I had the pleasure of working with ICLEI Europe to submit evidence to the European Commission Evaluation of the Public Procurement Directives. Focusing on the strategic/sustainability aspects (SPP), we reflected on progress to date and put forward recommendations to:

1. Engage more closely with those directly involved in public procurement as part of the legislative process. This could involve structured pilots and regulatory sandboxes to test the impact of any proposed measures, before rolling them out across Europe’s 250,000+ contracting authorities.

• Clarify language and concepts which make SPP more complicated, for example MEAT/BPQR, the link to the subject-matter and the rules on life-cycle costing and ecolabels. The effectiveness of Article 18.2, especially as it applies to subcontractors, also needs to be addressed.

• Include explicit reference to EU legislation creating sectoral SPP obligations (e.g. Energy Performance of Buildings, Energy Efficiency Directive, CSDDD) in the Procurement Directives, and consider whether enforcement of the obligations in sectoral legislation should be brought within the scope of the Remedies Directives to enhance their effectiveness. Strengthen the conditionality provisions in EU funds to promote consistent application of SPP criteria. Ensure emerging EU policy in relation to clean industry and sustainable food is fully reflected in the Procurement Directives.

• Evaluate targeted mandatory SPP measures in relation to defence and infrastructure procurement and other areas of high impact/spend. We outline a proposed approach to evaluating such measures, which recognises that one size does not fit all and learns from on-the-ground experience of implementing SPP.

• Ensure all SPP measures are accompanied by clear monitoring and reporting mechanisms, where possible capturing impact as well as application. The absence of systematic data collection on SPP hinders evidence-based policymaking. The Commission should establish (or pilot) better EU-wide reporting mechanisms for SPP, drawing upon best practice in monitoring SPP at local, regional and national level. This should also leverage existing e-procurement tools and AI-driven analytics and feed into the #Public Procurement Data Space.

I invite you to read the full submission here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14427-Public-procurement-directives-evaluation/F3524855_en

I presented some of these ideas at the Big Buyers Working Together meeting in Helsinki in March 2025.