EU’s draft procurement regulation is bold. Here’s some technical advice to make it work

The European Commission has finally published its draft regulation on public contracts and concessions. After the July leak, we were wondering whether its bold ambition to build the EU’s public procurement system on a real, mandatory data backbone for the first time would survive contact with reality. 

So it’s good news that, in fact, it actually got sharper in some places: 

• Central validation would now be law. At both the national and EU levels, data is checked upon arrival and confirmed back to whoever submitted it.
• The data-transfer window tightened. National data now has to reach the EU-level data space within ten days, down from twenty.
• The European Business Wallet made the cut, named explicitly as the mechanism for supplier credentials.

With the European Council taking on the Regulation, there will be a lot of back-and-forth about what’s actually achievable, technically and politically. 

Technical details like data spaces, validation architecture, and credential tools may not set the heart racing, but they will be critical to the success of delivering a pan-European marketplace that inspires the Regulation. The specific language written into the delegated and implementing acts will, for example, determine whether “once-only” means something real to suppliers or not.

To help guide these conversations, we have developed our best technical recommendations for implementation. We are also proposing ways to clarify or operationalize them in the Regulation and suggesting legal wording and precedents that show what good already looks like elsewhere.  

Here are our headline recommendations: 

1. Validate at the source, not just centrally. The confirmation loop in the current draft only catches errors once data has already left the buyer’s system. Better practice is for e-procurement platforms to catch them before submission through basic checks and validation.
2. Tie data completeness to the contract itself. No complete award data, no standstill clock, no signature, so there is a clear incentive to publish the right information.
3. Design the data publication for the national data spaces around a user-friendly schema not for compliance reporting (clue: Open Contracting Data Standard can help!). Ensure users, including those beyond government and the European Commission, have the most user-friendly and accessible data and information possible for procurement analysis.
4. Give people something back for entering good data. Dashboards and market intelligence are a stronger lever for data quality than penalties or compliance alone.
5. Lock in what the Business Wallet promises. Extend interoperability requirements now so no supplier ever holds two credentials that don’t recognize each other.

We welcome the opportunity to work directly with Member States, the EC, and everyone committed to getting this right. 

How the EC implements its technology vision will transform all its other procurement ambitions, supporting efficient, sustainable, and transparent public spending enabled by a fair and competitive marketplace. It will determine whether this effort will be powered by a living, used data infrastructure or by yet another well-intentioned compliance exercise. 

Photo Credit: European Union, 2026