The CUPCCAA bidding thresholds set three tiers for public works projects at California agencies that have opted into the Uniform Public Construction Cost Accounting Act: $75,000 or less can be done by force account with no bidding, $75,001 to $220,000 uses informal bidding, and anything above $220,000 requires full formal bidding. These figures took effect January 1, 2025, after Assembly Bill 2192 codified the increases the California Uniform Construction Cost Accounting Commission recommended.1California State Controller’s Office. New Informal Bid Limit Increase Pursuant to PCC 22032 They come from Public Contract Code Section 22032.
The Three Tiers
- $75,000 or less — force account: The agency can do the work with its own employees, negotiate directly with a contractor, or issue a purchase order. No bidding required.2California Legislative Information. California Code PCC 22032
- $75,001 to $220,000 — informal bidding: The agency follows the informal procedures in Section 22034, notifying qualified contractors and collecting bids without full publication requirements.2California Legislative Information. California Code PCC 22032
- Over $220,000 — formal bidding: Full competitive bidding with public advertisement, sealed bids, and strict notice timelines.2California Legislative Information. California Code PCC 22032
“Force account” is the statutory term for work performed by the agency’s own workforce using its own equipment and materials. For small repairs and maintenance, it is often the fastest path because it skips contracting entirely.
The commission reviews these thresholds under Section 22020, considering whether construction costs have materially changed, and recommends adjustments to the State Controller. Any adjustment takes effect at the start of the fiscal year that begins at least 60 days after the Controller notifies agencies.
How Informal Bidding Works in the Middle Tier
An agency operating in the $75,001 to $220,000 range must adopt an informal bidding ordinance and maintain a list of qualified contractors organized by category of work, such as electrical, plumbing, or general building. Contractors get on the list by submitting their name, address, and license information. Agencies typically refresh the list each year by sending notices to the construction trade journals the commission has designated for their county.3California Legislative Information. California Public Contract Code PCC 22036
When a project comes up, the agency must notify every contractor on the list for that category. Notice can go by mail, fax, or email, and it must reach contractors at least 10 calendar days before bids are due.4California Legislative Information. California Code PCC 22034 The agency can also notify the trade journals designated for its county. The notice must describe the project in general terms, explain how to get details, and state the bid deadline and location.
The governing board can delegate authority to award informal contracts to the public works director, general manager, purchasing agent, or another appropriate person. That delegation speeds routine projects considerably.
How Formal Bidding Works Above $220,000
Projects over $220,000 require sealed bids and broader public notice. Under Public Contract Code Section 22037, the agency must publish notice in a newspaper of general circulation at least 14 calendar days before the bid opening date, describing the project and stating when and where sealed bids will be opened.5California Legislative Information. California Code PCC 22037
The same notice must go to every construction trade journal the commission has designated for the county where the work will happen. That trade journal notice runs on a slightly longer lead: at least 15 calendar days before bid opening. Trade journal notices can be sent electronically by fax or email.
When Informal Bids Come in Above $220,000
An informal bidding process can produce bids that exceed the $220,000 ceiling, and CUPCCAA gives agencies an escape hatch instead of forcing them to start over. If every informal bid received exceeds $220,000, the governing board can pass a resolution by a four-fifths vote to award the contract to the lowest responsible bidder, provided the price is $235,000 or less and the agency’s original cost estimate was reasonable.4California Legislative Information. California Code PCC 22034
That $15,000 cushion above the informal ceiling keeps minor estimating misses from triggering a full formal bidding cycle. The four-fifths supermajority requirement matters, though. A simple majority will not work. If the board cannot reach four-fifths, or if the lowest bid exceeds $235,000, the project has to go through formal bidding.
Emergency Projects Are a Separate Track
When a public facility needs immediate repair or replacement, the thresholds above do not gate the work. Public Contract Code Section 22035 lets the governing body proceed immediately without plans, specifications, working details, or bid solicitation. The emergency work can be handled by the agency’s crew, a contractor, or both.6California Legislative Information. California Public Contract Code 22035 Agencies using the emergency route must follow the additional procedures in Chapter 2.5 starting at Section 22050, which generally require the board to revisit the emergency at each regular meeting and make findings that the emergency conditions still justify bypassing competitive bidding.
The Thresholds Only Apply If the Agency Has Opted In
CUPCCAA is voluntary. An agency cannot use any of these thresholds until its governing board passes a formal resolution electing to follow the uniform cost accounting standards, and then sends written notification to the State Controller’s Office.7California Legislative Information. California Code PCC 22030 Miss either step and the agency stays under the standard competitive bidding rules that apply to all California public works, regardless of project size.
What the Thresholds Do Not Change
Sitting under $75,000 does not exempt a project from California’s prevailing wage laws. Labor Code Section 1771 requires prevailing wage on every public works project over $1,000, a threshold so low it captures nearly every CUPCCAA job, including small force account work.8California Legislative Information. California Labor Code 1771
Contractors and subcontractors must also register with the Department of Industrial Relations before bidding on, being awarded, or performing any public works project. Registration is $400 per fiscal year, with two- and three-year options at $800 and $1,200. Working on public projects without registering carries a $2,000 penalty for the first violation and can disqualify a contractor from all public works for up to 12 months on repeat violations.9California Department of Industrial Relations. Contractor Registration Agencies maintaining a qualified contractors list should verify DIR registration before adding a contractor, because an unregistered contractor cannot legally be awarded a public works contract regardless of how the project was bid.
If federal grant money is involved, the federal procurement standards in 2 CFR Part 200, Subpart D apply on top of CUPCCAA and can be more restrictive than the state rules.10eCFR. Procurement Standards – 2 CFR Part 200 Subpart D Where the two conflict, the stricter rule controls.