Electronic Submission of Bids in Public Procurement 2026
Electronic submission of bids: obligation to submit bids digitally in public procurement. Overview of requirements, signatures, deadlines, and platforms.
Definition: Electronic submission of bids is the mandatory digital submission of bids, requests to participate, and other declarations in public procurement procedures via authorised e-procurement platforms while maintaining the confidentiality, integrity, and authenticity of the transmitted data.
Last updated: January 2026 · Legal basis: Directive 2014/24/EU Art. 22, BVergG 2018 §§ 83–89, VgV § 11, UVgO § 38
What is electronic submission of bids?
Electronic submission of bids has been mandatory above the EU thresholds across the EU since 2018 and has completely replaced paper-based bid submission. Art. 22 of Directive 2014/24/EU obliges all public contracting authorities to use means of communication that are non-discriminatory, generally available, and interoperable with commonly used ICT products. This includes electronic submission of bids as a core duty.
The digitisation of bid submission serves several purposes: it increases transparency, reduces sources of error in the physical transport of bids, enables automated time stamping, and simplifies documentation of the procurement procedure.
Legal foundations
Austria (BVergG 2018)
In Austria, §§ 83–89 BVergG 2018 govern electronic submission of bids. Bids above the EU thresholds must be submitted electronically; the contracting authority must provide or designate a suitable electronic platform. The confidentiality of bids up to the opening date must be technically ensured.
Germany (VgV, VOB/A)
In Germany, § 11 VgV enshrines the duty for electronic communication above the EU thresholds. § 11 VOB/A EU applies correspondingly to construction works. The UVgO (§ 38) recommends electronic submission of bids also below the EU thresholds but does not make it mandatory.
Technical requirements
E-procurement platforms for electronic submission of bids must meet specific technical and security-related requirements.
Key requirements:
- Confidentiality: The contents of submitted bids must only be accessible after the bid submission deadline has expired; no person may obtain knowledge of the bid contents before the opening date.
- Integrity: Tampering with submitted bids must be technically ruled out or detectable.
- Authenticity: The identity of the submitting company must be verifiable (electronic signature).
- Time stamp: The exact time of submission must be logged.
- Accessibility: The platform must be accessible to all bidders without discrimination.
Electronic signature for bid submission
The requirements for the signature level for electronic bid submission vary depending on national law and the contracting authority.
In practice, the following are frequently required:
- Advanced electronic signature (AES): Sufficient for most bids and declarations
- Qualified electronic signature (QES): For declarations subject to formal requirements or when expressly required by the contracting authority
The specific signature requirement must be explicitly stated by the contracting authority in the procurement documents.
Bid submission deadlines
The same deadlines apply for electronic bid submission as for paper-based submission; technical problems on the bidder's side do not, in principle, exempt them from meeting the deadline. Bidders should therefore not submit bids up to the last minute in order to avoid technical problems (e.g. slow upload speed, system overload).
Some platforms offer automatic bid receipt confirmations; these document the time of submission and can serve as evidence in case of dispute.
Exceptions to the duty for electronic submission of bids
Art. 22(1) third subparagraph of Directive 2014/24/EU allows paper-based submission in narrow exceptional cases.
Exceptions are permitted, among others, where:
- Specialised office equipment is required for displaying the bid
- Information cannot be transmitted electronically due to its physical nature (e.g. samples, models)
- The security of communication requires particularly high-grade protection measures that are not generally available
Platforms in Austria and Germany
Bidders must register on the platforms designated by the contracting authority and submit their bids there.
Widely used platforms in practice:
- Austria: Vergabe.at, BBG procurement portal, ANKÖ
- Germany: DTVP, subreport ELViS, eVergabe.de, Deutsche eVergabe, vergabe.de, federal-state-specific portals
Related terms
FAQ
What happens if a bidder submits their bid after the deadline has expired? Late-submitted bids must be mandatorily excluded, regardless of whether the delay is attributable to technical problems on the bidder's side or on the platform's side.
Does a bidder have to register on multiple platforms? Yes, if different contracting authorities use different platforms. There is no single mandatory platform for all of Austria or Germany.
Is an electronically submitted copy of a document sufficient? This depends on the contracting authority's requirements. Original documents requiring a handwritten signature must as a rule be submitted as qualified electronically signed files.
Last updated: January 2026 All information provided without guarantee. For legally binding advice, please consult a law firm specialising in public procurement law.
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