Amendments to the Finnish Public Procurement Act in 2026 – Key changes

Mandatory market studies for contracts over EUR 10 million 

One of the most significant changes concerns procurements worth over EUR 10 million (excl. VAT). Before initiating the procurement procedure, the contracting authority will be required to either conduct a market study or assess the suitability of the chosen procurement model. Previously, market studies and assessments of procurement models were voluntary and used only occasionally. Under the new rules, contracting authorities must document that they have carried out at least one of these measures before commencing the procurement procedure.​​

A market study or preliminary market consultation means that the contracting authority systematically gathers information on the market before carrying out the procurement. This may take the form of meetings, questionnaires, webinars or written requests for information addressed to potential suppliers. The aim is to help the contracting authority understand what is available on the market, what kinds of solutions exist and how to formulate the requirements to achieve the best possible competition.​​

Splitting contracts into lots: new rules for EU-threshold procurements 

Alongside market studies, the reform introduces new requirements for how procurements are structured. As a general rule, contracting authorities must divide contracts exceeding the EU thresholds into appropriate lots. An authority that chooses not to divide a contract must actively give reasons for that decision. Valid reasons, including the risks that division itself can create, may justify departing from this rule. The obligation also does not apply to procurements made under framework agreements..

This change enters into force on 1.10.2026, so authorities should prepare reasoning templates and assessment models now. The underlying objective of the amendment is to facilitate the participation of small and medium-sized enterprises (SMEs) in large procurements. This also means that companies specialised in narrow fields stand a better chance of winning parts of large contracts without having to manage the entire scope.​​ By enabling broader participation by SMEs, contracting authorities can diversify their supplier base, reduce their dependence on large individual suppliers, and potentially achieve greater value over the life cycle of contracts.

The obligation to re-tender when only one tender is received 

If a contracting authority receives only one tender in an open procedure for a contract above the EU thresholds, the procurement must, as a rule, be cancelled and re-tendered. The obligation enters into force on 1 October 2026. However, the obligation to re-tender will not apply if the contracting authority has carried out a market study or if the contract has been divided into lots.​

The obligation may also be waived for particularly weighty reasons, for example where the subject-matter of the contract is exceptionally complex or where there is only a very limited number of suitable suppliers on the market. The contracting authority will be required to organise a new tender procedure only once.​

From a European perspective, the obligation to re-tender in situations where only one tender is received is relatively rare and stems from the risks arising when only one supplier submits a tender. The requirement is intended to ensure that genuine competition is achieved in public procurement. For contracting authorities, this may mean longer timelines and, to some extent, additional work.​

The 10 percent rule for in-house procurements

The new Act also tightens the conditions under which a company can be regarded as an in-house entity. From now on, a contracting authority must hold at least 10 percent of an in-house entity in corporate form in order to award contracts to it directly, without competitive tendering. According to the Ministry of Economic Affairs and Employment, the aim is to increase fair competition and to prevent ownership from being fragmented into very small holdings. Under the current rules, some in-house entities have ended up with dozens of public-sector owners, each holding a minimal stake — allowing authorities to bypass tendering despite exercising no real control over the entity. The new threshold is intended to close that gap.

The change enters into force on 1 July 2027, and existing in-house entities may be used during the transitional period until 30 June 2027. The reform opens significant opportunities for suppliers, as many procurements previously carried out in-house will come to the market for competitive tendering. The most substantial changes will be seen in catering, cleaning and facility management services, and in ICT services. At the same time, municipalities consider that they stand to lose volume benefits and expertise, which is creating tension.

Preparing for the changes 2026-2027 

For contracting authorities, the most consequential review concerns in-house entities: each holding needs to be measured against the 10 percent threshold, and where ownership falls below it, the authority has to decide whether to increase its stake before the transitional period ends on 30 June 2027 or to plan for an exit and bring the relevant services to the market. Market studies, in turn, can no longer be an afterthought — for procurements above the relevant thresholds they need to be built into the annual planning cycle and the timetables for upcoming contracts. That also means a change in posture: rather than publishing a contract notice and waiting, authorities will need to engage potential tenderers early enough to attract a sufficient field, since the single-tender rule turns a thin response into a procedural problem. And where a procurement above the EU thresholds is not divided into lots, the reasoning has to be recorded as part of the publication decision, not reconstructed afterwards if the matter is later questioned.

The changes underline that, in procurement law, procedure matters as much as outcome. In practice, the planning of the tender procedure can already determine whether competition emerges or whether the procurement has to be run again. On small and specialised markets in particular, such as Ostrobothnia and Åland, the reform may affect the competitive landscape more strongly than elsewhere.

Updated 22.6.2026.