The Cost of Whining: Public Procurement Appeal Fees Across the EU

Yesterday I posted an SSRN preprint of my forthcoming chapter in the book A Research Agenda for Public Procurement Law, Policy and Regulation (Edward Elgar Publishing) edited by Geo Quinot. A major focus of that chapter is appeal fees, and their (in my opinion) detrimental effect on the accessibility of public procurement remedies and consequently – on procedural transparency.

While writing the chapter, I researched appeal fee amounts across all EU Member States, and created this table. The table did not make it to the final version of the chapter (word count constraints!) so I’m putting it up here. There is a link to the source(s) I used for every Member State.

While I verified much of this data with colleagues in the relevant countries, please let me know if I got anything wrong!

Member StateAmount
AustriaOn the Federal level: 400.00 EUR for procurement valued up to 500,000.00 EUR; 2,000.00 EUR for procurement valued between 500,000.00 and 1,500,000.00 EUR; 5,500.00 EUR for procurement valued between 1,500,000.00 EUR and the Article 12(1)(4) BVergG value; 15,000.00 EUR for procurement valued between the Article 12(1)(4) BVergG value and 15,000,000.00 EUR; 25,000.00 EUR for procurement valued between 15,000,000.00 and 50,000,000.00 EUR; and 50,000.00 EUR for procurement valued above 50,000,000.00 EUR. Statutory reductions of 25, 50 and 80 per cent apply in the cases listed in paragraph 5, and the fee for an application for an interim measure is 100.00 EUR.
Belgium200.00 EUR per applicant per request, twice that amount for suspension and later annulment.
Bulgaria≈435.00 EUR for procurement valued up to ≈522,000.00 EUR, ≈869.00 EUR between ≈522,000.00 EUR and ≈2,556,000.00 EUR, and ≈2,301.00 EUR above that.
Croatia1,320.00 EUR where the estimated value does not exceed 265,440.00 EUR; 0.5 per cent of the estimated value between 265,440.01 and 13,272,000.00 EUR; and fixed at 66,360.00 EUR above that threshold. The same 1,320.00 EUR applies where the estimated value is not known when the appeal is lodged.
CyprusThe fee for registering a recourse with the Tenders Review Authority is set by regulations made under the Law and is tiered by contract value. Amending legislation adopted in 2025 raised the minimum contract value for recourse to the Authority from 500,000.00 EUR to 1,000,000.00 EUR and made interim measures conditional on the appellant undertaking to provide a personal guarantee, the amount of which is fixed by the Authority by reference to the liquidated damages clauses in the contract and corresponding to up to five months’ delay.
CzechiaThe appeal is admissible only on payment of a deposit (kauce) of 1 per cent of the petitioner’s bid price for the contract period (or first four years), subject to a lower limit of ≈2,000.00 EUR and an upper limit of ≈408,000.00 EUR.
Denmark≈2,680.00 EUR where the complaint alleges breach of the EU procurement directives and ≈1,340.00 EUR in other cases; the fee is refunded where the complainant succeeds in whole or in part.
Estonia1,280.00 EUR for procurement procedures below the international threshold and 2,560.00 EUR for those above.
Finland2,440.00 EUR for procurement valued below 1 million EUR; 4,880.00 EUR between 1 and 10 million EUR and 7,300.00 EUR above 10 million EUR. A reduced fee of 500.00 EUR applies where the case is dismissed without a decision on the merits, and private individuals pay 610.00 EUR.
FranceNo special public procurement appeal fee.
GermanyAt Federal level a cost-based charge is applied – at least 2,500.00 EUR, reducible on equity grounds to one tenth of that amount, and usually not more than 50,000.00 EUR, although it may be raised in an individual case to 100,000.00 EUR where the economic significance of the procedure is exceptionally high. Half the fee is payable where the application is withdrawn before decision.
Greece0.5 per cent of the estimated contract value excluding VAT, with a floor of 600.00 EUR and a limit of 15,000.00 EUR; subsequent suspension petitions before the administrative courts require a further fee of 0.5 per cent of value, with a floor of 1,500.00 EUR and a limit of 30,000.00 EUR.
Hungary0.5 per cent of the estimated value of the procurement, with a floor of ≈760.00 EUR and a limit of ≈44,300.00 EUR for EU-threshold procurements and ≈12,700.00 EUR below the threshold; the base amount is multiplied according to the number of elements challenged, and reduced where only the notice or the tender documents are contested.
IrelandNo special public procurement appeal fee.
Italy2,000.00 EUR where the value of the dispute is equal to or below 200,000.00 EUR; 4,000.00 EUR between 200,000.00 and 1,000,000.00 EUR and 6,000.00 EUR above 1,000,000.00 EUR. The contribution is increased by half on appeal, and is 6,000.00 EUR where the declaration of value is omitted.
LatviaSecurity deposit (drošības nauda) of 0.5 per cent of the estimated contract value, limited at 840.00 EUR for supplies and services and 15,000.00 EUR for works (with fixed amounts – 840.00 EUR and 3,400.00 EUR respectively – where the price cannot be determined). (The Official Translation of the Latvian Public Procurement Act linked here does not contain the May 2025 amendments – but those amendments did not contain provisions affecting the appeal fees.)
LithuaniaBefore announcement of the winning bid, 300.00 EUR for small-value procurements, 1,000.00 EUR for simplified procurements, 3,000.00 EUR for international-threshold procurements and 10,000.00 EUR for procurements connected with strategic projects. After announcement of the winner, 350.00 EUR, 2,000.00 EUR, 5,000.00 EUR and 15,000.00 EUR respectively. Electronic filing attracts a 25 per cent discount. These amounts are indexed where the quarterly consumer price index exceeds 110, so the sums actually payable exceed the nominal figures.
LuxembourgNo special public procurement appeal fee.
Malta0.5 per cent of the estimated contract value, subject to a floor of 400.00 EUR and in all cases a limit of 50,000.00 EUR; the deposit ”may be refunded as the Public Contracts Review Board may decide in its decision”, making refund discretionary.
NetherlandsNo special public procurement appeal fee.
Poland≈1,750.00 EUR for supplies and services below the EU thresholds and ≈3,500.00 EUR above them; ≈2,330.00 EUR and ≈4,650.00 EUR respectively for works. These amounts have been unchanged since 2010. A draft amending Act published on 2 June 2026 would raise fees significantly.
PortugalNo special public procurement appeal fee.
RomaniaRomania has selective jurisdiction: an (administrative) appeal before the National Council for Solving Complaints (CNSC) or a judicial action. If an economic operator chooses CNSC, there is a refundable security (cauțiune) of 2 per cent of the estimated value of the contract, or of the value of the winning bid at the post-award stage, capped by stage and threshold at ≈6,930.00 EUR and ≈17,420.00 EUR for below-threshold contracts and ≈43,560.00 EUR and ≈174,260.00 EUR for above-threshold contracts. Where the judicial route is selected, the duty is 2 per cent of estimated value with a limit of (incredible) ≈19 million EUR.
SlovakiaAdmissibility is conditional on a deposit (kaucia) calculated as 0.1 per cent of the estimated value of the contract or concession, but not less than 2,000.00 EUR and the limit is set at 50,000.00 EUR; 2,000.00 EUR is payable where the estimated value is not published or cannot be determined.
Slovenia2,000.00 EUR where the appeal challenges the tender documentation in small-value or simplified procedures and 4,000.00 EUR in open and comparable procedures; where the appeal challenges an award or exclusion decision, the fee is 2 per cent of the price of the selected bid (including VAT), with a floor of 500.00 EUR and limit of 25,000.00 EUR, and fixed amounts apply in special cases (1,000.00 EUR for terminations; 6,000.00 EUR for framework-agreement awards).
SpainNo special public procurement appeal fee.
SwedenNo special public procurement appeal fee.

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