Planning an AI pilot budget within Turkey's 2026 direct procurement limit

What is the 2026 direct procurement limit and when does it apply?

The Public Procurement Authority (Kamu İhale Kurumu, KİK) updated the monetary limits for direct procurement set out in Article 22(d) of Law No. 4734 (Kamu İhale Kanunu, the Public Procurement Law) for 2026. The amounts were set by the Public Procurement Communiqué No. 2026/1 (Kamu İhale Tebliği No: 2026/1), published in the Official Gazette (Resmî Gazete) dated 22 January 2026, issue 33145. They entered into force on 1 February 2026 and apply until 31 January 2027.

The updating mechanism comes from Article 67 of the Law, which provides that the threshold values and monetary limits stated in the Law are updated by the Public Procurement Authority on the basis of the previous year's wholesale price index, and are announced in the Official Gazette by 1 February each year, effective from that date. Any institution planning a pilot budget should therefore note in advance which update period the procurement will fall into.

The monetary limit applies to the value of the individual requirement being met, not to the institution's annual budget. The assessment is made excluding value added tax: what matters is whether the VAT-exclusive value of the requirement exceeds the limit.

• Institutions within metropolitan municipality boundaries: TRY 1,021,827 (1 February 2026 – 31 January 2027).
• All other institutions: TRY 340,391 (1 February 2026 – 31 January 2027).
• In the preceding period, 1 February 2025 – 31 January 2026, the same limits were TRY 800,366 and TRY 266,618 respectively.
• The limits exclude VAT, and quotations gathered during market price research are also taken exclusive of VAT.
• The same communiqué set the negotiated procedure limit under Article 21(f) of Law No. 4734 at TRY 3,406,508.

Is direct procurement a tender method under Law No. 4734?

Direct procurement (doğrudan temin) is not structured as a tender method in Law No. 4734. Article 18 of the Law lists three tender methods: open procedure (açık ihale usulü), restricted procedure among pre-qualified candidates (belli istekliler arasında ihale usulü) and negotiated procedure (pazarlık usulü). The fourth item of that article was repealed by Article 12 of Law No. 4964 dated 30 July 2003, removing direct procurement from the list of tender methods and regulating it separately in Article 22 as a procurement route. The Public Procurement Authority's own training material states the distinction plainly: direct procurement is not, in essence, a tender method but a procurement method.

This distinction has practical consequences for pilot projects, because several procedural obligations do not apply. The first paragraph of Article 22 provides that in the cases listed there, requirements may be met through direct procurement without publishing a notice and without taking a guarantee.

The final paragraph of Article 22 sets out the method to be followed: in procurements made under this article, requirements are met through market price research carried out by the person or persons assigned by the procurement authority, without any obligation to form a tender commission or to apply the qualification rules listed in Article 10. In other words, forming a commission, publishing a notice and taking a guarantee are not mandatory; however, an approval document must be issued, an assignment must be made, and market price research must be conducted.

• No obligation to publish a tender notice (Law No. 4734, Article 22, first paragraph).
• No obligation to take a guarantee (Law No. 4734, Article 22, first paragraph).
• No obligation to form a tender commission (Law No. 4734, Article 22, final paragraph).
• No obligation to apply the qualification rules in Article 10 (Law No. 4734, Article 22, final paragraph).
• An approval document (onay belgesi) must be issued and market price research conducted; determining an approximate cost is not mandatory but is needed to demonstrate that the monetary limit has not been exceeded.
• Under the Communiqué on Procurements to be Made by Direct Procurement Method, published in the Official Gazette dated 11 July 2023, issue 32245 and in force since 1 February 2024, market price research may be conducted partly or wholly electronically through EKAP, the national e-procurement platform.

How to calculate a pilot budget for a token-based AI service

In a token-based language model service, the budget is built on consumption rather than on a number of licences. For a procurement unit the calculation reduces to four variables: the scope of the pilot, the estimated number of monthly requests, the average input and output tokens per request, and the unit price of the selected model. Multiplying these produces the VAT-exclusive amount to be entered on the approval document.

Article 9 of Law No. 4734 describes how approximate cost is determined: before a procurement is carried out, the institution conducts price research of every kind and determines the approximate cost exclusive of value added tax, presenting it in a calculation sheet together with its supporting basis. For a token-based service, that supporting basis is the provider's published unit price catalogue combined with the institution's estimated usage volume.

In the worked example below the unit price is deliberately left as a variable. Model unit prices differ by model and are revised over time, so current values should be taken from the LLMTR pricing and model catalogue pages. The scenario is as follows: a three-month pilot in a single unit, 22 working days per month, 200 requests per day, averaging 1,500 input and 500 output tokens per request. That produces a three-month total of 19.8 million input and 6.6 million output tokens; the amount for the approval document is this volume multiplied by the catalogue unit prices, plus the platform margin applied at credit top-up.

Approximate cost calculation for a pilot, excluding VAT. Fill in unit prices from the current catalogue on the /pricing page.

# Public sector AI pilot - input for the approximate cost calculation sheet

monthly_requests = 4_400   # 22 working days x 200 requests per day
input_tokens = 1_500       # average input per request
output_tokens = 500        # average output per request
pilot_months = 3           # pilot duration

# Unit prices: TRY per 1,000,000 tokens.
# These vary by model - take them from /pricing and /models.
input_unit_price = 0.0
output_unit_price = 0.0

# Platform margin applied at credit top-up.
# No margin is added to catalogue model prices.
PLATFORM_MARGIN = 0.08

input_millions = monthly_requests * input_tokens * pilot_months / 1_000_000
output_millions = monthly_requests * output_tokens * pilot_months / 1_000_000

model_cost = input_millions * input_unit_price + output_millions * output_unit_price
credit_to_load = model_cost * (1 + PLATFORM_MARGIN)

print(f"Total input volume : {input_millions:.1f}M tokens")
print(f"Total output volume: {output_millions:.1f}M tokens")
print(f"Approval document amount (excl. VAT): TRY {credit_to_load:,.2f}")

# Compare the result against the 2026 direct procurement limits:
#   Institutions within metropolitan municipality boundaries: TRY 1,021,827
#   All other institutions                                  : TRY   340,391

Budget band and procurement route by pilot size

Public institutions usually start an AI pilot with a narrow use case and widen the scope as results come in. The procurement route changes with that scope: a narrowly scoped pilot can stay within the direct procurement limit, while a continuous service rolled out across the institution requires the open procedure.

In the table below, the amount and legislation columns are values verified for 2026. The request volume bands are illustrative planning ranges rather than measured statistics, and should be replaced with the institution's own usage estimate.

In EKAP records these procurements usually appear under headings such as artificial intelligence software leasing or artificial intelligence service procurement rather than API or token terminology. While the technical specification will use concepts such as tokens, requests and model identifiers, describing the subject of the procurement in the institution's familiar service procurement language keeps the process straightforward.

Critical warning: splitting a requirement to stay under the limit is prohibited

Law No. 4734 expressly prohibits splitting procurements in order to stay below monetary thresholds. The fundamental principles provision in Article 5 states that goods or service procurements and works may not be divided into parts with the aim of remaining below the threshold values. This is binding for direct procurement limits as well.

Article 22.5.1.2 of the Public Procurement General Communiqué (Kamu İhale Genel Tebliği) makes the rule concrete for direct procurement. It provides that meeting a requirement which should be procured through the open procedure under Article 19 by dividing goods and service procurements or works that could fall within the same procurement subject into items or groups, on a unit basis, so as to remain below the monetary limits set for Article 22(d), constitutes a breach of the fundamental principles of Law No. 4734, and that such practices will give rise to liability.

The line between what is legitimate and what is not is clear here. Procuring a limited-scope pilot through direct procurement and then, once results are in, procuring the institution-wide rollout through a tender procedure is legitimate, because the two procurements correspond to different scopes and different requirements. Taking a single requirement that was planned for the whole institution from the outset and splitting it across units, line items or months so that each part stays under the limit is contrary to the provisions above and gives rise to liability.

It matters that the difference between the pilot and the rollout can be demonstrated on paper. The scope, duration, covered unit and the question the pilot is meant to answer should be written into the approval document and the technical specification, and the rollout decision should rest on the pilot's outcome report.

• Legitimate: procuring a three-month, single-unit pilot with a defined, measurable success criterion through direct procurement.
• Legitimate: procuring the institution-wide service through the open or negotiated procedure on the basis of the pilot outcome report.
• Contrary to the Law: splitting a single requirement planned for the whole institution across units and running a separate direct procurement for each.
• Contrary to the Law: dividing the same requirement into items or groups so that each part stays under the Article 22/d limit.
• Contrary to the Law: artificially breaking a single continuous service into a series of consecutive short procurements.
• Article 5 of the Law also provides that no work for which an appropriation is not available may be put out to tender.

How LLMTR addresses spending caps and usage reporting

In a pilot run through direct procurement, the main risk for the procurement unit is that the amount written on the approval document is exceeded during use. In a token-based service consumption is variable, so this risk is structural and needs a technical cap mechanism. LLMTR addresses it with a credit-based usage model: the institution loads credit in advance and spending stays limited to the credit loaded, so no open-ended consumption is invoiced after the fact.

Budget control can be pushed down to the level of the individual unit. Each unit can hold its own API key, and every key has its own rate limit, its own cap and its own usage report. This makes it technically demonstrable which unit the pilot was confined to, and provides evidence that the pilot really was narrow in scope should the question of requirement splitting arise.

On pricing, two items are kept separate. Model unit prices are preserved at their catalogue values and no margin is added to them; the platform margin applies only at credit top-up, at a rate of 8%. When preparing the approximate cost calculation sheet, the model cost should be derived from catalogue prices and the credit top-up margin shown as a separate line.

Usage reports can be used to document expenditure at the inspection and acceptance stage. Reports are kept at the level of request counts and token volumes; user prompts and model response bodies are not written to the usage and billing database. Customer API keys are stored as SHA-256 hashes rather than plain text. Models hosted in Türkiye and models from global providers are called through the same OpenAI-compatible interface in one catalogue, which means switching models during a pilot carries no integration cost and unit price comparison stays straightforward.

• Credit-based usage: spending is limited to the credit loaded in advance.
• Per-unit API keys: each unit can be given its own key, its own cap and its own usage report.
• No margin is added to model prices; the 8% platform margin applies only at credit top-up.
• Usage reporting is kept at request and token level; prompts and response bodies are not written to the billing database.
• Current unit prices and the model list should be taken from the pricing and model catalogue pages.

Sources

The legislative references and monetary amounts in this article were verified against the primary sources listed below. Last checked: 13 August 2026.

This content is informational and does not constitute legal advice. The final assessment rests with the institution's compliance and legal units.

• Law No. 4734 (Kamu İhale Kanunu, Public Procurement Law), Articles 5, 8, 9, 18, 21, 22 and 67 — mevzuat.gov.tr
• Public Procurement Communiqué No. 2026/1 (Kamu İhale Tebliği No: 2026/1), Official Gazette dated 22 January 2026, issue 33145 — resmigazete.gov.tr
• Comparative table of threshold values and monetary limits under Law No. 4734, 2026 — kik.gov.tr
• Public Procurement General Communiqué (Kamu İhale Genel Tebliği), Article 22.5.1.2 — ihale.gov.tr
• Direct procurement training presentation, EKAP Akademi — kik.gov.tr
• Communiqué on Procurements to be Made by Direct Procurement Method, Official Gazette dated 11 July 2023, issue 32245 — resmigazete.gov.tr

Planning an AI pilot budget within the direct procurement limit

Steps for calculating the pilot budget of a token-based AI service in a Turkish public institution and selecting the procurement route against the 2026 direct procurement monetary limits.

1. Define the pilot scope in writing. Write down which unit the pilot covers, which use case it addresses, how long it runs and what its success criterion is. This definition underpins both the technical specification and, for the purposes of the splitting prohibition, the distinction between the pilot and any later rollout.
2. Estimate request and token volume. Derive the monthly request count from the daily transaction volume of the unit in scope. Determine the average input and output tokens per request by measuring a short sample where possible. If measurement is not feasible, take the upper end of the estimated band.
3. Calculate approximate cost from catalogue unit prices. Take the input and output unit prices per million tokens for the selected model from the pricing and model catalogue pages. Multiply by the total token volume to obtain the model cost, and add the platform margin applied at credit top-up as a separate line. Present the amount exclusive of VAT.
4. Compare the amount against the 2026 monetary limits and select a route. Compare the VAT-exclusive amount against the Article 22(d) limit applicable to your institution: TRY 1,021,827 for institutions within metropolitan municipality boundaries, TRY 340,391 for all others. If the limit is exceeded, evaluate the Article 21(f) negotiated procedure or the open procedure under Article 19.
5. Issue the approval document and run market price research. In the approval document signed by the procurement authority, set out the nature and quantity of the requirement and the availability of appropriations. Have the assigned personnel conduct market price research and collect quotations exclusive of VAT. The research may be carried out partly or wholly electronically through EKAP.
6. Set a usage cap and track consumption through reports. Issue a dedicated API key for the pilot unit and set a usage cap matching the amount on the approval document. Compare monthly usage reports against the estimate in the calculation sheet, and revise the estimate before any rollout decision if there is a material deviation.

Frequently asked questions

What is the direct procurement limit in Turkey for 2026?

Public Procurement Communiqué No. 2026/1, published in the Official Gazette dated 22 January 2026, issue 33145, set the monetary limits under Article 22(d) of Law No. 4734 at TRY 1,021,827 for institutions within metropolitan municipality boundaries and TRY 340,391 for all other institutions. The amounts exclude VAT and apply from 1 February 2026 to 31 January 2027.

Is direct procurement a tender method?

No. Article 18 of Law No. 4734 lists the tender methods as the open procedure, the restricted procedure among pre-qualified candidates, and the negotiated procedure. Direct procurement was removed from that list by Law No. 4964 dated 30 July 2003 and is regulated separately in Article 22 as a procurement route. As a result there is no obligation to publish a notice, take a guarantee or form a tender commission.

Can an AI pilot project be procured through direct procurement?

If the VAT-exclusive value of the requirement does not exceed the monetary limit in Article 22(d), the direct procurement method can be used. In that case the procurement authority must issue an approval document, make an assignment, and have the assigned personnel conduct market price research. Determining an approximate cost is not mandatory, but it needs to be calculated in order to show that the requirement stays within the monetary limit.

Can we split a pilot across units to stay under the direct procurement limit?

No. Article 5 of Law No. 4734 provides that goods or service procurements and works may not be divided into parts with the aim of staying below the threshold values. Article 22.5.1.2 of the Public Procurement General Communiqué states that dividing procurements that could fall within the same procurement subject into items or groups in order to procure them under Article 22(d) breaches the fundamental principles of the Law and gives rise to liability. Procuring a narrow pilot through direct procurement and the rollout through a tender procedure, however, is legitimate.

How is approximate cost determined for a token-based AI service?

The calculation rests on four variables: estimated monthly request count, average input tokens per request, average output tokens per request, and the selected model's unit price per million tokens. These are multiplied and scaled by the pilot duration. Under Article 9 of Law No. 4734 the approximate cost is determined exclusive of value added tax and presented in a calculation sheet together with its supporting basis; for a token-based service that basis is the provider's published unit price catalogue.

Which procedure applies if we exceed the direct procurement limit?

If the approximate cost exceeds the Article 22(d) limit, direct procurement cannot be used. In the 2026 period, procurements of manufactured goods, materials or services with an approximate cost of up to TRY 3,406,508 may be carried out under the negotiated procedure in Article 21(f) of Law No. 4734; a notice is not mandatory in that case, but at least three bidders must be invited to submit their qualification documents and price offers together. For larger volumes the open procedure in Article 19 is the rule.

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• Writing an AI technical specification for public procurement: clause-by-clause examples
• Türkiye's AI Action Plan 2026-2030 and Public Budgets: Using the 2 Percent Share

• Pricing
• Model catalog
• Usage tracking
• API keys