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Initiating a Review Procedure

When and how to initiate a review before the procurement chamber – deadlines, process, and costs.

Steps Overview

  1. 1

    Identify Procurement Violation

    Identify whether a procurement violation has occurred that justifies a review.

  2. 2

    Object to the Authority

    Object to the violation promptly with the authority – this is a prerequisite for the review application.

  3. 3

    Observe Objection Deadlines

    Observe strict deadlines: 10 days after recognizing the violation, 15 days after information letter.

  4. 4

    File Review Application

    File the application with the competent procurement chamber with all required justifications.

  5. 5

    Follow the Procedure

    Follow the procedure before the procurement chamber – oral hearing, submissions, and evidence.

  6. 6

    Implement the Decision

    Implement the procurement chamber decision or consider an immediate appeal to the higher court.

Initiating a Review Procedure

The review procedure (Nachprüfungsverfahren) is the central legal remedy for bidders in EU-wide procurements. If you believe the contracting authority violated procurement law, you can request a review by the procurement chamber.

Prerequisites

The contract value must be above EU thresholds, a procurement violation must exist, you must have suffered or face potential damage, and you must have objected (rüge) in time.

The Objection (Rüge)

Before filing a review, you must object to the authority. Strict deadlines apply: violations recognizable from the notice or documents must be objected to before the bid deadline. Other violations within 10 calendar days of discovery. After the advance information letter: 15 calendar days. Missing deadlines makes the review inadmissible.

Common Violations

  • Excessive eligibility criteria
  • Incorrect evaluation
  • Unlawful bid exclusion
  • Wrong procedure choice
  • Unauthorized negotiations
  • Violation of information duties

The Review Process

File with the competent procurement chamber. The authority receives a standstill obligation. Oral hearing usually 3-5 weeks after filing. Decision within 5 weeks. Fees range from 2,500-50,000 EUR.

Appeal

Immediate appeal to the Higher Regional Court (OLG) within 2 weeks of the decision.

The review procedure is effective but requires fast action and specialized legal expertise. Consult a procurement lawyer early.

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