New Public Procurement Law 2025/2026 — What Changes for Contractors
Poland’s Public Procurement Law (Prawo Zamówień Publicznych, PZP) is going through its largest transformation since the Act of 11 September 2019 entered into force. The 2025/2026 amendment is not cosmetic. It is a systemic rebuild of how contracting authorities and contractors communicate, submit bids and perform public contracts. For IT, construction and services firms this means both new obligations and real business opportunities.
In this article we cover in detail the 7 most important changes, their impact on contractors (especially in IT), the implementation timetable, and concrete steps every company that bids in tenders should take. Whether your firm submits 3 or 30 bids a month — the changes apply to you directly and require action still in 2025. At the end you will find an FAQ and a preparation checklist.
Why Another PZP Amendment?
Legislative and market context
The public procurement market in Poland is worth more than PLN 250 billion a year — one of the largest budget pools in the entire European Union. At the same time, for years the system remained one of the most bureaucratic in Europe. The 2025/2026 amendment stems from several converging factors:
EU directives and eForms — since 2023 the European Commission has required electronic eForms in publications in the Official Journal of the EU (TED). Poland was one of the last countries not to have fully implemented the standard. The amendment closes that gap, introducing a mandatory eSender as the only channel of communication with TED.
100% digitalisation — even though the e-Zamówienia platform has been running since 2021, many procedures (especially below EU thresholds) were still run in hybrid mode — some documents on paper, some electronically. The amendment eliminates the last “paper loopholes” and makes full digitalisation the only permitted mode.
Digitalisation of public administration — the National Recovery Plan (KPO) and the 2025–2030 Digital Transformation of Administration Strategy assume that by the end of 2026, 100% of public services will be available online. Public procurement is a key piece of that puzzle.
Inflation and the need for indexation — the experience of 2022–2024 (a sharp rise in construction material, energy and wage prices) showed that the absence of mandatory indexation clauses leads to mass withdrawals from contracts and contractor bankruptcies. The legislator has drawn conclusions.
Green public procurement (GPP) — the European Green Deal requires that by 2027 at least 50% of public procurement in EU countries includes environmental criteria. Poland has catching up to do — in 2024 the share of green procurement was only 12%.
The 7 Most Important Changes in PZP 2025/2026
1. Full digitalisation — the end of paper
From 1 January 2026 all public procurement procedures — regardless of value — must be conducted exclusively in electronic form. This covers:
- Contract notices and the specification of contract conditions (SWZ)
- Submission of bids and requests to participate
- Contracting authority–contractor communication (questions, clarifications, requests)
- Bid-opening minutes
- Conclusion of contracts (qualified electronic signature)
What does this mean in practice? A contractor that does not have a qualified electronic signature and an account on the e-Zamówienia platform is de facto excluded from the public procurement market. There is no longer any possibility of submitting a bid in an envelope or sending documents by post.
It is worth stressing that digitalisation also covers subcontractors and third parties making resources available — every document submitted in a procedure (a third-party commitment, a subcontractor’s declaration of no grounds for exclusion) must be signed with a qualified electronic signature of the person authorised to represent that entity. That creates extra logistical challenges — especially when you work with smaller firms that have not invested in qualified signatures until now.
2. eForms / eSender — new TED forms
eForms is a unified European standard for public procurement notice forms. It replaces the previous Standard Forms used in TED publications. Key changes:
- More structured data — eForms contain more than 600 data fields (vs. ~200 in the old forms), which enables much more precise search and analysis of contracts
- eSender as the only channel — notices to TED may be sent only through a certified eSender module integrated with the e-Zamówienia platform
- Better interoperability — a unified XML format allows automatic processing of notices by tender-monitoring systems
For contractors this means better market transparency — more information in notices, easier filtering by detailed parameters, faster identification of contracts matching the company’s profile.
A practical consequence for contractors using tender-monitoring tools: systems must be updated to handle the eForms format. Older parsers based on Standard Forms will stop working correctly. If you use a solution that does not support eForms — it is time to change it. Modern platforms such as BudOS already handle the new format and automatically parse the extended data fields, enabling more precise matching of contracts to the contractor’s profile.
3. Raised thresholds — from PLN 130,000 to PLN 150,000
The amendment raises the threshold for applying the PZP Act to supplies and services:
| Category | Old threshold | New threshold | Change |
|---|---|---|---|
| Supplies and services | PLN 130,000 net | PLN 150,000 net | +15.4% |
| Works | unchanged | unchanged | — |
| Utilities contracts | unchanged | unchanged | — |
What does this mean? Contracts worth from PLN 130,000 to PLN 150,000 net for supplies and services are no longer subject to the full PZP procedure. Contracting authorities may run them under a simplified regime (internal rules). For contractors this is paradoxically a complication — fewer contracts are advertised publicly, which reduces market transparency in this segment.
At the same time, contracting authorities in this value band still have to publish notices in the Public Information Bulletin (BIP) or on the e-Zamówienia platform — but formal requirements on contractors are milder.
4. Remuneration indexation — mandatory in contracts longer than 12 months
This is one of the most important changes from the contractor’s perspective. The amendment introduces mandatory indexation clauses in every public procurement contract concluded for a period longer than 12 months. Details:
- Minimum indexation trigger: a change in costs of at least 5% of the remuneration value
- Base index: Statistics Poland (GUS) — the construction and assembly production price index (for works) or the consumer price index (for other contracts)
- Maximum indexation cap: not less than 10% of the remuneration value (the contracting authority may set a higher one)
- Frequency of indexation: no less often than every 6 months
Why is this a breakthrough? Until now contracting authorities often either provided for no indexation at all, or set absurdly low caps (e.g. 1–2%). Contractors had to price inflation risk into the bid, which raised procurement costs by 10–15%. Now the risk is shared more fairly.
5. E-invoicing — KSeF in public procurement
The National e-Invoice System (KSeF) becomes mandatory for all VAT taxpayers from 1 February 2026. In the public procurement context this means:
- Every invoice issued in the performance of a public contract must be sent through KSeF
- The contracting authority may not refuse to accept an electronic invoice from KSeF
- The KSeF invoice number becomes part of the contract settlement documentation
- Automatic verification of invoice data (NIP, amount, subject matter)
For contractors that have already implemented KSeF, this is a simplification — one invoicing channel instead of several. For those who are late with implementation, it is an extra organisational challenge in an already demanding transition period.
6. Green procurement (GPP) — new ESG criteria
Green Public Procurement (GPP) is an element of the European Green Deal that the PZP amendment implements at national level. Key changes:
- Mandatory environmental criteria in contracts above EU thresholds — at least one ESG criterion must account for a minimum of 10% of the bid-evaluation weighting
- Preference for low-emission solutions — contracting authorities may (and in selected sectors must) apply life-cycle costing (LCC) instead of purchase price alone
- Carbon-footprint requirements — in IT contracts above PLN 1 million the contracting authority may require a carbon-footprint declaration for the devices and services supplied
- Eco-certificates and labels — accepted as evidence of meeting ESG criteria
For IT firms this means having to prepare ESG documentation — environmental declarations, sustainability policies, energy-efficiency certificates for equipment. It is a new formal requirement, but also a competitive advantage — firms that prepare this documentation sooner will score extra points in bid evaluation.
7. Simplified procedures below EU thresholds
The amendment introduces a new “simplified basic procedure” for contracts below EU thresholds (currently EUR 221,000 for supplies and services, EUR 5,538,000 for works):
- Shortening of minimum bid-submission deadlines from 7 to 5 working days (procedure without negotiation)
- Simplified ESPD / JEDZ (European Single Procurement Document) — instead of the full form, a contractor’s declaration is enough
- Possibility of waiving the bid bond for contracts below PLN 500,000
- Electronic bid opening without a public stream (minutes are enough)
The effect? A faster procedure cycle — from notice to contract signature on average 25–30 days instead of the previous 40–60 days. For contractors this means less bureaucracy and faster cash flow.
Particularly important is the simplification of participation conditions. In the simplified basic procedure the contracting authority may not demand documents confirming fulfilment of the conditions at the bid-submission stage — a contractor’s declaration is enough. Documents may be demanded only from the contractor whose bid was ranked highest. That significantly reduces the administrative burden — instead of assembling a full document pack for every bid, you prepare them only when you can realistically win.
What Do the Changes Mean for IT Contractors?
The IT sector is one of the largest beneficiaries of the 2025/2026 PZP amendment — but only if firms prepare properly.
Opportunity: more digitalisation contracts
Full digitalisation of public administration generates huge demand for IT services:
- e-service systems — every office that has to digitise further processes needs software vendors
- Integrations with e-Zamówienia and KSeF — firms performing public contracts need tools for automatic communication with government platforms
- Cybersecurity — digitalisation increases demand for security audits, DLP systems, SOCs
- Training and change management — officials need support in moving to new tools
It is estimated that the value of IT contracts in the public sector will grow by 18–25% in 2026 compared with 2024 — mainly thanks to KPO funds earmarked for digitalisation.
Specific areas where growth in IT contracts is expected:
| IT segment | YoY growth (estimate) | Main funding source |
|---|---|---|
| Public e-service systems | +30% | KPO, FERC |
| Cybersecurity (NIS2) | +45% | Central budget |
| API integrations (KSeF, eForms) | +60% | Entity budgets |
| Cloud and migrations | +25% | KPO |
| Digital training | +20% | ESF+ |
Challenge: new formal requirements
Digitalisation of procurement also means new requirements on IT contractors:
- Qualified electronic signature — mandatory for everyone authorised to submit bids and sign contracts. Cost: PLN 200–400/year per certificate + USB token or electronic seal
- e-Zamówienia profile — company registration, KRS/CEIDG verification, assignment of authorised persons
- Electronic bid bond — bank/insurance guarantees in electronic form (PDF with a qualified signature)
- ESG documentation — for contracts above PLN 1 million, a carbon-footprint declaration and an environmental policy
- KSeF compliance — an invoicing system integrated with the National e-Invoice System
Necessity: automation of the bidding process
With a growing number of IT contracts (an estimated 15,000–18,000 procedures a year in the ICT sector) and shortened bid-submission deadlines, manual monitoring and bid preparation becomes inefficient. A firm submitting 8–12 bids a month needs:
- Automatic monitoring of new notices (alerts by CPV, keywords, value)
- A deadline-management system (deadline tracker with notifications)
- A library of bid-document templates (ESPD/JEDZ, references, declarations)
- A bid/no-bid analysis tool (win-probability scoring)
- Integration with electronic signature (batch signing)
Without automation the firm loses its competitive edge — it reacts more slowly than the competition, misses attractive contracts and wastes time on procedures it has no real chance of winning. In the era of full digitalisation and shortened deadlines, speed of response becomes a key success factor.
Implementation Timeline — When Does What Take Effect?
The 2025/2026 PZP amendment does not enter into force all at once — individual provisions have different effective dates. Below is the timetable of key changes:
| Change | Entry into force | Who it affects | What to do |
|---|---|---|---|
| Full digitalisation (end of paper) | 1 January 2026 | All contractors | Qualified signature + e-Zamówienia account |
| Mandatory eForms / eSender | 1 January 2026 | Contracting authorities (contractors indirectly) | Update TED monitoring |
| Raised thresholds (130k → 150k) | 1 March 2026 | Supplies and services | Also monitor contracting authorities’ BIP |
| Mandatory indexation | 1 April 2026 | Contracts of 12+ months | Prepare indexation calculations |
| KSeF in procurement | 1 February 2026 | All VAT taxpayers | Implement an e-invoicing system |
| Green procurement (GPP) | 1 July 2026 | Contracts above EU thresholds | ESG documentation |
| Simplified procedures below thresholds | 1 January 2026 | National contracts | Adjust bidding deadlines |
Practical note: Transitional provisions state that procedures initiated before a given change enters into force are conducted under the previous rules. That means that for the first 2–3 months of 2026 two regimes will operate in parallel — the old and the new.
For contractors this means having to maintain two sets of internal procedures for a time — for “old” procedures (initiated before the amendment) and for “new” ones (initiated after the changes take effect). That is an extra organisational burden worth planning in advance — ideally by the end of Q4 2025 prepare internal instructions for both paths.
How to Prepare the Company for the New PZP?
Implementation checklist — 12 steps
The checklist below covers all the actions a company that bids in tenders should take to be ready for the new PZP:
Technical infrastructure:
- Buy a qualified electronic signature for every person authorised to submit bids (Certum, Szafir, SimplySign — from PLN 200/year)
- Create and verify the company profile on the e-Zamówienia 2.0 platform
- Implement a KSeF system (integration with accounting software or a dedicated module)
- Configure a tender-monitoring tool with eForms support
Documentation: 5. Update bid templates — adapt them to the new digitalisation requirements 6. Prepare ESG documentation (environmental policy, carbon-footprint declaration) 7. Draft a simplified ESPD/JEDZ (version for procedures below EU thresholds) 8. Collect references and documents confirming experience in electronic form (scans with a qualified signature)
Internal processes: 9. Appoint a person responsible for monitoring legal changes in PZP 10. Train the bid team on the new procedures and tools 11. Develop an indexation procedure — how to calculate bids taking mandatory indexation into account 12. Implement a tool to automate the bidding process (monitoring → analysis → bid/no-bid decision → bid preparation)
Digitalisation of Procurement — the End of Paper
The e-Zamówienia 2.0 platform
In Q4 2025 the Ministry of Development and Technology launched version 2.0 of the e-Zamówienia platform, which replaced both the old version of the platform and miniPortal, which was switched off in 2024. Key features of the new version:
- Single access point — all procedures (national and EU) in one place
- Bid-submission module — integrated with a qualified signature (a Trusted Profile is not enough!)
- Electronic auctions — full handling of auctions as a bid-evaluation stage
- Encrypted communication — end-to-end encryption for documents covered by trade secret
- API for contractors — the ability to integrate with your own CRM/ERP systems
The end of miniPortal — what instead?
MiniPortal (epuap.gov.pl/miniportal) was definitively switched off on 31 March 2024. Contracting authorities that used it to run procedures had to move to:
- The e-Zamówienia platform (free, government-run)
- Commercial purchasing platforms (Marketplanet, Josephine, SmartPZP, Open Nexus)
For contractors this means having to hold accounts on several platforms at once — because different contracting authorities use different solutions. That is another argument for automating monitoring — a tool that aggregates notices from all platforms saves hours a day.
Qualified signature — the absolute minimum
There is no public procurement without a qualified electronic signature. From 1 January 2026 a Trusted Profile (ePUAP) is not accepted for signing bids — only a qualified signature or an electronic seal.
Options on the market:
| Provider | Annual price | Form | Notes |
|---|---|---|---|
| Certum (Asseco) | from PLN 199 | USB token / cloud | Most popular in PL |
| Szafir (KIR) | from PLN 249 | USB token | Banking |
| SimplySign (Asseco) | from PLN 299 | Mobile app | Convenient, no token |
| EuroCert | from PLN 219 | Token / cloud | International |
| CenCert (Enigma) | from PLN 189 | USB token | Budget option |
Recommendation: For a firm that regularly submits bids, the most convenient option is a cloud signature (SimplySign or Certum in the cloud version) — it lets you sign documents from any device without carrying a USB token.
Remember certificate validity — a qualified signature is valid for 1 or 2 years (depending on the variant). Expiry of the certificate during a procedure means you cannot sign supplementary documents or clarifications. Best practice is to renew the certificate at least 30 days before expiry and to have a backup certificate for a second person authorised to represent the company.
Remuneration Indexation — How to Use It?
Indexation clauses — new rules of the game
Mandatory indexation in contracts longer than 12 months is a fundamental change in the philosophy of public procurement. Until now contractors had to “price the risk” — i.e. build a buffer for inflation, wage growth or material prices into the bid. Now those risks are shared with the contracting authority.
How the new indexation clauses work:
- The contract must specify the indexation index (e.g. CPI, the GUS index for the sector)
- Indexation occurs automatically after the 5% cost-change threshold is exceeded
- The maximum indexation cap is a minimum of 10% of the remuneration value (the contracting authority may set a higher one)
- Frequency — no less often than every 6 months
- The contractor must present evidence of cost increases (invoices, subcontractor contracts)
How to negotiate indexation?
Even though the clauses are mandatory, their details (index, threshold, cap) are negotiable within the SWZ. Here are strategies for contractors:
Before submitting the bid:
- Analyse the proposed indexation clause in the draft contract
- If the indexation cap is too low (e.g. 10% on a 3-year contract), ask the contracting authority a question and propose a higher one
- Check whether the indexation index matches the structure of your costs (e.g. for IT, the ICT-sector wage index is better than general CPI)
When calculating the price:
- You no longer need to assume a full inflation buffer — a buffer up to the indexation threshold (5%) is enough
- That allows you to submit a more competitive bid while keeping profitability
- Include the administrative costs of indexation (preparing applications, documentation)
After signing the contract:
- Monitor GUS indices every month
- Submit indexation applications on time — delay may mean losing the right to indexation for a given period
- Document all cost increases on an ongoing basis (do not wait until you file the application)
Calculation example: If you are performing an IT contract to implement an ERP system worth PLN 2 million net over 18 months, and the GUS index rose by 7% after the first year — you have a right to indexation of at least 7% × 2 million = PLN 140,000 (subject to the cap). Without a mandatory clause you would have had either to accept the loss or to price that risk into the bid (adding PLN 200–300 thousand as a “buffer”), which would have worsened your price position. The new rules allow you to offer a real price and index it during performance — a win-win for both sides.
How Does Automation Help Meet the New Requirements?
The scale problem
The 2025/2026 PZP amendment increases both the number of available contracts (more electronic publications, better transparency thanks to eForms) and the formal requirements on contractors (ESG, KSeF, new forms). That creates a paradox — more opportunities, but also more administrative work per bid. Firms that do not invest in automation will quickly discover that the new PZP generates more costs than revenue.
An IT firm submitting 10 bids a month must:
- Analyse 200–500 notices to choose those 10 (time: 40–80 h/month manually)
- Prepare formal documents for each bid (time: 4–8 h/bid)
- Monitor legal changes and update templates (time: 8–16 h/month)
- Manage deadlines and respond to contracting-authority requests (time: 10–20 h/month)
In total: 100–200 person-hours a month — i.e. 1–2 full-time roles devoted solely to administering the bidding process.
Where does automation have the greatest effect?
1. Monitoring of legal changes An automated system tracks the Journal of Laws, UZP notices and changes on the e-Zamówienia platform. Instead of reading dozens of pages a week, you receive a summary of material changes with an assessment of the impact on your firm.
2. Alerts on new tenders Instead of manually browsing e-Zamówienia, TED and BIPs — you configure filters (CPV codes, keywords, value, location, contracting authority) and receive real-time notifications of contracts matching your profile.
3. Bid/no-bid scoring An algorithm analyses historical data on the contracting authority (how many bids came in, what the price spread was, who won), the contract parameters and your company’s profile — and recommends whether it is worth bidding. It saves 60–70% of the time spent analysing contracts you have no chance of winning.
4. Electronic forms and templates Automatic filling of the ESPD/JEDZ, declarations of no grounds for exclusion, and bid forms based on company data stored in the system. Instead of 4 hours preparing formal documentation — 30 minutes verifying automatically generated documents.
5. Deadline management and workflow A dashboard with deadlines, automatic reminders, task assignment (who writes the technical part, who prices it, who checks formalities) — full control of the bidding process without Excel and sticky notes.
BudOS — a platform for monitoring and automating bidding
BudOS is a tool designed specifically for contractors bidding in public procurement. It combines tender monitoring with automation of the bidding process — from identifying the opportunity, through bid/no-bid analysis, to preparing documents and managing deadlines.
In the context of the new PZP 2025/2026, BudOS offers:
- Monitoring of e-Zamówienia, TED (eForms), BZP and BIPs in one panel
- Automatic alerts matched to the company profile
- AI scoring of contracts — which to bid on and which to skip
- A library of document templates aligned with the new requirements
- Tracking of legal changes with an assessment of impact on bidding processes
Thanks to automation of the bidding process, a firm can not only keep up with the new requirements, but actually turn them into a competitive advantage. While the competition struggles with organisational chaos and missed deadlines, you will respond in hours — not days — of publication of an interesting contract.
FAQ — Frequently Asked Questions
Does a small company (SME) need to prepare for the new PZP?
Yes — if the company submits bids in public procurement, the new rules apply in full, regardless of size. What is more, digitalisation and simplified procedures are an opportunity for SMEs — lower entry barriers (less paperwork), faster proceedings (faster cash flow) and transparency (easier to compete with large players on equal terms). All you need is a qualified electronic signature (from PLN 189/year) and an e-Zamówienia account (free of charge).
When exactly do the individual changes take effect?
The amendment has a staggered timetable: full digitalisation and eForms from 1 January 2026, KSeF from 1 February 2026, new thresholds from 1 March 2026, mandatory indexation from 1 April 2026, and green procurement (GPP) from 1 July 2026. You will find a detailed table of dates in the “Implementation timeline” section above.
Is a Trusted Profile (ePUAP) enough to submit bids?
No — from 1 January 2026 only a qualified electronic signature or a qualified electronic seal is accepted for signing bids, applications and contracts in public procurement. The Trusted Profile still works for communicating with public offices (e.g. ZUS, tax office filings), but not for PZP. A qualified electronic signature can be bought from one of the certified providers (Certum, KIR, EuroCert, CenCert) — the cost is PLN 189–399 per year.
What if the contracting authority did not include an indexation clause?
If the contract is concluded for a period longer than 12 months and the contracting authority did not include an indexation clause in the draft contract, this is a breach of the PZP Act. The contractor may: (1) ask a question on the SWZ pointing out the missing required clause, (2) lodge an appeal with the National Appeals Chamber (KIO), (3) notify the President of the Public Procurement Office (UZP) of the breach. In practice the most effective step is a question on the SWZ — contracting authorities usually add the clause once the statutory duty is pointed out.
How can I monitor PZP changes on an ongoing basis?
We recommend three sources: (1) the Public Procurement Office newsletter — official interpretations and notices, (2) the Journal of Laws — publication of legal acts with entry-into-force dates, (3) a tool for automatic monitoring of legal changes, such as BudOS, which aggregates information from multiple sources and assesses their impact on your bidding processes. It is also worth following KIO case law — Chamber decisions in the first months of the new rules shape how they are applied in practice. It is also worth joining industry groups on LinkedIn and procurement forums — other contractors’ practical experience with the new procedures is often more valuable than a dry reading of the rules.
Summary — the New PZP as an Opportunity, Not a Threat
The 2025/2026 Public Procurement Law amendment is the most serious change in years — but for prepared firms it is above all a business opportunity. Full digitalisation removes geographic barriers (you can bid in tenders across Poland without travelling), mandatory indexation protects the profitability of long contracts, and simplified procedures shorten the time from notice to contract signature.
Key takeaways for contractors:
- Act now — most changes take effect in Q1 2026. Firms that prepare earlier have a first-mover advantage and avoid last-minute chaos
- Invest in tools — a qualified signature, tender monitoring, bid automation are not costs, but investments with measurable ROI (typical payback within 2–3 months)
- Use indexation — the new clauses allow more competitive bids without the risk of losing money on the contract, which directly translates into a higher win rate
- Prepare ESG documentation — green procurement is a growing trend, and firms with documentation ready score extra points on non-price criteria
- Automate monitoring — with 15,000+ IT contracts a year, manually browsing portals is a waste of time and money that costs you missed opportunities
Next step
Want to learn how BudOS can help your firm prepare for the new PZP and automate the bidding process? Book a free consultation — we will show you how to configure tender monitoring matched to your profile, how to cut bid-preparation time by 60–70%, and how to use mandatory indexation to build more competitive bids.
Article updated: 14 August 2026. Information based on the text of the PZP amendment published in the Journal of Laws and on notices of the Public Procurement Office. The authors monitor changes on an ongoing basis — if new interpretations or date shifts appear, the article will be updated.