Remember OJEU? The Official Journal of the European Union — the place UK public contracts used to be advertised before Brexit. It was replaced by Find a Tender Service (FTS) in January 2021. Most UK-only suppliers barely noticed. But three years on, the rules themselves have diverged — not just the portal. If you bid in both the UK and EU, or you're thinking about it, here's what you actually need to know.
The Portal Change: FTS Replaced OJEU
UK above-threshold contracts are now advertised on Find a Tender Service, run by the UK government. EU contracts are advertised on TED — Tenders Electronic Daily, the official EU procurement portal. These are two completely separate systems. There's no cross-search between them. If you want to monitor both markets, you need to monitor both portals.
FTS is at find-tender.service.gov.uk. TED is at ted.europa.eu. Both have search and alert functionality. Both are free. The practical difference for most UK-only suppliers: you already use FTS and you've never needed TED.
The Legislation: Act vs Directives
UK procurement used to be governed by transpositions of EU Directives — PCR 2015 transposed Directive 2014/24/EU, the Utilities Contracts Regulations transposed 2014/25/EU. Post-Brexit, the UK had no obligation to keep those rules in that form. The Procurement Act 2023, which came into force in February 2025, is the first genuinely UK-authored procurement law.
The EU, meanwhile, is in the process of updating its own directives. Both regimes share the same foundational principles — transparency, equal treatment, proportionality, value for money — because both are rooted in WTO GPA obligations. But the specific procedures, thresholds, and rules now differ.
Procedure Differences
The EU still uses the named procedures from the 2014 directives: Open, Restricted, Competitive Dialogue, Competitive Procedure with Negotiation, Innovation Partnership. The UK has replaced most multi-stage routes with the Competitive Flexible Procedure — a more flexible framework that lets contracting authorities design their own process.
In practice, this means the procedure you'll encounter on a UK Competitive Flexible procurement may look quite different from an EU Competitive Dialogue. Read each procurement's specific rules. Don't assume familiarity from one regime transfers to the other.
Thresholds: Similar Numbers, Different Frameworks
Both UK and EU thresholds are ultimately set by WTO GPA negotiations, which is why the numbers are similar but not identical. The UK thresholds (£139,688 for central government goods/services, £214,904 for sub-central) and EU thresholds (approximately €143,000 and €221,000 respectively at current rates) track each other closely. They're updated on the same WTO GPA cycle.
WTO GPA: UK Suppliers Can Still Bid in the EU (In Theory)
Both the UK and EU are members of the WTO Government Procurement Agreement. This means UK suppliers have a legal right to bid on above-threshold EU public contracts, and EU suppliers have the same right in the UK. Brexit didn't remove this entitlement.
Here's the honest answer though: legal access and practical access are different things. Winning an EU public contract as a UK supplier means understanding the local language (many specifications are only published in the national language), navigating unfamiliar rules and procedures, establishing local presence or credibility, and competing against suppliers with established relationships. The right to bid doesn't make bidding competitive.
Practical Note
If you're a UK supplier seriously considering EU bidding, start with TFEU Article 18 — the principle of non-discrimination — and the specific contracting authority's language requirements. Some EU bodies publish notices in English, particularly in Ireland, the Netherlands, and Nordic countries.
Sub-Contracting and Supply Chains
One area where Brexit created genuine complexity is sub-contracting in cross-border supply chains. UK suppliers working as sub-contractors to EU prime contractors on EU public contracts, or vice versa, now need to navigate different regulatory environments. TUPE rules, employment law, and social value requirements differ between the UK and EU. If you're in this position, get specific legal advice — this isn't an area where general procurement knowledge is enough.
What This Means If You're Only Bidding in the UK
If you're a UK-only supplier with no current interest in EU markets, post-Brexit changes very little day-to-day. FTS replaced OJEU. The Procurement Act 2023 replaced PCR 2015. The new rules are better in some areas — more transparency, better pipeline information, clearer debrief requirements. The procedures work differently but the bid-writing fundamentals don't.
- •Monitor FTS for above-threshold UK contracts — don't use OJEU/TED unless you're specifically targeting EU opportunities
- •The Procurement Act 2023 is your governing legislation — not EU directives
- •Your WTO GPA rights to bid in the EU exist but come with significant practical barriers
- •If you're a non-UK EU supplier bidding in the UK, you have the same legal right to bid as UK suppliers — the GPA protects you too
The divergence between UK and EU procurement rules will likely increase over time as the UK exercises more of its legislative freedom and the EU continues to update its own directives. For now, the two systems are more similar than different. The gap will widen.