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American Chamber of Commerce in Croatia
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Comments on the Bylaw on the Procurement Plan, Register of Contracts, Prior Consultation and Market Analysis in Public Procurement

Comments on the Bylaw on the Procurement Plan, Register of Contracts, Prior Consultation and Market Analysis in Public Procurement

AmCham raised comments on the Ordinance on Procurement Plans, Contract Registers, Preliminary Consultations, and Market Analysis in Public Procurement.

The main concerns are:

  • Procurement Plan (Art. 2): mandatory CPV codes, even for simple procurement, unnecessarily complicate procedures; the phrase “if known” for estimated value allows room for misuse; unclear link between estimated value and “planned/secured” funds.
  • Market Analysis (Art. 8): provisions are too general, requiring clearer guidelines on permissible practices.
  • Preliminary Consultation (Art. 9): positive step, as mandatory consultations improve transparency and timely information for bidders.

AmCham welcomes the mandatory publication of procurement plans, contract registers, and consultations via EOJN as of 2018 but calls for more precise and practical rules in certain areas.