The Croatian Employers’ Association warns that the proposed amendments to the Public Procurement Act, which suggest the obligation to publish all procurements above 15,000 euros, represent a serious potential harm to the domestic economy and a significant administrative and financial burden.
This change would also be one of the strictest rules in the entire European Union. While the EU prescribes thresholds of 221,000 euros for goods and services and over 5 million euros for works, Croatia would become an exception with rules nearly ten times stricter than European practice. Instead of greater trust and transparency, these amendments would achieve the opposite effect, namely an increase in bureaucracy, a slowdown of the system, and additional costs, especially for small and medium-sized enterprises. On an annual basis, according to currently available data, contracting authorities have conducted over 69,200 simple procurements, of which over 13,270 procurements had a value exceeding 15,000 euros.
Examples from other EU member states show that thresholds for simple procurements are set significantly higher. In Slovenia, the threshold is up to 40,000 EUR for goods and services, and even up to 80,000 euros for works, while in Austria it is as high as 143,000 euros. The fact that a significant number of EU member states have thresholds at least double or triple that of 15 euros clearly shows that the proposed solution in Croatia cannot be considered aligned with the best EU practices. The introduction of a public publication obligation for all simple procurement procedures valued above 15,000 euros not only undermines the principle of proportionality but also places Croatian contracting authorities and suppliers in a subordinate position compared to their colleagues in the rest of the EU.
Croatia already has one of the most transparent public procurement systems in the EU, so there is no justification for additional administrative burdens. At the same time, transparency and accountability can be strengthened in a much more effective way: through digital tools for e-procurement, through open contract registers, and through audit and oversight mechanisms that sample check risks in smaller procurements. The introduction of a threshold of 15,000 euros would mean that schools, hospitals, and other public institutions would have to conduct lengthy formal procedures instead of quickly procuring basic supplies. This would slow down the delivery of services and goods, increase costs, and create space for the emergence of unfair competition with low-quality offers.
Public procurement in Croatia accounts for almost 13 percent of GDP and is crucial for the functioning of the economy, while the value of contracts concluded through simple procurement represents only 14% of all concluded contracts. If such low thresholds are imposed as an obligation, this significant segment of the economy will face slowdowns and additional costs.
The Croatian Employers’ Association warns that the proposed amendments to the Public Procurement Act still do not address the key issue of unfair competition from companies in third countries. Although the law provides for the violation of collective agreements as a reason for excluding bidders, it is necessary to apply this provision more clearly and effectively in practice. It is essential to ensure that only companies that respect collective agreements, employ workers properly, transparently pay wages, invest in technological development, and duly fulfill obligations to the state can compete for public procurement jobs. All these criteria should be clearly incorporated into the amendments to the law.
