Support for three guidelines AI Act

Planned negotiated procedure EC-CNECT/2026/MVP/0091-EXA by the European Commission DG CNECT to commission desk research and analysis supporting implementation of the EU AI Act, providing input to three guidelines on responsibilities along the AI value chain, the concept of substantial modification for AI systems, and the interplay between the AI Act and other EU legislation. The services contract is classified under CPV 73000000, has a maximum value of €139,000 and a maximum duration of 10 months. This publication is an intention notice inviting expressions of interest via the EU Funding & Tenders Portal using an EU Login account; the expression of interest period runs from 03/04/2026 to 21/04/2026 with an indicative launch of the negotiated procedure on 23/04/2026. Eligible economic operators with demonstrated expertise in EU AI policy, legal analysis and guideline drafting should prepare submissions in line with the portal requirements.

Tender summary

What is funded

A study contract to support implementation of the EU AI Act through desk research, analysis and drafting input for three guideline topics: responsibilities along the AI value chain, the concept of substantial modification for AI systems, and the interplay between the AI Act and other relevant EU legislation.

Maximum value and duration:Maximum contract value €139,000; maximum duration 10 months.

1. 1Contract type: planned negotiated procedure for low/middle value contract
2. 2Nature of services: research and consultancy (CPV 73000000)

Expressions of interest are to be submitted electronically via EU Login. Key dates:start for expressions of interest 03/04/2026; deadline 21/04/2026 23:59 (Brussels); indicative launch of the negotiated procedure 23/04/2026. ¹

Footnotes

1. 1An EU Login account is required for subscription and electronic submission. See the EU Login help page on the European Commission portal for registration details.

Opportunity summary

What the tender is for

The European Commission (Directorate-General for Communications Networks, Content and Technology, DG CNECT) plans to launch a negotiated low or middle value procurement to commission a study that will support implementation of the EU AI Act. The contractor will conduct desk research and analysis and provide inputs to three sets of guidelines: guidelines on responsibilities along the AI value chain, guidelines on the concept of substantial modification in the context of AI systems, and guidelines on the interplay between the AI Act and other relevant EU legislation on specific topics. The procurement is classified under CPV 73000000 Research and development services and related consultancy services. The maximum value of the contract is €139,000 and the maximum contract duration is 10 months. The planned procedure identifier is EC-CNECT/2026/MVP/0091-EXA. This publication is an intention notice: it is not yet the final call but signals an upcoming negotiated procedure for a low/middle value contract ¹.

Lead contracting authority:European Commission, DG CNECT - Communications Networks, Content and Technology.

Main classification (CPV):73000000 Research and development services and related consultancy services.

Nature of contract:Services contract (procurement).

Maximum value and duration:Maximum contract value €139,000. Maximum contract duration 10 months.

Eligibility and applicant information

Eligible applicant types

The tender is a public procurement by the European Commission. Typical eligible applicants are legal entities able to conclude a services contract with the Commission, including but not limited to consultancies, law firms, policy and regulatory research organisations, think tanks, universities and research institutes, SMEs and larger companies offering policy analysis and regulatory expertise, and consortia or partnerships of such organisations. Public bodies may also participate subject to procurement rules. Individual natural persons are typically not suitable unless they are able to contract as legal entities. Participation requires registration and submission via EU Login and the EU Funding & Tenders Portal procedures for negotiated procurements.

Consortium requirement

The procedure is a negotiated low/middle value procurement. The publication does not mandate a consortium. It is therefore open to single legal entities. Forming a consortium or subcontracting relevant expertise is normally possible and common in EC services contracts where multidisciplinary expertise is required; the Commission will specify rules in the call documents. For planning purposes, bidders should assume either: single-lead bidder with named subcontractors or a formal consortium where participants provide complementary skills.

Geographic eligibility / beneficiary scope

The contracting authority is the European Commission. The opportunity is intended for organisations that can contract with the Commission under EU procurement rules. Practically this covers organisations established in EU Member States and generally in EEA and certain third countries eligible under Commission procurement rules. The announcement and upcoming negotiated procedure are published on the EU Funding & Tenders Portal, and submission requires an EU Login account. The opportunity is EU-focused and aims to support implementation of EU legislation (the AI Act).

Scope, expected tasks and project stage

Project scope and tasks

The contractor will perform desk research and analysis and will produce inputs for three separate sets of guidelines: 1) guidelines on the responsibilities along the AI value chain; 2) guidelines on the concept of substantial modification in the context of AI systems; 3) guidelines on the interplay between the AI Act and other relevant EU legislation on specific topics. The work is policy- and law-focused. Tasks will include literature and legislative review, mapping responsibilities across actors (developers, deployers, operators, providers, users), legal analysis of substantial modification and its triggers, analysis of overlaps and interaction with other EU laws, drafting guidance text, and likely participating in meetings or presentations with the Commission to discuss findings and refine recommendations.

The expected project maturity is in the policy research/analysis stage:research, legal and policy analysis, development of guidance documents, and validation with the Commission. This is not technology development; it is implementation support for regulatory guidance.

Financial and procedural details

Funding type

This is a procurement / service contract. The primary financial mechanism is a public procurement payment for services. It is not a grant, loan or equity instrument.

Funding amount:Maximum contract value €139,000.

Application method and timeline

The current publication is an intention notice (reference contains ExA). The planned procedure type is a negotiated procedure for middle/low value contract. Interested parties must submit an expression of interest electronically via the EU Funding & Tenders Portal using an EU Login account. Key dates published in the notice are: start date for expression of interest 03/04/2026 (Europe/Brussels); deadline for expression of interest 21/04/2026 23:59 (Europe/Brussels); indicative date of launch of the negotiated procedure 23/04/2026 (Europe/Brussels). Full procurement documents and rules will be published at launch of the negotiated procedure.

Method of expression of interest:Electronic submission via EU Login / EU Funding & Tenders Portal. Submissions must be sent exclusively to the address for submission given in the call documents at the time of launch.

Application stages

At least two stages are identifiable:1) Expression of interest (pre-selection interest submitted electronically); 2) Negotiated procedure stage when the Commission issues the call documents, invites selected candidates, receives proposals and negotiates final terms. There may be further evaluation and contract award steps defined in the negotiated procedure; the final number of stages will be set out in the procurement documents.

Co-funding requirement

No co-funding by applicant is required under this services procurement. The Commission will pay for the contracted services up to the maximum contract value under the financial and invoicing rules specified in the procurement contract. Bidders should ensure their price proposals are complete and compliant with contract terms.

Success rates

The notice does not publish success rates. As a negotiated procurement for a single contract of limited value, competition will be limited to the candidates invited to the negotiation phase. The practical chance of award depends on the number and quality of competing offers and whether the bidder is invited to negotiate. No quantitative success-rate data is provided.

Practical guidance for applicants

Recommended applicant profile and expertise

Successful applicants should demonstrate:legal and regulatory expertise in EU law, specifically the AI Act and relevant sectoral EU legislation; experience drafting policy guidance and guidelines; capability to perform high-quality desk research and synthesize complex legal interactions; multidisciplinary teams combining legal, technical and policy analysis on AI; prior experience with European Commission contracts or other public procurement for policy research is an advantage; strong project management to deliver within the 10-month timeframe; ability to present and defend findings to Commission staff.

Suggested proposal structure and templates

The procurement documents will set the exact submission templates. Based on common Commission service tenders, bidders should prepare a structured dossier that typically contains the following elements and which can be adapted to the negotiated-procedure requirements:

1. 1Administrative cover letter and declaration of honour (compliance, conflicts of interest).
2. 2Legal and financial identification documents (company registration, VAT, bank details) as requested by the portal.
3. 3Technical proposal with methodology: objectives, work plan, tasks and deliverables, milestones, risk management and quality assurance.
4. 4Detailed work breakdown and Gantt / timeline aligned to the 10-month maximum duration.
5. 5Team composition and CVs: profiles of key experts (legal experts on AI law, policy analysts, technical advisors on AI, senior project manager).
6. 6Past experience and references: similar EU or international contracts, examples of guideline drafting or legal analysis on AI or digital regulation.
7. 7Price proposal: detailed budget and justification, staff rates, travel and other costs if applicable. Ensure total does not exceed proposed contract ceiling unless the procurement allows higher offers.
8. 8Consortium or subcontracting arrangements: letters of intent or consortium agreement and description of the role of each partner.
9. 9Deliverable samples or prior outputs (executive summaries, previous guidelines drafted).

Deliverables and outputs (anticipated)

While final deliverables will be defined in the contract, expected outputs include:reports and evidence-backed analyses for each guideline topic; draft guideline sections and recommended wording; mapping documents showing responsibilities across the AI value chain; legal analysis of substantial modification triggers with illustrative examples; mapping of interactions with other EU legislation and recommendations for alignment; executive summary and presentation for DG CNECT; finalised guidance documents ready for Commission review and publication.

Administrative and contact details

Expressions of interest must be submitted electronically via the EU Funding & Tenders Portal/EU Login. The expression of interest submission window shown in the notice is from 03/04/2026 to 21/04/2026 23:59 Europe/Brussels. The Commission will publish the negotiated procedure launch (indicative date 23/04/2026). Questions can be submitted via the portal Q&A after logging in; none were listed at the time of the notice. The DG CNECT contact information and department pages are available from the Commission website and the DG CNECT section on the portal.

Categorisation fields

Below are the requested categorisation fields extracted and interpreted from the notice.

1. 1Eligible Applicant Types: consultancies, law firms, policy/research organisations, think tanks, universities, research institutes, SMEs and large enterprises capable of contracting with the European Commission, consortia and subcontracting arrangements are acceptable; individuals are generally not the expected contracting entity.
2. 2Funding Type: procurement / service contract (public procurement), not a grant or loan.
3. 3Consortium Requirement: single legal entity is sufficient; forming a consortium or using subcontractors is permitted but not mandated. The procurement is a negotiated procedure, so the Commission may invite selected candidates to negotiate.
4. 4Beneficiary Scope (Geographic Eligibility): EU-focused; organisations able to contract with the European Commission (typically established in EU Member States and eligible third countries under Commission procurement rules). Submission requires EU Login and use of the EU Funding & Tenders Portal.
5. 5Target Sector: policy/regulatory analysis for artificial intelligence; thematic sectors include ICT, AI regulation, legal and governance frameworks, and digital policy. Related sectors: data governance and cross-sectoral EU legislation interplay.
6. 6Mentioned Countries: European Union (implied). The notice references Europe/Brussels time and the European Commission as contracting authority; no other countries are explicitly listed.
7. 7Project Stage: research / policy analysis / guideline drafting (research and validation rather than technological development).
8. 8Funding Amount: maximum €139,000 for the contract.
9. 9Application Type: planned negotiated procedure; expression of interest (electronic) followed by the negotiated procurement stage. Applicants must register and submit via EU Login on the EU Funding & Tenders Portal.
10. 10Nature of Support: monetary payment for services (money) under a public procurement contract; deliverable-based payment under contract terms.
11. 11Application Stages: at least 2 stages (expression of interest and negotiated procedure / proposal and negotiation); further evaluation/contract award steps will be in procurement documents.
12. 12Success Rates: not specified in the notice. As a negotiated procurement, selection will be limited to invited candidates and success depends on invitation and proposal quality.
13. 13Co-funding Requirement: no co-funding requested. The Commission pays for services under contract; bidders should include full cost in their price proposal.

How to prepare and recommended next steps

Organisations intending to respond should ensure they have an EU Login account and are registered on the EU Funding & Tenders Portal. Prepare administrative and financial documentation commonly required in Commission procurements, and assemble a multidisciplinary team with demonstrable AI law and policy expertise. Draft a clear methodology and timeline for delivering the three guideline inputs within 10 months and a realistic pricing schedule not exceeding €139,000. Monitor the portal for publication of the negotiated procedure documents on or after the indicative launch date and submit any questions via the portal Q&A once available. If forming a consortium, prepare consortia agreements and evidence of partners' capacities.

The Commission’s DG CNECT focuses on digital policy and enforcement of the AI rulebook; this contract will feed directly into EU-level guidance to support consistent interpretation and implementation of the AI Act across the value chain and across interacting legislation.

Footnotes

1. 1Source: EU Funding & Tenders Portal tender notice EC-CNECT/2026/MVP/0091-EXA Support for three guidelines AI Act published on the portal. See the contracting authority DG CNECT page for context EU Funding & Tenders Portal tender details.

Opportunity Overview

This is a planned negotiated procedure for a middle/low value service contract (EC-CNECT/2026/MVP/0091-EXA) to conduct desk research and analysis supporting the implementation of the EU AI Act. The study will provide input for three specific guidelines: (1) responsibilities along the AI value chain, (2) the concept of substantial modification in the context of AI systems, and (3) interplay between the AI Act and other relevant EU legislation on specific topics.

The procurement is managed by the European Commission, Directorate-General for Communications Networks, Content and Technology (DG CNECT), under CPV code 73000000 for research and development services and related consultancy services. Maximum procurement value is €139,000 with a contract duration of 10 months.

Procurement Type and Status

This is not an open call for tenders but a publication announcing the contracting authoritys intention to launch a future negotiated low or middle value procedure. Expressions of interest are invited to potentially be selected for direct negotiations. An EU Login account is required for electronic submission.

Key Dates and Milestones

1. 1Start date for expression of interest: 03/04/2026 (Europe/Brussels)
2. 2Deadline for expression of interest: 21/04/2026 23:59 (Europe/Brussels)
3. 3Indicative date of launch of the negotiated procedure: 23/04/2026 (Europe/Brussels)

Eligibility and Application Process

Eligible applicants are those expressing interest electronically via the EU Funding & Tenders Portal. Submissions must be sent exclusively through the designated address. Specific eligibility criteria for the negotiated procedure will be detailed upon launch, but interest is typically open to economic operators capable of delivering research and consultancy services in AI regulation. An EU Login account is mandatory; create one using email and password if needed.

Submission Method:Electronic submission via EU Funding & Tenders Portal. Log in required.

Scope of Work

The contractor will perform desk research and analysis to inform AI Act guidelines. These guidelines align with broader EU efforts by the AI Office, which is preparing practical instructions on AI Act application, including responsibilities along the value chain, substantial modifications, and interactions with other legislation such as GDPR and DSA¹².

Contract Details

Financials:Maximum value: €139,000. This is the estimated total value for the service contract.

Duration:10 months maximum.

Nature:Services contract, no framework agreement.

Contracting Authority

European Commission, DG CNECT (Communications Networks, Content and Technology). DG CNECT shapes Europes digital policies, including AI regulation, enforcement of the AI Act, and promotion of AI innovation while ensuring safety and compliance³.

Strategic Context

This procurement supports the EUs AI Act implementation, which entered into force with phased obligations (e.g., prohibitions from February 2025, high-risk systems by 2027). The guidelines address key areas like value chain responsibilities, substantial modifications (changes affecting AI system compliance), and harmonization with sectoral laws (e.g., finance, healthcare). Providers with expertise in AI policy, legal analysis, and EU regulatory interplay are ideal¹⁴.

Questions and Answers

Public Q&A is available on the portal; log in to submit questions. EXA references indicate planned negotiated procedures, not full tenders, with details provided upon expression of interest⁵.

Recommendations for Applicants

• Register for EU Login immediately to monitor updates and submit expressions of interest.
• Prepare expertise demonstrations in AI Act analysis, desk research on value chain responsibilities, substantial modifications, and EU legislative interplay.
• Review AI Act guidelines in development by the AI Office for alignment¹.
• Note the tight timeline: expressions due mid-April 2026.

Primary source:EU Funding & Tenders Portal. DG CNECT: Communications Networks, Content and Technology.

Footnotes

1. 1AI Office guidelines include responsibilities along the AI value chain, substantial modification, and interplay with other EU legislation. Source: digital-strategy.ec.europa.eu.
2. 2Study on AI Act tensions with GDPR, DSA, and sectoral laws (finance, healthcare). Source: bertelsmann-stiftung.de.
3. 3DG CNECT responsibilities in AI regulation and enforcement. Source: ec.europa.eu/info/departments.
4. 4AI Act provisions on substantial modification and high-risk systems. Source: artificialintelligenceact.eu.
5. 5EXA references explain planned negotiated procedures. Source: EU Funding & Tenders Portal Q&A.