Comments on the Bylaw on Procurement Documentation and Bids in Public Procurement

Comments on the Bylaw on Procurement Documentation and Bids in Public Procurement

AmCham submitted comments on the Ordinance on Procurement and Bidding in Public Procurement Procedures.

Bill of Quantities (Art. 5): it is unclear whether contracting authorities may continue using Excel-based forms; AmCham suggests a technical solution in the EOJN RH system to allow flexible expansion of the standardized form (e.g., adding columns) to avoid duplicating standard and non-standard forms.

Submission of Documents (Art. 20): the definition of an “updated document” is vague and creates legal uncertainty (e.g., how old a Tax Administration certificate can be). AmCham proposes setting a clear limit — documents proving no criminal record or outstanding tax debt should not be older than 30 days at the time of submission.