SPZP submitted its comments in the European Commission’s consultation on the revision of EU public procurement rules
On Monday, the European Commission closed its consultation on the planned revision of the public procurement directives. The Public Procurement Law Association (SPZP) submitted its position, alongside 742 other stakeholders across the EU.
SPZP’s submission sets out key recommendations, including:
- strengthening the principle of proportionality and recognising it as an independent basis for judicial review,
- replacing the fragmented optional exclusion grounds with a single, substantive criterion,
- introducing an EU‑wide mechanism for recognising serious violations established in third countries,
- centralising and harmonising the assessment of self‑cleaning measures,
- maintaining the separation of the Classical and Utilities Procurement Directives,
- applying EU content requirements proportionally and contextually,
- ensuring the right to effective remedies for non‑GPA contractors.
The submission was rated very highly by the EU Consultation Tracker tool in terms of scope, usefulness and clarity. The assessment noted:
“This is a top-tier submission. Its value lies in its practitioner-led, legally specific proposals that go beyond general complaints. Unlike many submissions that vaguely ask for 'simplification', this one proposes concrete mechanisms to achieve it (e.g., strengthening proportionality, consolidating exclusion grounds). The proposals are directly usable for drafting and impact assessment work, making this significantly more valuable than broader, less specific feedback. It is comparable in quality and actionability to submissions from national competition authorities or highly specialized legal bodies.”
The automatic analysis ranked SPZP’s position among the top 9 submissions out of 743.
The SPZP submission is available on the European Commision's website or in the EU Consultation Tracker.