When we analyse a specific public tender for a client, we don’t rely on reading the documentation alone. We also check the bid against a catalogue of real exclusion grounds — the 50 most common reasons evaluation committees in Bulgaria throw bids out. This article is that catalogue, brought into the open — because these reasons are predictable, and the predictable is preventable.
It was built from 5,679 real exclusion grounds across 59 active firms. From them we distilled the most frequent, clearly-defined patterns — the recurring reasons behind the bulk of preventable losses. These aren’t anecdotes: each one is written in black and white in a committee report. Company names are removed on purpose — what matters is the reason, not who tripped on it.
What the catalogue shows
Group the grounds into their large families and the pattern is the same one we see in every analysis: bids rarely fall on price. They fall on form and compliance.
Look at the bottom: price is under one tenth — and even there it’s almost always a rejected justification under Art. 72, not the fact that you were expensive. A document sinks the bid even when price is the trigger.
Top 15 specific grounds, by frequency
Most often, committees write the general Art. 107 ground — “the bid does not meet the pre-announced conditions” (on its own about a third of all cases). In practice it almost always resolves to one of the specific gaps below. Here are the fifteen most frequent specific grounds across the 5,679 cases. Remember: not one of them requires a better price, higher quality or connections.
Count across 5,679 grounds at 59 firms. Each ground is classified by its leading cause.
- 1 Missing/incomplete description of performance (programme, strategy, methodology) 335 · 5.9%
The work programme or strategy fails to cover the required minimum content — a missing activity, measure or technological sequence.
- 2 ESPD — unfilled, unsigned or irregular 295 · 5.2%
Empty national databases, a missing signature, the wrong or incomplete version of the form.
- 3 Price non-compliance or incompleteness (general) 293 · 5.2%
Gaps or discrepancies in the price section beyond the classic Art. 72 justification.
- 4 Non-compliance with the technical specification 291 · 5.1%
The proposal does not literally match the spec — a missing parameter, a lower class, an unmet capacity.
- 5 Technical proposal below the minimum requirements 201 · 3.5%
The technical part falls under the announced minimum on at least one metric or mandatory element.
- 6 General non-compliance with the selection criteria 180 · 3.2%
The bid fails to prove compliance with one or more of the admission requirements.
- 7 Price proposal not decrypted in time 150 · 2.6%
A technical fumble at electronic opening — the price never becomes available to the committee in time.
- 8 Abnormally low price / rejected justification (Art. 72) 147 · 2.6%
The price is low, but the Art. 72 justification is missing or was rejected.
- 9 No manufacturer, brand and model stated 143 · 2.5%
The most common technical omission in supplies — offered equipment without clear identification.
- 10 Discrepancy in the linear time schedule 140 · 2.5%
The schedule does not match the activities, deadlines or resources; a machinery diagram is missing.
- 11 Personal status — tax/social-security/convictions (Art. 54/55) 128 · 2.3%
A missing document on the absence of debts to the state, or a personal-status declaration.
- 12 Missing registration or entry (builders register, commercial register, licence) 128 · 2.3%
The firm lacks the required status or a current registration at the time of bidding.
- 13 Missing or irregular template ("Implementation Proposal", etc.) 106 · 1.9%
The mandatory template is skipped, incomplete or does not match the announced conditions.
- 14 Missing or irregular declaration 101 · 1.8%
A mandatory personal-circumstances declaration or another form is missing or defective.
- 15 Signature — handwritten/scanned instead of QES 99 · 1.7%
The form of the signature defeats an otherwise valid document — often hidden inside the ESPD and declarations.
The full catalogue: the exclusion grounds
Below is the complete catalogue, grouped by category and ordered by frequency. The number in brackets is the count of cases, among the 5,679, whose leading ground is this one. The general Art. 107 ground (“does not meet the pre-announced conditions”) is shown at the top of each of the two large categories — it is the umbrella under which one of the specific gaps almost always sits. This is the pre-submission check, line by line.
Documents and declarations (≈ 46%)
The category that sinks more bids than all the others combined. Almost none of these mistakes require skill — only attention.
- General finding: “the bid does not meet the pre-announced conditions” (Art. 107) — 1204
- ESPD — unfilled, unsigned or irregular — 295
- Price proposal not decrypted in time — 150
- Personal status — tax/social-security/convictions (Art. 54/55) — 128
- Missing registration or entry (builders register, commercial register, licence) — 128
- Missing or irregular template (“Implementation Proposal”, etc.) — 106
- Missing or irregular declaration — 101
- Signature — handwritten/scanned instead of QES — 99
- Bid/performance guarantee — missing or irregular — 98
- “Professional liability” insurance — missing or invalid — 91
- Documents not submitted within the set deadline — 88
- Sanctions declaration (Art. 5k / Reg. 2022/576) — 84
- Missing catalogue, brochure or sample — 46
- Error/discrepancy in the bill of quantities (BoQ) — 40
- No official Bulgarian translation — 29
Technical non-compliance (≈ 36%)
Here the mistakes are more substantive, but still a matter of preparation, not market power. The spec is read literally — implication is no defence.
- Technical proposal “does not meet the announced conditions” (Art. 107) — 839
- Missing/incomplete description of performance (programme, strategy, methodology) — 335
- Non-compliance with the technical specification — 291
- Technical proposal below the minimum requirements — 201
- No manufacturer, brand and model stated — 143
- Discrepancy in the linear time schedule — 140
- Deadline or warranty period outside the requirement — 57
Price and price justification (≈ 10%)
A low price almost never excludes you on its own — what excludes you is the missing or weak justification under Art. 72.
- Price non-compliance or incompleteness (general) — 293
- Abnormally low price / rejected justification (Art. 72) — 147
- Price above the estimated (maximum) value — 89
- Arithmetic error in the price proposal — 33
Experience and selection criteria (≈ 7%)
Here the firm is often capable but fails to prove it in the required format.
- General non-compliance with the selection criteria — 180
- Unproven experience / similar contracts — 68
- Key expert or team — missing or unproven — 45
- Turnover / financial standing below the minimum — 37
- Missing certificate (ISO or other) — 36
Reserved tenders and unclear grounds (< 1%)
- Reserved tender (Art. 12) — missing registration — 15
- Unclear ground (the report does not allow an unambiguous classification) — 43
How we use this catalogue
The catalogue isn’t meant to be read once and forgotten. It’s a checklist we apply in every tender analysis and fit scoring. When we review a specific procedure, we run the bid against each of these grounds and flag where you’re exposed — before the committee does it for you.
The logic is simple: over four fifths of these grounds are free to avoid. They don’t ask for a better price, higher quality or connections — only for discipline and a timely check. That’s the difference between “we lost fairly” and “we were excluded over the folder”.
In public procurement, more often than anything else, the winner is not the cheapest nor the best-connected — it’s the most meticulous.
— Analysis of 5,679 real exclusion grounds across 59 firms. Bidder names removed; only the grounds are kept.