Threshold for Sub-Central Authorities

Sub-central authorities are the regional, local, and municipal bodies that sit below the national government level: county councils, city authorities, regional agencies, school boards, housing associations, and similar entities. Because their procurement is less internationally exposed than central government purchasing, they benefit from a higher threshold before the full EU directive procedures apply.

What is the threshold for sub-central authorities?

Under Directive 2014/24/EU, the threshold for supplies and services contracts awarded by sub-central contracting authorities is higher than the threshold for central government authorities. In the 2024-2025 period, this threshold is set at 221,000 euros for supplies and services (again, excluding certain social and specific services). For works contracts, the same threshold applies to all authority types regardless of whether they are central or sub-central.

The higher sub-central threshold reflects the World Trade Organization Government Procurement Agreement (GPA) structure: EU member states did not commit to opening sub-central procurement to the same level of international competition as central government procurement. As a result, the directive allows national flexibility to set the sub-central threshold at a higher level.

Why it matters for bidders

Sub-central authorities account for a substantial share of all public procurement spending across Europe. City councils, regional transport authorities, hospitals, and universities all fall into this category. If your target market is local and regional government, the sub-central threshold is the figure that determines when contracts must be published on TED and run through a full procedure.

Contracts below this threshold at the sub-central level may only be advertised on national or regional portals, or even directly to known suppliers in some member states. The threshold therefore directly affects how you monitor the market. Above-threshold sub-central contracts are fully accessible via TED to any European supplier; below-threshold opportunities are harder to find systematically.

When calculating whether a contract reaches this threshold, authorities must follow aggregation rules to combine related lots and similar requirements, and must not use anti-splitting rules to artificially divide contracts.

Example

A Spanish provincial authority plans to purchase IT support services across three separate departments. Each departmental contract is worth approximately 90,000 euros, giving a combined total of 270,000 euros. Because the contracts are functionally similar and would normally be acquired together, aggregation rules require the authority to treat the combined value as a single estimated value of 270,000 euros. This exceeds the sub-central threshold of 221,000 euros, so a full directive-compliant procedure must be run.

Frequently Asked Questions

Do hospitals and universities count as sub-central authorities?

In most EU member states, yes. Public hospitals, state universities, and bodies governed by public law that are not part of the central government apparatus are typically treated as sub-central or bodies governed by public law for threshold purposes. Their precise classification depends on national implementing legislation, but in practice they fall under the higher sub-central threshold rather than the lower central government threshold.

Is there a different threshold for social services at the sub-central level?

Yes. Social and specific services listed in Annex XIV of Directive 2014/24/EU have their own much higher threshold, which applies to all contracting authorities including sub-central bodies. See threshold for social and specific services for detail.

Can a sub-central authority voluntarily publish above-threshold notices even if the contract is below the threshold?

Yes. Many authorities choose to publish voluntary transparency notices or use EU portal tools even for below-threshold contracts, either for policy reasons or to attract a wider supplier base. This is permitted and does not trigger full directive obligations unless the authority explicitly commits to following directive procedures.