Below the EU thresholds: what 73,000 smaller Polish supply contracts show

TED shows the larger public contracts in Europe. In Poland, a second record sits underneath it: the Biuletyn Zamówień Publicznych (BZP), the national bulletin where buyers publish the contracts too small for TED but large enough for the Public Procurement Law. We read a year of its supply award notices. Here is what the law says, what a notice contains, where the numbers need care, and what the record shows about who sells to Polish public buyers.

Putting it simply: a Polish public buyer must follow the Public Procurement Law for a contract with an estimated value of PLN 170,000 or more, net of VAT. Up to the EU thresholds, it runs a national procedure and publishes the notices in the BZP; TED is optional. In our analysis of 12 months of BZP supply awards, nearly half of the contracts with a reported number of offers drew a single offer, the median contract was about PLN 54,000 gross, and roughly half of the winning companies had no TED supply award in our data since November 2023.

What "below the EU thresholds" means in Poland

The Public Procurement Law of 11 September 2019 (Prawo zamówień publicznych, Pzp) applies to classic contracts of public contracting authorities worth PLN 170,000 or more (art. 2(1)(1)). The value is the buyer's estimate of the total remuneration "without VAT" (art. 28). The threshold was PLN 130,000 until the end of 2025; an amending act of 25 July 2025 raised it from 1 January 2026, and procedures started before that date continue under the old rules (art. 7 of that act). Below PLN 170,000 the Act does not apply, so those purchases do not have to appear in the BZP.

At the top end sit the EU thresholds. Commission Delegated Regulation (EU) 2025/2152 sets them for 2026 and 2027 at EUR 140,000 for supplies and services bought by central government authorities and EUR 216,000 for other contracting authorities (in 2024 and 2025 they were EUR 143,000 and EUR 221,000, under Delegated Regulation (EU) 2023/2495). The President of the Public Procurement Office (UZP) has announced their złoty equivalents for 2026–2027: PLN 603,400 and PLN 930,960, at a rate of 4.31.

Between the two, the rules are in Division III of the Pzp, "procedure for awarding a classic contract with a value below the EU thresholds", from art. 266. The usual route is the basic procedure (tryb podstawowy, art. 275): any interested company may submit an offer in response to the notice, and the buyer either picks the best offer without negotiation, may negotiate if it said so in advance, or must negotiate and then ask for final offers. The procedure starts with a contract notice in the BZP (art. 276). In defined cases the Act also allows negotiation without a notice (art. 301) and a single-source award (art. 305).

Two details explain what the data looks like. First, the threshold applies to the whole purchase: for supplies, the value is the total of similar supplies, even where the buyer splits them into lots or runs a separate procedure for each part (art. 30(2)). A procedure above PLN 170,000 can therefore be made of lots worth far less. Second, sectoral contracts of utilities fall under the Act only from the EU thresholds (art. 2(1)(2)), so their smaller purchases are not in the BZP at all.

Where the notices are published

The BZP is published on the UZP's internet portal (art. 267(1)). Since 1 January 2021 it has been a module of the e-Zamówienia platform, at ezamowienia.gov.pl. Buyers file their notices on its electronic forms (art. 269(1)). A buyer may also send a notice to TED, but only after it has appeared in the BZP (art. 270(2)–(3)). The Act lists nine notice types, including the contract notice, the notice of the result of the procedure, the notice of a contract change and the notice of contract performance (art. 267(2)).

The result notice (ogłoszenie o wyniku postępowania) is the one that names the winner. The buyer must publish it within 30 days of the end of the procedure, whether the contract was awarded or the procedure was cancelled (art. 309(1)).

What a BZP result notice contains

The content is fixed by a regulation of 23 December 2020 on BZP notices, annex 3. Beyond the buyer and the subject (with the main CPV code), three sections matter to anyone studying a market. The offers and winner sections are given as many times as needed, in practice once per lot:

• Offers (section 6): the number of offers received; how many came from micro, small and medium-sized enterprises; how many from companies based in another EEA country and how many from outside the EEA; the number rejected; the lowest and the highest price among offers not rejected; and the price of the winning offer.
• The winner (section 7): whether the contract went to a consortium; the winner's size class; its name and address; and, if it runs a business, its national number (REGON or NIP for Polish companies).
• The contract (section 8): the date it was signed; its period; and its value, defined as "the total price given in the offer, or the maximum nominal value of the commitment where the offer gave a unit price or unit prices".

That is enough to see who wins, for which buyers, against how many rivals and at what price.

Where the numbers need care

Prices are gross. The threshold and the estimated value are net of VAT (art. 28). The contract value is a price, and "price" in the Pzp has the meaning given by the prices act (art. 7(1)), which says that VAT is included in the price (art. 3(2)). BZP contract values are therefore gross, while the threshold is net. VAT rates differ by product, so there is no single factor to convert them.

Some values are ceilings. Where the winner quoted unit prices, the published value is the maximum the buyer may spend, not what it will spend. The same applies to framework agreements, as on TED (why a framework value is a ceiling, not a price).

Some details may be withheld. A buyer may leave information out of the result notice where publishing it would hinder law enforcement, run against the public interest, harm a company's legitimate commercial interests or affect fair competition (art. 309(2)).

Sole traders appear by name. Under the Polish Civil Code, the business name of a natural person is that person's name and surname (art. 43⁴). A sole trader who wins a contract therefore appears in the BZP under a personal name, which is personal data; the Pzp itself says that the GDPR rights of access and rectification over personal data in the BZP are exercised by a request to the buyer (art. 269(2)). We do not show sole traders, and we leave out civil partnerships (spółki cywilne) too. The figures below cover companies only.

What a year of BZP supply awards shows

The figures come from a Cresques analysis of Poland's BZP contract award notices for supplies published from 24 October 2025 to 31 October 2026, imported from the e-Zamówienia platform. Sole traders and civil partnerships are excluded, and values are as published, gross, in PLN. Because the period starts in late 2025, it includes procedures run under both the PLN 130,000 and the PLN 170,000 national threshold.

• 53,725 award notices, covering 73,553 contracts (lots) with a published winner, won by 6,871 distinct companies.
• 46.6% of the contracts with a reported number of offers received a single offer. The average was 2.25 offers. The figure covers every contract where the buyer reported offers; we have not split it by procedure type, so it can include negotiated and single-source awards where only one company may have been asked.
• The median contract value was PLN 54,289 (gross, as published). Half of the contracts were worth less.
• Categories. Counting each notice under the CPV division of its main code (CPV divisions explained):

• About half of the winners are not in TED supply awards. Of the 6,871 companies, 3,276 (48%) also won at least one supply award on TED in our data since November 2023. The other half did not appear among TED supply winners in that period, in our data.

What this means for a manufacturer

Smaller contracts, many buyers. The median contract is modest, and a procedure can be split into lots. The buyers are public bodies such as hospitals, municipalities, schools and agencies, each buying for its own needs. The companies that win their contracts already deliver to them.

Many contracts see little competition. Almost half of the contracts with a reported count drew one offer. That can mean a narrow specification, a small market or a supplier the buyer already knows. For a new manufacturer it cuts both ways: a well-prepared distributor has room to win, but an incumbent may already have the relationship. The notice also counts offers from companies based in other EEA countries and outside the EEA, so you can see how open a category has been to foreign bidders. Procedures run in Polish; other languages are accepted only in justified cases (Pzp, art. 20), one more reason to work through a Polish partner.

Many winners never show up on TED. Roughly half of the companies that won a below-threshold supply contract had no TED supply award in our data. A partner list built from TED alone would miss them. We have not classified these companies in this analysis: whether each one is an independent distributor, a manufacturer or a manufacturer's own subsidiary needs checking company by company.

Medical, transport, food and furniture lead. If your range sits in division 33, 34, 15 or 39, there is a deep record of smaller awards to study by buyer and region; see our medical supplies and furniture pages. Fuel and energy (09) are large by count too; check whether the winners there could carry your range at all.

How to use the record. Read the result notices for your categories, note the companies that win repeatedly and for whom, and check their registration numbers. Then make the first contact the lawful way: in Poland, a commercial e-mail needs the recipient's prior consent (art. 398 PKE), so open with a letter, a trade fair or an introduction (selling into Poland through distributors, entering Poland through distributors). A contract award is evidence, not a guarantee; what an award tells you about a distributor covers what to check next.

How Cresques shows it

For Poland, Cresques reads the BZP result notices for supplies from the last 12 months, companies only, and shows the same evidence as for TED: who won, for which buyer, for how much and when, with gross values labelled as such. Every plan sees how many smaller contracts there are in a Polish market; the Growth plan includes the full picture for one market and Scale for three (pricing, what you get). Below-threshold data for other countries is not available today.