Public procurement in Latvia now bars Russian and Belarusian goods and services

A new Article 2.² of Latvia's Public Procurement Law took effect on 9 June 2026. It requires every company supplying goods or services to the state, a municipality or any other public sector body to ensure that its supply chain contains no goods or services originating in the Russian Federation or the Republic of Belarus. The rule is examined by Katrīne Pļaviņa-Mika, a sworn advocate and lawyer at the law firm Sorainen.

Contracting authorities must apply the requirement in every procurement, regardless of the estimated contract value. The ban is not tied to a sanctions list and also applies to goods and services that fall outside the European Union's sanctions regime. According to the author, the provision stems from a political decision to limit the flow of Latvian state budget funds to countries waging war against Ukraine. Utilities, such as state-owned energy companies and municipal boiler houses, are exempt.

How compliance will be checked

The main tool is a self-declaration by the supplier. The contracting authority may request it when a bid is submitted or at any stage of contract performance. The declaration is legally binding. If it later proves untrue, the authority may impose a contractual penalty, demand compensation for losses and have the supplier excluded from future public procurement.

Latvia's Procurement Monitoring Bureau states that the origin of services from legal entities is determined by country of registration, and for individuals by citizenship. Interpretation questions may still arise. For example, a grounds maintenance or cleaning contract in Latgale cannot use a subcontractor registered in Belarus. Responsibility stays with the bidder even if the link to a Russian or Belarusian product is indirect, such as through a subcontractor or an intermediary.

Relationship with EU law

In a 2024 ruling in case C-652/22 and a 2025 ruling in case C-266/22, the Court of Justice of the European Union stated that the access of third-country operators to EU public procurement is a matter for the EU, not member states. The court also said each contracting authority may freely decide whether to admit third-country persons and set this out in its tender documents. For that reason, the Saeima, Latvia's parliament, signals that the authority itself should include the requirement in procurement documents rather than treat it as a statutory ground for rejecting bids.

What companies should do

The author recommends reviewing the supply chain, including the origin of goods and components, organising origin documentation, and updating contracts with subcontractors so that losses can be recovered if they supply Russian or Belarusian products.