10 September 2026
Executive Summary
The European Commission has proposed a major overhaul of EU public-procurement rules that could materially change access to approximately €2.5 trillion of annual public-sector purchasing.
The proposed Public Procurement Act would replace three existing EU procurement directives with a single regulatory framework.
The Commission says the reforms are intended to:
- Simplify procurement.
- Increase digitalisation.
- Improve supply-chain resilience.
- Strengthen cybersecurity considerations.
- Reduce strategic dependencies.
- Increase support for European industry.
The proposed rules stop short of imposing a universal “Buy European” requirement.
However, public authorities would gain powers in certain circumstances to favour European suppliers or exclude bids where less than 50% of the contract value represents European content.
Countries with reciprocal public-procurement agreements with the EU would receive different treatment.
The proposal still requires legislative approval.
Businesses should therefore treat this as an emerging procurement risk rather than a rule already in force.
UK Impact
The proposal has particular significance for UK companies bidding for European public contracts following Brexit.
Affected sectors could include:
- Infrastructure.
- Technology.
- Healthcare.
- Transport.
- Construction.
- Energy.
- Professional services.
- Cybersecurity.
- Engineering.
The central issue is not necessarily nationality.
It is the origin of economic value within the bid.
A UK-headquartered company might use European manufacturing and suppliers and therefore perform differently under proposed content criteria from another UK bidder whose supply chain is largely outside Europe.
Companies should therefore begin understanding European content throughout their bids.
Global Impact
Public procurement accounts for approximately 15% of EU GDP.
Changing the rules governing that expenditure could significantly influence international supply chains.
Businesses may respond by:
- Moving production into Europe.
- Increasing EU sourcing.
- Forming European joint ventures.
- Changing subcontractors.
- Restructuring bids.
- Increasing local inventory.
- Changing technology suppliers.
Procurement policy can therefore become industrial policy.
The proposed rules also explicitly encourage contracting authorities to consider:
- Critical-infrastructure risk.
- Cybersecurity.
- Foreign influence.
- Strategic dependencies.
- Supply-chain resilience.
That means lowest price alone may become less decisive in strategically sensitive contracts.
Our View
Businesses involved in EU public-sector procurement should begin mapping European content before the legislation is finalised.
Companies should ask:
- What proportion of contract value originates in the EU?
- Where are products manufactured?
- Where is software developed?
- Which subcontractors are European?
- Are critical components imported?
- Could suppliers be substituted?
- Would changing suppliers affect quality?
- Would localisation increase cost?
- Could joint ventures improve eligibility?
- Are tender documents beginning to include resilience criteria?
- Are cybersecurity requirements increasing?
- Is critical infrastructure involved?
- Does the customer’s country have reciprocal procurement arrangements?
- Could future tenders exclude non-European content?
- How long would restructuring the supply chain take?
The important risk-management opportunity is timing.
Businesses that wait until a tender actually contains European-content restrictions may discover that their supply chain cannot be restructured quickly enough to qualify.
Risk Indicator: HIGH – EU PROCUREMENT, TRADE & SUPPLY-CHAIN ACCESS
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The information contained within these Market Alerts is provided for general market awareness and informational purposes only. It does not constitute financial, legal, investment, regulatory or insurance advice. Whilst every effort has been made to ensure accuracy at the time of publication using multiple reputable and independently verified sources, geopolitical events, legislation, regulation and market conditions may change rapidly. Readers should obtain appropriate professional advice before acting upon any information contained herein.
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