Government Procurement Requirements – A Practical Guide

Public procurement is not only about getting the best price. It is about being able to document how that price came about. Traceability is not a reporting exercise after the fact — it is something the system either produces continuously, or does not produce at all.

What the rules require

Norway's Public Procurement Act and its regulations set requirements with direct consequences for how a procurement system has to work:

• Verifiability. It must be possible to document afterwards how the procurement was carried out — who ordered what, when, from whom and at what price, stored rather than reconstructed from email
• Equal treatment. Buyers should order on the agreements that were actually competed. A system that lets people order freely off-contract moves the compliance burden onto the individual
• Use of framework agreements. Agreements that went through competition should be used, which assumes the buyer can find them without searching
• Documented authority. Approval must follow set thresholds and be logged, not rest on someone remembering a yes

EHF invoicing is mandatory

Norwegian central government and municipal bodies must receive invoices electronically in EHF format over the PEPPOL network. That applies to their suppliers too: a PDF by email does not meet the requirement.

Electronic ordering is a separate track. More public bodies ask for it in tenders even where it is not yet absolute. The difference between invoice and order is worth understanding before you write the specification — it is set out in EHF or PEPPOL — what is the difference?

DFØ is Norway's PEPPOL Authority and operates ELMA, the registry that determines who can receive what.

When the auditor arrives

The Office of the Auditor General audits central government bodies, municipal audit units the municipalities. The questions tend to be the same, and they are practical:

• Can you show what share of spend went on framework agreements?
• Can you extract every order above a given value, with its approver?
• Can you document that the buyer had authority at the time of ordering?
• Do you know what was bought off-contract — and why?

If the answer is "we would have to search email and spreadsheets", the audit is not the problem. The problem is that the numbers did not exist along the way either.

Checklist before choosing a system

• Is every change logged with timestamp and user, without the buyer doing anything extra?
• Can the approval flow mirror your delegation structure, with different thresholds per department?
• Does the buyer see only suppliers and prices covered by a valid agreement?
• Can you pull a report an auditor can actually read, without ordering it from the vendor?
• Is the system registered in ELMA for the document types you need — catalogue and order, not just invoice?

How Asker municipality solved it

Asker municipality has over 700 end users, most of whom buy alongside their primary duties. Of the previous solution the municipality says nothing was standardised and much of it stalled in the message flow to suppliers. Usability became the deciding criterion, and end users sat on the tender group.

"It has to be easy to order on the municipality's framework agreements. We are not only obliged to use the agreements we have signed — they also save the municipality money."

– Mona Omli Landsrød, procurement adviser, Asker municipality

Official sources

• The Public Procurement Act (LOV-2016-06-17-73) — Lovdata
• anskaffelser.no — DFØ's guidance on public procurement
• DFØ on electronic trade and EHF