds (from 2026, €216,000 for supplies and services of state and municipal buyers, €140,000 for federal ministries, and €5,404,000 for works), German procurement is governed by budget law, not the competition law that applies above them. Two sets of rules do the work:
- UVgO for supplies and services.
- VOB/A, section 1 for works.
Neither is a statute. Each applies only where federal or state budget rules order it, and each state decides how, with its own value limits (Wertgrenzen). Municipalities usually follow their state’s rules, but North Rhine-Westphalia freed its municipalities from fixed limits in 2026.
Federal buyers since 2026:
- Direct award (Direktauftrag): up to €50,000 for supplies, services and works.
- Negotiated award without competition: up to €100,000 (supplies and services).
- Works: freihändige Vergabe up to €100,000 and restricted tender without a public call up to €150,000.
The procurement acceleration law (July 2026) also made negotiated procedures with a public call standard options alongside open and restricted tenders.
The limits in all 16 states
Values are net of VAT:
- DA = direct award.
- Neg. = negotiated award (UVgO) or freihändige Vergabe (works), without a public call unless stated.
- Restr. = restricted tender without a public call.
- “EU” = up to the EU threshold.
| State | Supplies and services: DA / Neg. / Restr. | Works: DA / Neg. / Restr. | State wage-compliance law |
|---|---|---|---|
| Baden-Württemberg | €100k / EU / EU | Municipal: €100k / €216k / €1M | Yes, above €20k; national minimum wage |
| Bavaria (municipal; state similar) | €100k / EU / EU | €250k / €1M / €1M | None |
| Berlin | €75k / €200k / €200k | €500k / €1M / €1M | Yes; €14.84/h (€15.58 from 2027) |
| Brandenburg | €100k / EU / EU | €100k / €1M / €1M | Law exists; floor below national minimum, so €13.90 applies |
| Bremen | €3k / under €50k / €100k | €5k / €50–100k / €500k | Yes; €14.87/h |
| Hamburg | €5k / simplified under €100k / under €100k | €3–10k / €150k / €1M | Wage rules planned for 2027 |
| Hesse | No procedure required up to €100k; above it, neg. and restricted up to EU | No procedure required up to €750k; above it, neg. and restricted up to EU | Yes, above €20k; sector agreements |
| Lower Saxony | €20k (schools €100k) / €100k / €100k | €20k / €150k / €1M | Yes, from €20k; national minimum |
| Mecklenburg-Western Pomerania | €100k / EU / EU | €150k / €300k / €1M | Yes; €14.68/h |
| North Rhine-Westphalia (state) | €50k / €100k (EU with a public call) / €100k | €100k / €100k (EU with a public call) / €1.25M | Yes, from €25k; national minimum |
| Rhineland-Palatinate | €10k / €100k / €100k | €10k / €100k / €250k | Yes, from €20k; national minimum |
| Saarland (municipal) | €100k / EU / EU | €100k / EU / EU | Yes, from €25k |
| Saxony | €500 / €25k / no fixed cap | €50k / €25–100k (disputed) / €150k | None (planned 2027) |
| Saxony-Anhalt | €100k / EU / EU | €100k / under €2.5M / EU | Yes; €16.12/h |
| Schleswig-Holstein | €50k / €150k / €150k | €100k / €1M / €1M | Repealed (public transport only) |
| Thuringia | €30k / EU / EU | €75k / €1M / €1M | Yes; about €15.40/h |
Notes:
- Bavaria’s municipal limits apply from 2025 to 2029.
- Baden-Württemberg’s raised limits expire in October 2027.
- North Rhine-Westphalia’s municipalities have had no state-set procedures or limits since 1 January 2026, only principles of efficiency, equal treatment and transparency, plus their own local rules.
- Saxony still applies older rules (VOL/A), and some of its works values are disputed between sources.
- Bremen plans to raise its limits sharply, which isn’t in force yet.
- National minimum wage: €13.90 an hour in 2026, rising to €14.60 in 2027.
What this means for you. Below these limits, buyers can award without advertising, so the contract goes to firms they already know or invite. Above them, contracts are advertised. In Bavaria, a municipality can give you a €250,000 works contract directly; in Bremen, anything over €5,000 needs a procedure.
Where below-threshold tenders are published
- Advertised tenders go on the buyer’s website or a procurement portal, and must be findable through the bund.de search (service.bund.de). Works tenders can also appear in newspapers or official gazettes.
- State platforms include vergabe.bayern.de, the Berlin procurement platform (mandatory for Berlin buyers, and electronic from €25,000), Brandenburg’s Vergabemarktplatz, Hesse’s HAD, evergabe.nrw.de, and the platforms of Saxony, Saxony-Anhalt, Thuringia and Saarland.
- The federal notice service (oeffentlichevergabe.de) is optional below the thresholds.
- After award: restricted tenders and negotiated awards above €25,000 must be published for 3 months (supplies and services), and works awards above €15,000–25,000 for 6 months. This is useful for tracking which buyers award what.
Challenging a decision
There’s no federal review procedure below the thresholds, but some states offer one:
| State | Review | Applies from |
|---|---|---|
| Saxony | Losing bidders are told at least 10 days before the contract. A complaint goes to the supervisory authority, and the award waits 10 days. | €75k works, €50k supplies and services |
| Thuringia | Procurement chamber at the state administration office | €150k works, €50k supplies and services |
| Saxony-Anhalt | Procurement chamber; information 7 working days before the contract | €120k works, €40k supplies and services |
| Hesse | Procurement competence office, after an unsuccessful complaint to the buyer | €750k works, €100k supplies and services |
| Rhineland-Palatinate | Procurement review offices | €75k (until June 2027) |
| Saarland | Non-binding conciliation | €25k |
Notice periods: Lower Saxony requires a 15-day standstill (10 if electronic), and Schleswig-Holstein requires 7 days’ notice to losing bidders from €50,000.
Everywhere: you can ask a civil court for an interim injunction to stop an award, and courts have granted these in 2024 and 2026 cases.
Tips for foreign bidders
- Self-declarations come first. Buyers may accept the European Single Procurement Document, and equivalent documents if you have a good reason.
- Prequalify to avoid resubmitting papers: PQ-VOB for works (open to any construction business) and the chambers of commerce’s AVPQ register for supplies and services.
- Bid electronically above €25,000. Some states allow email procedures up to €100,000–150,000.
- Expect German. No law requires it below the threshold, but tender documents and bids are in German in practice.
- Sign wage declarations above each state’s threshold. Several states require more than the national minimum.
- Cross-border interest: Brandenburg and Mecklenburg-Western Pomerania require buyers to check for it even before a direct award. Contracts that would interest foreign bidders must then be advertised fairly.
What changed in 2025–2026
- 2025: most states raised their limits. Bavaria and Baden-Württemberg’s municipalities and Rhineland-Palatinate in January, Thuringia in April, Lower Saxony in May, Brandenburg in June, Saarland in July, Saxony-Anhalt in November.
- 1 January 2026: new federal VOB/A limits; North Rhine-Westphalia freed its municipalities; new EU thresholds.
- March–May 2026: Mecklenburg-Western Pomerania (March), new state wage floors (Saxony-Anhalt and Bremen in April), the federal wage-compliance law (May), Schleswig-Holstein (May).
- June–July 2026: Hesse’s reformed procurement law (June); the federal procurement acceleration law and €100,000 negotiated awards; Berlin’s new procurement law (July).
- September–October 2026: Berlin’s new value limits, and North Rhine-Westphalia’s new state rules from 1 October.
- Coming:
- A slimmer UVgO, in draft since June 2026.
- Reforms in Lower Saxony and North Rhine-Westphalia.
- Wage rules in Hamburg in 2027.
- A wage law in Saxony in 2027.
- Higher limits in Bremen.
Questions
What is the direct-award limit in Germany?
It depends on who’s buying. Federal buyers can award directly up to €50,000 since July 2026 (works since January 2026). The states set their own limits: €100,000 for supplies and services in Bavaria, Baden-Württemberg, Brandenburg, Mecklenburg-Western Pomerania, Saxony-Anhalt and Saarland’s municipalities, but as low as €3,000 in Bremen and €5,000 in Hamburg. For works, Bavarian municipalities can award directly up to €250,000 and Berlin up to €500,000.
Do German states follow the federal VOB/A limits?
Only some. The new VOB/A limits (direct award €50,000, negotiated award €100,000, restricted tender without a public call €150,000) apply automatically only in states whose law refers to the VOB/A dynamically and that set no limits of their own. Lower Saxony and Rhineland-Palatinate explicitly don’t apply them, and most states have their own, often higher, limits.
Where are German below-threshold tenders published?
On the buyer’s website or a procurement portal, and they must be findable through the search on bund.de (service.bund.de). Many states have their own platforms, such as vergabe.bayern.de, evergabe.nrw.de and the Berlin procurement platform, which is mandatory for Berlin buyers. Direct awards aren’t advertised, but larger awards must be published afterwards.
Can I challenge a German tender below the EU threshold?
There’s no federal review procedure below the thresholds, but six states offer one: Saxony, Thuringia, Saxony-Anhalt, Hesse, Rhineland-Palatinate and, non-bindingly, Saarland. Lower Saxony and Schleswig-Holstein require advance notice to losing bidders. Everywhere, you can seek an interim injunction from the civil courts.
Do German states have their own minimum wage for public contracts?
Several do, above the national minimum wage of €13.90 an hour in 2026. Saxony-Anhalt requires €16.12, Thuringia about €15.40, Bremen €14.87, Berlin €14.84 and Mecklenburg-Western Pomerania €14.68; Hesse ties wages to sector collective agreements. Bavaria and Saxony have no state wage-compliance law, and others apply the national minimum.
Do I need to bid in German?
There’s no explicit legal rule, but in practice tender documents and bids below the threshold are in German. Self-declarations are the default, and prequalification through PQ-VOB (works) or the AVPQ register (supplies and services) saves you resubmitting documents.
Sources
- Federal VOB/A value limits from 1 January 2026 (BMWSB decree, via Bremen circular 01/2026)
- Vergabeblog: federal negotiated awards without competition up to €100,000 from 1 July 2026
- Baden-Württemberg: procedures and value limits (January 2026)
- Bavaria: value limits for municipal buyers from 1 January 2026
- Berlin: budget law (LHO and administrative rules), September 2026
- Brandenburg: administrative rules on §55 LHO (June 2025)
- Hamburg: procurement guideline HmbVgRL (January 2025)
- Hesse: amended procurement and wage law HVTG (GVBl. 2026 Nr. 40)
- Mecklenburg-Western Pomerania: procurement one-pager 2026
- Lower Saxony: value-limits ordinance NWertVO (from 29 May 2025)
- North Rhine-Westphalia: decree on the interim rules for §55 LHO (21 September 2026)
- Rhineland-Palatinate: current procurement information (April 2026)
- Saxony: Sächsisches Vergabegesetz
- Saxony-Anhalt: procurement ordinance AwVO (from 7 November 2025)
- Schleswig-Holstein: procurement ordinance as amended May 2026 (GVOBl.)
- Thuringia: administrative rules on public procurement (ThürVVöA 2025)
This guide explains the rules in plain English; it isn’t legal advice. Procurement rules change, and each tender document sets its own conditions — it always prevails.