On 3 August, ANAC published the report Corruption and Procurement in Italy: Analysis from January 2020 to May 2026 (Corruzione e appalti in Italia: analisi gennaio 2020 – maggio 2026), which summarizes information on corruption and other unlawful conduct in procurement contained in materials submitted by public prosecutors between 1 January 2020 and 15 May 2026.
A total of 135 reports concerning 141 criminal proceedings were analyzed. These proceedings involved 1,295 charges related to corruption and other violations in the award and performance of public contracts. ANAC stresses, however, that the data do not provide an estimate of the actual scale of corruption in the country and reflect only those cases reported to the Authority by law enforcement bodies.
The most common violations were interference with tendering or contractor-selection procedures, accounting for 28.3% of the offenses identified. This was followed by bribery for acts contrary to official duties – 22.2%, corrupt conduct by private parties – 21.2%, and fraud, including fraud in contract performance – 8.5%.
Overall, the cases involved 994 individuals, including 583 representatives of suppliers and 411 representatives of contracting authorities. They also involved 490 companies, 212 contracting authorities, and more than 530 public contracts and concessions. Local government bodies were the most frequently represented contracting authorities, accounting for 46.2%; healthcare organizations accounted for another 20.8%, and state-controlled companies for 14.2%.
Public works proved to be the most vulnerable area, accounting for more than 40% of the cases examined. Services followed at 32%, mixed contracts at 13.5%, and supply contracts at 9.5%. Frequently affected areas included road and green-space maintenance, waste management, cleaning, social services, as well as healthcare-related services and supplies.
According to the study, corruption-related violations may occur at different stages of the procurement cycle – from preparing tender documentation and setting contractor-selection criteria to the performance of an already awarded contract. Unlawful arrangements between representatives of contracting authorities and suppliers often extend beyond a single procurement procedure, covering several contracts and developing into sustained relationships.
The cases examined by ANAC also include violations involving direct awards and procedures used in emergencies or situations requiring urgent action. In some cases, such mechanisms were used to award multiple contracts to the same supplier.
ANAC separately analyzed the risks associated with the expanded use of direct awards in an April 2026 study devoted to direct procurement of goods and services without competitive procedures in 2021–2024.
In 2021, contracts for goods and services could be awarded directly where the procurement value did not exceed €75,000. The threshold was subsequently raised to €140,000 and incorporated into the new Public Contracts Code (Codice dei contratti pubblici).
Following the increase, ANAC identified a marked concentration of procurements valued just below the applicable threshold, particularly in the €135,000–€140,000 range. The aggregate value of procedures in this range stood at approximately €213 million in 2021, rising to €859 million in 2022, €1.38 billion in 2023, and €1.53 billion in 2024. In 2024, procurements worth between €135,000 and €140,000 accounted for approximately 31% of the aggregate value of the procedures analyzed in the €100,000–€180,000 range.
This “threshold effect” was particularly pronounced in procurement of engineering, legal and architectural services, waste-management services, software development and consulting – areas in which the value of services is more difficult to determine objectively. By contrast, the concentration of procurements just below the threshold was considerably less pronounced for medical equipment and pharmaceutical products, which tend to have more standardized prices.
According to ANAC, such concentration may indicate that procurement values are being set so as to preserve the possibility of awarding contracts without a competitive procedure. ANAC President Giuseppe Busia has also pointed to cases of artificial contract splitting designed to keep individual contracts below the relevant threshold. Such practices, he said, may conceal inefficient spending, opportunistic behavior, and even infiltration of public procurement by criminal organizations.
The higher thresholds for direct awards were originally intended to speed up and simplify procurement procedures. However, ANAC’s findings show that reducing administrative burdens and the number of competitive procedures may at the same time increase certain corruption risks.
Against this background, the updated Russian approach to distinguishing permissible single-source procurement from artificial contract splitting is particularly noteworthy.
While ANAC regards the concentration of contracts immediately below the applicable threshold as one indicator of a possible attempt to avoid a competitive procedure, Russian lawmakers in 2026 expressly established the possibility of awarding several contracts for homogeneous or identical goods, works, and services in a number of cases involving procurement from a single supplier.
The relevant provision was introduced by Federal Law No. 484-FZ of 26 December 2024 and entered into force on 1 January 2026. It allows several contracts for homogeneous or identical goods, works, and services to be awarded under Clauses 4, 5 and 28 of Part 1, as well as Part 12, of Article 93 of Federal Law No. 44-FZ, subject to the limits established for the relevant types of procurement.
For comparison with the Italian rules, the so-called “small-value procurements” under Clause 4 of Part 1 of Article 93 are particularly illustrative. The value of a single contract with a sole supplier may not exceed RUB 600,000, while the annual aggregate value of such procurements generally may not exceed either RUB 2 million or 10% of the contracting authority’s total annual procurement volume, subject in the latter case to an overall cap of RUB 50 million.
Additional amendments introduced by Federal Law No. 279-FZ of 4 August 2026 entered into force on 4 August 2026. The law now expressly provides that several contracts awarded in the cases covered by Part 15 of Article 93 may be concluded including with the same supplier. The new rule also applies to legal relations that arose before the amendments entered into force.
The introduction of the possibility of making several homogeneous procurements was linked to the need to simplify procurement activities and eliminate inconsistencies in enforcement practice. At the same time, Russia’s Federal Antimonopoly Service notes that artificially splitting a single transaction into several contracts in order to make it possible to award them to a sole supplier may be regarded as an attempt to circumvent a competitive procedure and may be assessed under competition law.
Thus, the Italian and Russian approaches differ primarily in their assessment of multiple procurements below the applicable value threshold: ANAC treats the concentration of such contracts as an indicator of heightened risk, whereas Russian legislation proceeds from the premise that several homogeneous procurements, including from the same supplier, do not in themselves constitute a violation.
