Public Procurement Changes in Poland in 2026: A Timeline with Sources

This timeline collects the 2026 changes in Polish public procurement in one place. Each entry has a date, the group of bidders it affects, its legal status and a link to the official source, so your bid team can check it in the original. It also covers the EU-level changes that matter for anyone bidding in Poland. If you are new to the Polish system, start with our overview of how public procurement works.

Key changes at a glance

In 2026, bidders in Poland are affected by seven changes and deadlines, plus two drafts still in progress:

• From 1 January 2026, the Polish Public Procurement Law (Pzp) applies to contracts worth PLN 170,000 net or more (previously PLN 130,000), which affects companies bidding for smaller contracts.
• From 1 January 2026, the EU thresholds for 2026 and 2027 apply, together with a conversion rate of PLN 4.31 per euro, which affects companies bidding for the largest contracts.
• From 1 February 2026 for the largest companies and from 1 April 2026 for all other Polish VAT taxpayers, invoices must be issued in KSeF, the national e-invoicing system, including invoices to public buyers.
• From 13 March 2026, the National Appeal Chamber (KIO) can hold remote hearings, and evidence must be filed no later than the day before the hearing, which affects bidders who file or join appeals.
• From 3 April 2026, contracting authorities must reject bids that include ICT products covered by a high-risk vendor recommendation or decision, which affects IT and telecoms suppliers.
• From 12 July 2026, voluntary contractor certification is available to any company bidding in Poland.
• On 31 August 2026, the deadline for Recovery and Resilience Plan (KPO) milestones passed, which affects contractors on KPO-funded contracts.
• Still in progress: the draft amendment to the Pzp (UD409) on KIO appeals and abnormally low prices, and the EU Public Procurement Act proposed on 9 September 2026.

Month-by-month timeline

The table lists the 2026 changes in date order. Each row shows the legal status and the date we last checked it against the source.

January 2026: new Pzp threshold and EU thresholds for 2026 and 2027

From 1 January 2026, the Polish Public Procurement Law applies to contracts worth PLN 170,000 net or more. The previous threshold was PLN 130,000. The change comes from a 2025 amendment (Journal of Laws 2025, item 1173), and procedures launched before 1 January keep the old threshold. Smaller purchases follow each authority's internal rules and are usually advertised in the Public Information Bulletin (BIP) or on the authority's own purchasing platform.

On the same day, the EU thresholds for 2026 and 2027 took effect, together with a new conversion rate of PLN 4.31 per euro. The thresholds are slightly lower than in 2024 and 2025, so some procedures that used to be national now follow the EU procedure. The Polish amounts were announced by the President of the Public Procurement Office in a notice of 8 December 2025:

• supplies and services for central government authorities: EUR 140,000, or PLN 603,400,
• supplies and services for other classical contracting authorities: EUR 216,000, or PLN 930,960,
• supplies and services for utilities: EUR 432,000, or PLN 1,861,920,
• works: EUR 5,404,000, or PLN 23,291,240 (EUR 5,538,000 in 2024 and 2025).

The euro amounts are the same in every EU member state. Above-threshold procedures are published in the Official Journal of the EU and available in TED. Our guide on where to find public tenders in Europe shows how to search TED alongside national portals.

February and April 2026: mandatory KSeF e-invoicing

From 1 February 2026, companies whose 2024 sales exceeded PLN 200 million issue invoices in KSeF, the National e-Invoicing System. From 1 April 2026, the obligation covers all other VAT taxpayers. It also applies to invoices issued to public buyers. The Electronic Invoicing Platform (PEF) remains the channel for invoices in public procurement and is integrated with KSeF.

A transition period runs until 31 December 2026. Penalties for KSeF errors are deferred, and the smallest taxpayers, with monthly sales up to PLN 10,000, may still invoice outside the system. Foreign bidders without a Polish establishment should confirm with their tax adviser whether the obligation applies to them. Dates and exemptions are listed by the Polish Ministry of Finance on the KSeF website.

March 2026: remote KIO hearings and a new procurement policy

From 13 March 2026, appeal procedures follow rules introduced by the 2025 deregulation act. The President of the National Appeal Chamber (KIO) can order a remote hearing or session (Art. 508a Pzp). Parties file evidence with the appeal, the response, the notice of intervention or in a letter submitted no later than the day before the hearing (Art. 535 Pzp). The contracting authority must file a response to the appeal. The new rules do not apply to disputes in procedures launched before 13 March 2026. The current text is available in the Public Procurement Law in the ISAP database.

On 31 March 2026, the Council of Ministers adopted the National Procurement Policy 2026-2029. The policy sets directions for contracting authorities and does not change the law. Its priorities are the competitiveness of the Polish economy with a focus on SMEs, state resilience and the professionalisation of the procurement market. Its tools include an SME test, plainer language in tender documents and dividing large contracts into lots more often.

April 2026: cybersecurity in ICT purchases

On 3 April 2026, an amendment to the Polish National Cybersecurity System Act took effect. A contracting authority must reject a bid that includes ICT products, services or processes named in a recommendation of the Government Plenipotentiary for Cybersecurity (Art. 226(1)(17) Pzp) or in a decision classifying a supplier as a high-risk vendor (Art. 226(1)(19) Pzp). According to the Ministry of Digital Affairs, no proceedings to classify a high-risk vendor had been opened by 6 August 2026, so no such list exists yet.

July and August 2026: contractor certification and KPO deadlines

On 12 July 2026, the Act on the certification of public procurement contractors took effect (Journal of Laws 2025, item 1235). Certification is voluntary. One certificate confirms that the company has no grounds for exclusion and has the capacity to perform the contract, so it does not need to file the same documents in every procedure. A regulation on the contractor certificate was published on 21 August 2026 (Journal of Laws 2026, item 1116).

On 31 August 2026, the EU deadline for reaching the milestones and targets of Poland's Recovery and Resilience Plan (KPO) passed. According to the Polish Ministry of Funds and Regional Policy, some projects can be completed and settled until the end of 2026. Contractors on KPO-funded contracts should check that acceptance and payment dates in their contracts fit this schedule.

September 2026: the EU Public Procurement Act and a new UD409 draft

On 9 September 2026, the European Commission proposed the Public Procurement Act, COM(2026) 590. The regulation would replace the three 2014 directives (2014/23/EU, 2014/24/EU and 2014/25/EU) and apply directly in every member state. It covers contracts at or above the EU thresholds. Below-threshold contracts, the organisation of national procurement systems and remedies stay with national law. The proposals that matter most for bidders are:

• two main procedures, open and dynamic, both of which can include negotiation without special justification,
• a cap on the required annual turnover, as a rule 50% of the estimated annual contract value (Polish law currently allows up to twice the contract value),
• quality criteria worth at least 30% of the score as a rule, and 50% in labour-intensive contracts, with justified exceptions,
• abnormally low price reviews without a fixed 30% trigger, based on other bids, market prices and actual delivery costs,
• mandatory electronic verification of bidder eligibility, which may use adapted national services, so Poland's contractor certification could become part of it,
• a single 15% threshold of the original contract value for non-substantial modifications, provided the economic balance of the contract is maintained.

Under the proposal, the regulation would enter into force 20 days after publication in the Official Journal of the EU and apply two years later. The text now goes to the European Parliament and the Council, so details may still change. A clause-by-clause comparison with the Polish Public Procurement Law (in Polish) is available from Portal Zamówienia Publiczne.

On 17 September 2026, a new version of the draft Pzp amendment (UD409) appeared. According to legal press coverage, it keeps the proposed appeal fees, the abnormally low price rules and the binding force of KIO resolutions unchanged. The edits concern remote hearings and legal guidance issued by the President of the Public Procurement Office. Each version of the draft is published by the Government Legislation Centre.

What the changes mean for bidders

The table turns each change into a task. Every row ends with an action your bid team can add to its plan.

Some changes happen inside a single procedure, after the notice is published. Authorities amend documents and move deadlines, so a fixed process for tender document change monitoring protects the bid until submission.

What is still in progress

• Pzp amendment (UD409): draft. It covers higher KIO appeal fees, dropping the automatic 30% trigger for abnormally low price reviews and moving the burden of proof to the appellant. Adoption by the Council of Ministers is planned for Q4 2026, so the new rules could apply from 2027 at the earliest.
• Capability levels for construction works: planned. The regulation is a draft, and its entry into force is planned for 1 January 2027.
• KSeF: transition period until 31 December 2026. From 1 January 2027, the obligation also covers the smallest taxpayers, and invoicing errors may lead to penalties.
• Public Procurement Act: European Commission proposal. Until the regulation is adopted and starts to apply, the 2014 directives and national laws such as the Pzp remain in force.
• EU thresholds: in force until 31 December 2027. The next update is scheduled from 1 January 2028.

Sources

Every entry in the timeline can be checked in an official source:

• Public Procurement Law (Pzp) in ISAP, consolidated text: Journal of Laws 2026, item 793
• Notice of the UZP President of 8 December 2025 on EU thresholds
• KSeF implementation dates, Ministry of Finance
• National Procurement Policy 2026-2029, Ministry of Development and Technology
• High-risk vendors, Ministry of Digital Affairs
• UD409 in the government legislative work programme
• UD409 at the Government Legislation Centre
• KPO deadlines, reply of the Ministry of Funds and Regional Policy to a parliamentary question
• Public Procurement Act, European Commission press release

Frequently asked questions

What are the EU procurement thresholds in 2026?

From 1 January 2026 to 31 December 2027, the threshold for works is EUR 5,404,000. For supplies and services, it is EUR 140,000 for central government authorities, EUR 216,000 for other classical contracting authorities and EUR 432,000 for utilities. In Poland, the conversion rate for these amounts is PLN 4.31 per euro, so the works threshold equals PLN 23,291,240.

When did contractor certification start in Poland?

The Act on the certification of public procurement contractors has applied since 12 July 2026. Certification is voluntary. Capability levels for construction works will start once the related regulation takes effect, planned for 1 January 2027.

Is the Polish amendment on KIO appeals already in force?

No. The amendment (UD409) is a draft, and its latest version is dated 17 September 2026. Adoption by the Council of Ministers is planned for Q4 2026, so the new rules could apply from 2027 at the earliest. Remote hearings and the evidence deadline before KIO have applied since 13 March 2026.

Do invoices to Polish public buyers have to go through KSeF?

Yes, for Polish VAT taxpayers. Since 1 February 2026 for the largest companies and since 1 April 2026 for all others, invoices, including those to public buyers, are issued in KSeF. The Electronic Invoicing Platform (PEF) still delivers invoices to public buyers and is integrated with KSeF. The smallest taxpayers have a transition period until the end of 2026.

Where can I track changes in Polish public procurement?

Laws are published in the Journal of Laws (ISAP and ELI), notices and guidance by the Public Procurement Office, draft laws by the Government Legislation Centre, and contract notices on the e-Zamówienia platform and in TED. This timeline collects changes from these sources, and we update it on the first working day of each month.

What is the EU Public Procurement Act and when will it apply?

The Public Procurement Act is a draft EU regulation proposed on 9 September 2026 to replace the three 2014 procurement directives and apply directly in every member state. It covers contracts at or above the EU thresholds. Under the proposal, it would apply two years after entry into force, and there is no fixed date yet because the European Parliament and the Council still have to agree the text.

Minerva tracks changes in the procedures you follow and shows them to your team in one place. Book a short call and we will show you how it works.

This article is for information only and is not legal advice. Legal status and legislative progress as of 21 October 2026. Before a decision in a specific procedure, check the current text of the law in official sources or consult a lawyer.