GEBTA Challenges the 605-million-tender to manage ministry travel
The association of corporate travel agencies has filed an appeal with the Central Administrative Court for Contractual Appeals, requesting the suspension of the proceedings and the annulment of the bidding documents. Among other issues, GEBTA questions the cost structure, the requirement for discounts on airfares, and certain obligations that it considers impossible for agencies to meet.
GEBTA has challenged the bidding process for the provision of travel agency services for the General State Administration (AGE), a contract valued at 604.8 million euros intended to manage travel arrangements for ministries and public agencies.
On September 2, the association filed an appeal with the Central Administrative Court for Contractual Appeals (TACRC) requesting the suspension of the proceedingsand the annulment of the bidding documents prepared by the General Directorate for the Rationalization and Centralization of Procurement.
GEBTA maintains that the terms of the tender contain various regulatory violations and raises objections of an economic, operational, and legal nature.
Costs and Profitability
One of the main issues raised by the association is the cost structure outlined in the tender. According to GEBTA, the bidding documents do not adequately justify these costs and establish conditions that could force agencies to submit bids with prices that do not cover their actual expenses or eliminate their profit margin.
The organization believes that this issue may be particularly relevant for those agencies that do not currently provide services to the government and are considering participating in the new bidding process.
Among the contested conditions are also the requirement for flat-rate discounts on airfares and certain improvements to travel insurance at no cost. GEBTA believes that these clauses could violate Articles 102.3 and 2 of the Public Sector Contracts Law (LCSP).
Obligations that are difficult to fulfill
A second part of the appeal concerns certain requirements set forth in the Technical Specifications (PPT) which, in the association?s view, are operationally impossible to guarantee.
GEBTA argues that some of these requirements depend on the practices and conditions of the transportation providers themselves and are therefore beyond the direct control of travel agencies. Others, according to the organization, would exceed the usual functions of a travel intermediary.
The association also questions whether these obligations could entail penalties for the awarded agencies when compliance does not depend exclusively on them.
Data protection, insurance, and IATA
The appeal includes a third set of objections related to regulations that are strictly outside the scope of public procurement. GEBTA argues that certain clauses could conflict with legislation on data protection, the regulation of the insurance market, and the IATA regulations.
The organization therefore considers that the issues identified are not limited to the contract?s economic model but affect various legal and operational aspects of the future provision of the service.
The 2025 Precedent
This is not the first time that GEBTA has challenged the conditions set forth by the Administration for contracting its travel services. In 2025, the association had already challenged the Framework Agreement for contracting travel agency services, arguing that it violated current regulations and the principles of freedom of enterprise and competition.
That procedure ultimately resulted in the tender being declared void, as no bids were submitted by travel agencies. Consequently, the Central Administrative Court for Contractual Appeals did not rule on the merits of the appeal.
GEBTA argued then, as it does now, that the conditions set forth not only posed legal problems but also made the contract economically unfeasible for the agencies.
GEBTA Calls for Dialogue
The association also criticizesthat the Administration did not resort to the preliminary market consultations provided for in Article 115 of the Public Sector Contracts Law before drafting the bid documents.
According to GEBTA, a process of prior dialogue with the agencies would haveallowed the terms of the bid to be adapted to market realities and would have prevented both this new appeal and the costs and delays that a possible suspension of the procedure could cause.
The organization asserts that, as early as the previous tender, it offered its services to the Administration to advise on the contract terms and establish a framework for collaboration that would reconcile the needs of the public sectorwith the functioning of the corporate travel market.
Finally, GEBTA highlights the economic significance of corporate travel agencies in Spain. According to its estimates, the sector has an annual revenue exceeding 4,000 million euros and contributes to generating approximately 390,000 million euros in business activity.
The association is therefore calling for ?fair and balanced? contracting terms that allow agencies to maintain their ability to provide services to businesses and government agencies and continue to generate value for the economy.