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We have already discussed the many changes awaiting entrepreneurs in 2026, including in “Tax changes from the beginning of 2026”. However, new developments are not limited to taxation. Next year also brings many changes to Public Procurement Law, including a higher minimum threshold for applying the Act and a new obligation concerning contracting authorities’ analysis of needs and requirements.
A higher threshold for applying Public Procurement Law
Public Procurement Law from 1 January 2026: raising the threshold from PLN 130,000 to PLN 170,000
The biggest change taking effect at the start of 2026 is undoubtedly increasing the minimum threshold from PLN 130,000 to PLN 170,000. This results from the President-signed Act of 25 July 2025 amending Public Procurement Law and certain other acts.
From 2026, all procurement below PLN 170,000 will therefore fall outside the Act’s stringent requirements.
Driven partly by rising goods and service prices, this simplifies matters and reduces formalities for both contracting authorities and contractors.
Many lower-value contracts can thus be performed without complex statutory tender procedures, saving both parties considerable time and money.
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The contracting authority’s needs analysis expanded to market research on increasing competition in procurement
The same amendment introduces another significant change.
A new obligation applies to public contracting authorities’ analysis of needs and requirements, conducted before commencing procurement proceedings.
Previously, this particularly examined whether identified needs could be met with internal resources and researched alternative means of meeting them and possible procurement implementation variants.
From 2026, the analysis must also include market research on increasing competition in the procurement procedure.
Public and subsidised contracting authorities using open tenders, restricted tenders, competitive procedures with negotiation, competitive dialogue or innovation partnerships must also identify procurement conditions promoting greater competition in their needs and requirements analysis.
Transitional provisions of the Act amending Public Procurement Law and certain other acts
Articles 7–10 contain transitional rules. Existing provisions apply to:
public procurement and framework agreement procedures and contests begun but not completed before 1 January 2026;
public procurement contracts and framework agreements concluded before 1 January 2026;
public procurement contracts and framework agreements concluded after 31 December 2025 following procedures initiated before 1 January 2026.
Other public procurement amendments taking effect in 2026
(The higher PLN 170,000 threshold is not the only simplification for contractors)
The Act of 5 August 2025 on certification of public procurement contractors also takes effect in 2026.
Certification aims to make participation easier by removing the need to repeatedly submit the extensive documentation currently required. Instead, a certificate will officially confirm fulfilment of specified tender participation requirements.
This should significantly accelerate bidding processes and simplify them, especially for businesses relying on tenders.
Businesses operating under Public Procurement Law should also remember that from 13 March 2026, rules will permit remote hearings before the National Appeals Chamber. This can significantly simplify daily operations and reduce the costs of attending in-person hearings.
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Summary
In 2026, contracting authorities and tender participants must remember several significant changes. The most important include:
raising the minimum Public Procurement Law threshold from PLN 130,000 to PLN 170,000;
expanding the needs and requirements analysis to market research on increasing competition;
using certificates confirming specified requirements are met;
participating remotely in National Appeals Chamber hearings.
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