The EU Public Procurement Act, proposed by the European Commission on 9 September 2026, would replace the three directives that have governed European public procurement since 2014 with a single Regulation, and it changes how social value counts in public contracts.
Quality criteria, including social considerations, would carry a guaranteed minimum share of every award decision.
Ireland, whose national procurement strategy for 2026 to 2030 sets its own ambition for social considerations in public contracts, would apply the new rules directly.
This blog explains what we know so far about these two landmark measures.
The EU Public Procurement Act (COM(2026) 590
On 9 September 2026 the European Commission proposed the Public Procurement Act (COM(2026) 590), a single Regulation to replace the three directives that have governed EU public procurement since 2014.
Most media coverage has led with the Buy European provisions, which allow public buyers to favour EU suppliers and goods and which Commissioner Stéphane Séjourné has presented as an answer to the way “China, India, the United States and all the major powers are now using this lever.”
But on top of this high-profile measure, the Act puts forward sweeping changes to the treatment of social impact in public contracts.
What the Act changes for social impact
Quality, not lowest price, becomes the default basis for awarding contracts
Public buyers are, as a rule, to award on the best price-quality ratio, and quality criteria must carry at least 30 per cent of the total points (Article 98). Social considerations are named in the text as quality criteria, alongside environmental, innovation and accessibility considerations. Buyers may also fix the price and have tenderers compete on quality alone.
Labour-intensive contracts carry a 50 per cent quality minimum
Where the cost of labour normally accounts for at least half the contract value (Article 6(10)), which describes most services, construction and facilities work, quality criteria must carry at least 50 per cent of the points. The proposal’s recitals add that for these contracts the 50 per cent should include significant social considerations.
Buyers who move away from the default must say how
A buyer may derogate from the best price-quality ratio and the minimum weightings only by indicating, in the published summary of the competition, how quality is otherwise secured through specifications or contract performance conditions (Article 98(5)).
Social considerations get a dedicated chapter
Articles 55 to 58 list the social objectives procurement can pursue: social inclusion and labour market integration of disabled and disadvantaged people, high quality jobs and better working conditions with explicit acknowledgement of collective bargaining, accessibility, training and reskilling of the workers on the contract, gender equality and non-discrimination, promotion of the social economy and of social and affordable housing, and human rights protection in the relevant supply chains. Buyers can apply these through specifications, award criteria, contract performance conditions or, where relevant, selection criteria.
Meeting existing legal obligations does not count
Compliance with labour and social law, collective agreements or the international conventions annexed to the Regulation is the floor, not the offer. Social considerations qualify only where they go beyond it (Article 55(4)).
Commitments must attach to the contract, not the company
Criteria must be linked to the subject matter of the contract. The link can be direct or indirect, and the text names the working conditions of workers at any stage of the life-cycle, responsible sourcing and supply chain transparency as qualifying examples. The recitals exclude criteria relating to general corporate policy (Article 90). A company-wide programme scores nothing; what the contract’s own workforce and communities receive does.
Accessibility becomes mandatory
For any procurement intended for use by people, buyers must require accessibility for persons with disabilities and take account of design-for-all approaches, except in duly justified cases (Article 56).
Reserved contracts remain
Buyers may reserve contracts, or lots within them, for organisations whose main aim is the social and professional integration of disabled or disadvantaged people, where at least 30 per cent of employees are from those groups, and may reserve certain welfare services for recognised non-profits that reinvest their surpluses (Article 57).
Social outcomes become reportable data
Each Member State must establish a National Public Procurement Data Space feeding a Union-level data space run by the Commission, publication obligations extend across the whole contract life-cycle, and Member States must monitor their procurement systems, including the uptake of strategic procurement, and publish the results at least once a year (Articles 134 to 137).
From Act to Regulation: the long road ahead
The Public Procurement Act is a proposal, not law. It now enters the ordinary legislative procedure, where the European Parliament and the Council can amend any of it, including the weightings above.
As drafted, it would apply two years after entry into force (Article 149), and only above the thresholds it sets: EUR 140,000 for central government supplies and services, EUR 216,000 for sub-central authorities, EUR 5,404,000 for works and concessions, and EUR 750,000 for social, health and educational services (Article 2).
However, the choice of instrument indicates the European Commission’s determination to push reform through consistently. A Regulation, unlike a directive, applies directly in every Member State with no national transposition. Whatever version is adopted will apply in each member state as written.
Combine all of this with the disclosure requirements in the EU Omnibus and the demands of Double Materiality, and we’re looking at a major upheaval in the coming years.
“Procuring For Our Future”: Ireland leads the way
Ireland is not waiting for Brussels. A month after Ireland assumed the Presidency of the Council of the EU in July, the Office of Government Procurement (OGP) published “Procuring for our future”, the country’s first overarching national procurement strategy, covering an estimated EUR 29.5 billion in contracts awarded each year. All public bodies are required to integrate its objectives into their own procurement strategies, and Circular 18/2025 makes value for money, redefined to include societal, economic and environmental outcomes, a duty.
Socially Responsible Public Procurement (SRPP)
The Irish framework for the social dimension is socially responsible public procurement (SRPP), which sits under the umbrella of strategic public procurement alongside green and innovation procurement. The UK Social Value Model and Procurement Policy Notes do not apply in Ireland; the Irish terms are SRPP, social considerations and procuring for impact.
The strategy states the baseline and the ambition plainly. In 2025, 4.6 per cent of published Irish tenders included SRPP. The strategy sets an ambition of 10 per cent of public contracts incorporating social considerations by 2030. The target is voluntary, adopted by public bodies through their Corporate Procurement Plans, and there is no mandatory minimum weighting. A mid-term review in 2028 and a full OGP evaluation in 2029 will decide whether stronger measures are needed.
SRPP Measurement Infrastructure
Around the target, the strategy commits to a measurement infrastructure:
- SRPP uptake monitored through structured eForms data on the eTenders platform, so buyers must record social considerations in a reportable format.
- A feasibility study on a digital SRPP Criteria Search tool by the end of 2026, modelled on the green procurement equivalent that has drawn 72,000 users since 2022.
- A public OGP data analytics website showing tender and spend data from late 2026.
- Corporate Procurement Plans from all departments and their bodies published centrally by Q2 2028.
The social economy features throughout: social enterprise representation on the SME Advisory Group from Q2 2026, annual buyer briefings on procuring from social enterprises, an information note on commissioning from the Community and Voluntary sector by the end of 2027, and Community Wealth Building named as a local SRPP approach.
How the EU Act and Ireland’s Policy interact
- Ireland’s strategy runs to 2030, with a voluntary 10 per cent ambition and reviews in 2028 and 2029. The proposed Regulation, on the Commission’s stated timeline, would begin applying within that same window and would set a binding 30 per cent quality weighting for Irish buyers above threshold, rising to 50 per cent for labour-intensive contracts.
- The two texts also ask for the same thing operationally. Ireland will monitor SRPP through structured eForms data; the proposal routes procurement data through national data spaces into an EU-level one, with strategic procurement uptake monitored and published.
- Under both, social considerations are recorded as structured, reportable data rather than described loosely in a tender narrative. Organisations that can already define, deliver and report social outcomes will meet either framework; the difference between the two is whether doing so is encouraged or required.
Measuring social impact before it is required
However, both texts assume a capability that neither provides: a consistent way to measure and evidence social outcomes.
The EU proposal requires award criteria to be specific, objective and measurable, and ties social criteria to the workers and communities on the contract. The Irish strategy asks buyers to record social considerations in reportable eForms data and to plan them through Corporate Procurement Plans.
Thrive provides that missing scaffolding. The Thrive platform enables organisations to capture, measure and report their social, economic and environmental impact, while the Impact Evaluation Standard provides a framework that makes those results consistent, comparable and auditable.
Neither text names or requires any specific framework or platform to be used, but both point towards measured, evidenced social outcomes, and for Irish suppliers preparing for SRPP questions in tenders, and public bodies preparing Corporate Procurement Plans and eForms returns, the work of building a robust, credible foundation of data is best started before it is compulsory.
If you are procuring for impact in Ireland, or supplying organisations that are, talk to us about what measurement looks like in practice.
Q&A
It is the European Commission’s proposal, published on 9 September 2026 as COM(2026) 590, for a single Regulation on public contracts and concessions. It would replace the three 2014 procurement Directives and apply directly in every EU Member State, covering procedures, award criteria, strategic objectives including social and environmental considerations, and a common digital ecosystem for procurement data.
No. It is a proposal at the start of the EU’s ordinary legislative procedure, and the European Parliament and the Council can amend it. As drafted, it would apply two years after it enters into force, so its rules would not bind buyers before the late 2020s at the earliest.
A dedicated chapter (Articles 55 to 58) lists the social objectives buyers can pursue, including social inclusion, high quality jobs, accessibility, training, gender equality, the social economy and human rights in supply chains. Accessibility requirements are mandatory. Separately, Article 98 makes the best price-quality ratio the default award method, with quality criteria worth at least 30 per cent of points, and at least 50 per cent for labour-intensive contracts.
SRPP is the Irish term for taking social considerations into account in public purchasing. It sits within “strategic public procurement” in Ireland’s National Public Procurement Strategy 2026-2030, alongside green and innovation procurement. It is distinct from the UK’s Social Value Model, which does not apply in Ireland.
The national strategy sets an ambition for 10 per cent of public contracts to incorporate social considerations by 2030, up from 4.6 per cent of published tenders in 2025. The target is voluntary, adopted through public bodies’ Corporate Procurement Plans, with a mid-term review in 2028 and a full evaluation in 2029.
Alan Boyce
Senior Researcher More articles by Alan >
