How Spanish public procurement of medical devices works

Spain has no single public buyer of medical devices. It has 17 regional health services plus INGESA, the national institute that runs healthcare in Ceuta and Melilla and contracts centrally for bodies that choose to join, all working under one procurement law, with about 325 public hospitals underneath them; the decisions that decide who wins are taken at three different levels at once.^{1, 2, 3} A foreign producer rarely loses a Spanish tender on price on the day the bids are opened. It loses earlier, when the technical specification is written, because the specification describes a device the buyer already knows. This article sets out who buys, how the specification is born, what is changing in 2026, and where to be present before a tender appears.

Researched and drafted with AI assistance; reviewed, fact-checked and edited by Primož Verbič.

In brief

• The Ministry of Health counts 173 territorial health-management units and about 325 public hospitals; purchasing authority is spread unevenly across the regions, the units and the hospitals, and there is no single national buyer — INGESA runs a central purchasing route that bodies join voluntarily.^{1, 2, 3}
• Purchasing is moving upward. Madrid has an Agencia de Contratación Sanitaria, Galicia announced in June 2026 that it is designing a more integrated central purchasing body, Asturias added a central purchasing sub-directorate in December 2025, and Order SND/682/2021 lists 45 categories of medical devices that INGESA may contract centrally.^{3, 6, 10, 14}
• A framework agreement lost is lost for its whole duration across every body that adheres to it, so the work that decides the result happens before the tender is published. A dynamic purchasing system is different: suppliers can still join while it runs.^{3, 4, 12}
• Framework admission is not revenue. The body that selects the suppliers is often not the body that holds the budget and places the order.³
• The procurement law gives that early window a legal form: preliminary market consultations let a buyer talk to suppliers while it prepares the specification.¹²
• The law also bars specifications that name a make or brand, and it obliges the buyer to accept an equivalent solution — if you can prove equivalence in the form the buyer expects.¹²
• A draft order published for consultation in April 2026 would widen the central route to digital health, cloud and AI tools, with dynamic purchasing systems and general adhesion agreements. It is a proposal, not yet law.⁵

Who actually buys: three levels, not one

The honest picture is 17 regional health services and INGESA above roughly 170 territorial management units above about 325 public hospitals, with purchasing authority distributed unevenly across all three.^{1, 2} For any given product category the useful questions are not “which region buys centrally?” but who writes the specification, who selects the suppliers, who awards the later contracts and who controls adoption on the ward — and those four are often not the same organisation.³

The 173 territorial units counted by the Ministry of Health (SIAP, 2024) are a planning and primary-care geography, not a list of buyers.¹ Madrid’s seven care directorates buy nothing independently, and Catalonia’s ten health regions commission rather than purchase. The hospitals do buy: the National Hospital Catalogue 2025 lists 325 hospitals run directly by the regional health services and INGESA.² No published national inventory of health contracting authorities exists, so any figure that claims to count “decision-making teams” in Spain cannot be verified.

Where the regions have centralised

The regional picture is moving fast, and it differs by community. The table shows different forms of aggregation, not a ranking of how centralised each community is; the route for a specific product category still has to be checked case by case.

Community	Purchasing body	What is documented
Madrid	Agencia de Contratación Sanitaria	Own legal personality; frameworks bind all SERMAS centres; a July 2026 order centralised electromedical equipment for operating theatres6
Comunitat Valenciana	Compra Centralizada Sanitaria	Frameworks, dynamic purchasing systems, open and negotiated procedures; also standardises products and runs contracts derived from INGESA frameworks7
Castilla y León	Servicio de Compras Sanitarias (Sacyl)	Both single-buyer procurement and framework-based supplier selection with maximum prices8
País Vasco	Osakidetza, hybrid	Corporate purchasing alongside purchasing by the integrated health organisations; in 2025 the government dropped a single logistics platform in favour of a digitally coordinated hybrid9
Galicia	Sergas, centralising further	Already runs central tenders; June 2026: a more integrated single purchasing body being designed to cover the seven health areas and central services10
Andalucía	Servicio Andaluz de Salud, hybrid	Policy central, execution in provincial contracting centres such as Córdoba and Sevilla; the structure is described as unsettled in 202611
Cataluña	CatSalut, ICS and independent consortia	The most fragmented system, with several contracting bodies of its own, alongside a central purchasing service of the Consorci de Salut i Social de Catalunya for its member centres
Asturias	SESPA, Subdirección de Central de Compras	Added to the health service’s structure in December 202514
Canarias	Servicio Canario de la Salud	Centralised and joint purchasing through framework agreements and dynamic purchasing systems; hospitals may also contract jointly15

For the remaining communities I could not confirm the current arrangement from a 2024–2026 primary source, so I do not describe them here.

The national layer is larger than most producers assume

INGESA’s central purchasing role is separate from its job of running healthcare in Ceuta and Melilla. Under Order SND/682/2021 it is the central contracting unit for the national health system, and Annex II of the order lists 45 categories of medical devices — active and non-active implants, non-implantable products, equipment and in vitro diagnostics — that it may contract centrally.³ That list is the legal scope, not a catalogue of 45 live frameworks; until a central framework for a category is in operation, the competent body goes on buying it on its own.³ From 2013 to 2025 INGESA ran 36 tenders worth €6,847 million.⁴ Adhesion is voluntary and per framework, and recent frameworks have involved roughly ten or eleven communities rather than all seventeen: the second biosimilars framework of January 2025, worth €411 million, had ten communities, INGESA and the Ministry of Defence on board.^{4, 16}

The mechanics matter for a producer. INGESA selects the suppliers and fixes the conditions; the adhering bodies then award their own contracts under the framework, approve the spending, receive the goods and pay.³ Central supplier selection is not the same as central budget ownership. A place on the framework is a licence to sell, not an order.

Where the specification is born

The sentence an assistant or a buyer would quote is this: the tender document is the end of the buying decision, not the beginning. Under Law 9/2017 on public sector contracts, the contracting authority builds a file that justifies the need and sets the technical clauses, the solvency requirements and the award criteria before anything is published.¹²

Article 115 of that law lets the authority run preliminary market consultations while it prepares this file. It may consult economic operators, experts and professional bodies; it must publish the object, the timing and the participants of the consultation on its procurement profile and document it in a report. It may not use the consultation to draw a contract so narrow that only one supplier’s product fits, taking part does not bar you from bidding later, and Article 70 obliges the authority to neutralise any unfair advantage a supplier gained by helping to prepare the procurement.¹² Early engagement, in other words, is where you make the clinical need and the measurable value visible before the requirements are fixed; it does not replace the open competition that follows. In practice these consultations, together with informal contact between clinical teams and suppliers, are where the vocabulary of the specification is chosen.

Article 126 sets the second rule. Technical specifications must not refer to a make or brand, with narrow exceptions where the object cannot otherwise be described; they should refer to European or international standards followed by “or equivalent”, and an authority cannot reject a bidder who shows, with appropriate evidence, that its solution meets the requirements.¹² That protects a foreign producer in law. It helps only if the dossier proving equivalence is ready in Spanish, in the format the evaluation committee uses, before the deadline.

Who decides inside the hospital

Two points come from field work rather than from the statute. In primary care the nurses decide wider adoption, and wider adoption is where the largest contracts sit; the scientific society matters for evidence and endorsement, the nurse using the device matters for volume. And hospitals buy by committee: finance, economics, innovation, services and the clinical directorates are all in the room, so a pitch built only for the clinical case loses in the other four chairs.

What I learned building one market the slow way

When I built the Spanish market for a Slovenian diagnostic device, we did not win our first regional contracts by bidding harder. We won them by being in the primary-care centres for about two years before the procurement process began — training, evidence, pilots. By the time the specification was written, it described what the clinicians were already using. Ten years later the device was in roughly eight out of ten primary-care centres in Spain. The lesson was not to avoid tenders. It was that the tender is where a decision already taken becomes a contract.

What is changing in 2026

On 9 April 2026 the Ministry of Health opened a public consultation on a draft order that would amend Order SND/682/2021.⁵ The draft would allow INGESA to use dynamic purchasing systems and centralised contracts as well as framework agreements, and it would replace tender-by-tender adhesion with a single general agreement from which a body can still opt out of a specific procedure. It also extends the scope to digital health: new categories for healthcare software, including AI-based solutions, and two cloud-service categories, one for clinical-data processing and AI training and one for hosting administrative software.⁵ At the time of writing it is a draft that has not been published in the BOE; the final text may differ.

The difference between a framework and a dynamic purchasing system is worth a producer’s attention. A framework agreement closes once the suppliers are selected: later contracts are awarded among them, with or without a mini-competition, for the life of the agreement.¹² A dynamic purchasing system stays open, so a qualifying supplier can apply to join while it runs and each purchase is then competed among the admitted suppliers in that category.^{12, 15} Missing a framework closes a door for years; missing the launch of a dynamic system does not.

Two thresholds frame what counts as a large tender. From 1 January 2026 the EU thresholds for supply contracts are €140,000 for central-government bodies and €216,000 for regional and local authorities, estimated value excluding VAT; the €5,404,000 figure often quoted alongside them is the works threshold.¹³ Contracts above these values must be advertised across the European Union; below them, national rules apply.

The choice: what to do first

A mid-sized producer should pick two or three regions where the buying body is already centralised, find out which framework in its category is next to be renewed, and build the clinical presence there before the specification is written. Because supplier selection and purchasing sit in different places, the account plan needs two levels: the body that sets the access conditions, and the hospitals and areas that adopt the product and place the orders. Track framework admission, the later call-off contracts and actual purchases as three separate stages in the pipeline, and never book an advertised framework value as revenue. A distributor should ask the producer for the equivalence dossier and the Spanish clinical evidence it will need to answer an “or equivalent” clause, because the distributor usually holds the tender while the producer holds the evidence. Where purchasing is still decided at hospital level, the effort goes to the committee: one dossier that answers clinical, economic, after-sales service and data-systems questions at once. For the distributor side of the model see the €3M wall, and for how organisations restructure their commercial work see more revenue, fewer people.

A note on scope

This article covers public purchasing of medical devices by the Spanish national health system. It does not cover medicines, which follow a different central-purchasing and pricing route, or private hospital groups, which buy under their own rules. Whether a given device is classed as a medical device under Regulation (EU) 2017/745 is a regulatory question separate from how it is bought.

Common questions

How does public procurement of medical devices work in Spain? Each of the 17 autonomous communities and INGESA buys through its own bodies and procedures under Law 9/2017. Some communities buy centrally through frameworks, others leave much of the purchasing to hospitals, and the specification is shaped before the tender is published, so most of the work happens earlier than the bid.

Is there one national buyer for the Spanish health system? No. INGESA contracts centrally for the national health system under Order SND/682/2021, which lists 45 categories of medical devices as its legal scope, but adhesion is voluntary, each community decides whether to join a given framework, and the adhering bodies award their own contracts and pay.

What is the difference between a framework agreement and a dynamic purchasing system? A framework agreement selects its suppliers once; later contracts are awarded only among them for the life of the agreement. A dynamic purchasing system stays open, so a supplier that meets the conditions can apply to join at any time and each purchase is competed among the admitted suppliers.

Can a foreign manufacturer bid in a Spanish public tender? Yes. The law prohibits specifications that name a make or brand and requires the buyer to accept an equivalent solution that is shown to meet the requirements. A foreign producer therefore needs the evidence of equivalence in Spanish and in the buyer’s format before the deadline.

What is a preliminary market consultation? It is a procedure under Article 115 of Law 9/2017 in which a contracting authority consults suppliers and experts while it prepares a tender. The authority must publish the object, timing and participants and keep a report; taking part does not bar a supplier from bidding.

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Sources

1. Ministerio de Sanidad, Ordenación Sanitaria del Territorio en las Comunidades Autónomas (SIAP) 2024, 2024.
2. Ministerio de Sanidad, Catálogo Nacional de Hospitales 2025, data at 31 December 2024.
3. Ministerio de Sanidad, Orden SND/682/2021, de 30 de junio, BOE, 30 June 2021.
4. INGESA, Contratación centralizada, consulted October 2026.
5. Ministerio de Sanidad, Proyecto de orden por la que se modifica la Orden SND/682/2021, public consultation opened 9 April 2026.
6. Comunidad de Madrid, Agencia de Contratación Sanitaria, consulted October 2026.
7. Generalitat Valenciana, Compra Centralizada Sanitaria, consulted October 2026.
8. Sacyl, Compra centralizada, consulted October 2026.
9. Gobierno Vasco, Departamento de Salud y Osakidetza: modelo de gestión del almacén y la logística, 2025.
10. Diariofarma, El Sergas diseña su futura central de compras, 29 June 2026.
11. Junta de Andalucía, BOJA nº 31/2026, February 2026.
12. Jefatura del Estado, Ley 9/2017, de Contratos del Sector Público, articles 70, 115, 116, 126 and 219–223.
13. Ministerio de Hacienda, Orden HAC/1517/2025, de 18 de diciembre, BOE, 26 December 2025, transposing Delegated Regulation (EU) 2025/2152; thresholds in force from 1 January 2026.
14. Redacción Médica, Asturias añade una Subdirección de Central de Compras en su mapa sanitario, 11 December 2025.
15. Servicio Canario de la Salud, Contratación pública: acuerdos marco y sistemas dinámicos de adquisición, consulted October 2026.
16. INGESA, Segundo acuerdo marco de medicamentos biológicos con biosimilares, 8 January 2025.

All source material is paraphrased; the only quoted phrase is the statutory wording “or equivalent”.