What we found ourselves

What we measured

852 of the 4,372 purchases with published bidders (19.5%) received exactly one offer, and all are procedures that exist to produce competition: price competition 522 of 2,781, abbreviated tender 323 of 1,489, public tender 7 of 102. It is the first measurement of its kind on Uruguayan procurement.

Which law it would engage

No law is broken by receiving a single offer. It is the first of the eight risk indicators oversight bodies use worldwide, and what it opens is a question about the tender document, not a case file.

TOCAF, article 33 — defines which procurement procedure applies when.

What is missing before asserting it

Knowing why. A single-offer tender may reflect a market with one capable supplier, a specification written too closely to one product, a short deadline, or nobody hearing about it. Each explanation leads to a different action and none follows from the number.

Who has to answer

Each public body, about its own tenders: whether it re-tendered, reviewed the specification, or asked the suppliers who did not bid.

Read the full investigation → Measured on 2026-08-13 · Re-measure it with: npx tsx tests/unit/competencia-aparente.verify.ts

What we measured

2.4% of award lines since 2023 (28,008 of 1,156,503) carry a unit price of one peso or less. They are not evenly spread: at the Presidency they are 64.5% of its lines and at the state power utility 43.5%, and those lines carry 6,390 million pesos. The practical effect is that in those purchases the unit price stops being a price, and no comparison between bodies is possible: measured without filtering, "integral cleaning of premises" showed a 17-million-fold gap between one body and another.

Which law it would engage

None that is broken on its own: it is not a diversion of funds nor an irregular purchase, it is a way of entering the data. What it breaks is oversight: the published record stops allowing the comparison that justifies publishing it.

TOCAF, article 33, and the publicity regime of the state procurement portal.

What is missing before asserting it

Knowing whether the system allows another way to record a lump-sum service contract. It may be a limitation of the form rather than a decision by the body, in which case the request goes to whoever designs the system, not to whoever fills it in.

Who has to answer

The bodies where the practice is the majority, and the state procurement agency, which defines the record format.

Measured on 2026-08-13 · Re-measure it with: npx tsx tests/unit/sobreprecio-organismo.verify.ts

What we measured

Across awards in pesos from January to July — 69,026 in 2024, 55,792 in 2025 and 37,466 in 2026, deduplicated by ocid — we measured how many fall just below the direct-purchase ceiling and how many just above. One correction has to come first: the corpus stores amounts excluding tax and the legal ceiling includes it, so at the standard 22% rate the 2025 ceiling ($263,000) appears in the database as $215,574 and the 2026 one ($654,000) as $536,066. In the ±1.1% band around the old point the below/above ratio was 0.51 in 2024, 2.98 in 2025 and 1.03 in 2026 — the bunching dissolved — and around the new point it was 0.37 in 2024, 0.69 in 2025 and 3.71 in 2026, with 126 purchases below against 34 above. The result holds across window widths of ±3,000 to ±15,000 pesos (4.40 · 3.76 · 2.93 · 2.38 in 2026 against 0.65 · 0.69 · 0.85 · 0.91 in 2025) and no single body drives it: excluding the Maciel Hospital the 2026 ratio rises to 4.09. Sixteen awards in 2026 land exactly on $536,066; we opened all 16 official records and 11 read «Monto Total de la Compra: $ 654.000,00» to the peso, the other 5 between $653,998 and $653,999, and all 16 are labelled «Compra Directa» (10 belong to the national education council's governing board); in 2025 and 2024 there are none. What we did not find is a stampede towards direct purchase: the band the law opened went from 9.09% of awards in 2025 to 10.40% in 2026 (8.33% to 9.40% without the Maciel), against 8.88% in 2024, and in a random sample of 30 awards from 2026 in the $6,000 just below the point, 27 are direct purchases, 2 price competitions and 1 an exception purchase.

Which law it would engage

No law is broken by what we measured, and it is worth saying so up front: a body buying directly for $654,000 is using exactly the authorisation Parliament gave it. The rule that sets the line is Law 20,446 (National Budget 2025-2029, of 16 December 2025), article 28, which replaces item C) of article 482 of Law 15,903 (TOCAF art. 33 lit. C) and reads, verbatim: «Directamente el monto de la operación no exceda de $ 630.000 (seiscientos treinta mil pesos uruguayos) a excepción de los Gobiernos Departamentales cuyo monto máximo autorizado para la compra directa será de $ 987.000 (novecientos ochenta y siete mil pesos uruguayos) a precios enero 2025». Indexed by the statistics institute, that $630,000 floor at January 2025 prices becomes $654,000 for January-December 2026, which is the figure the procurement agency publishes. The rule that would actually be engaged, and only if the next step confirms it, is a different one: the TOCAF forbids splitting a contract to avoid the competitive procedure its size would require. We did not measure that: we saw repetitions — the Maciel Hospital awarded 7 times to SANYFICO S.A. and the education board 6 times to SAN PEDRO CARRATO MARIO RICARDO, all in the 3% just below the ceiling — but we did not verify that they are one purchase split up, and seven months of hospital purchases from one supplier are perfectly normal.

Ley 20.446 (Presupuesto Nacional 2025-2029, 16/12/2025), art. 28, que sustituye el literal C) del art. 482 de la Ley 15.903 (TOCAF art. 33 lit. C). Amount in force January-December 2026 ($654,000; departmental governments $1,024,000) published by the procurement agency, indexed per the statistics institute's technical bulletin of 30/12/2025 (table «Montos Límites de las Adquisiciones Estatales»). Competent body: Agencia Reguladora de Compras Estatales (ARCE); external oversight: Tribunal de Cuentas.

What is missing before asserting it

Four concrete things, none of which is «let the body explain it». (1) The procurement method is not in the open data: zero of the 42,544 awards from January to July 2026 carry tender.procurementMethodDetails and the merged OCDS record does not carry it either; the «Compra Directa» label exists only in the HTML of each record, and we downloaded 70 records by hand. To say what share of the 3,896 purchases in the band are direct purchases you have to download the 3,896 records, or the procurement agency has to publish the field in the award release: until then the «27 of 30» is a sample, not a rate. (2) The tax conversion is an approximation: we divided by 1.22, correct for the standard rate but not for the 10% reduced rate nor for exempt services, so the real cut-off is not a line but a band ($536,066 at 22%, $594,545 at 10%, $654,000 exempt) and our count of 126 purchases is a floor, not the total; closing it requires each purchase's tax-inclusive «Monto Total de la Compra», which is also only in the HTML. (3) 2026 is an incomplete year in the feed — 37,466 awards in pesos from January to July against 55,792 in the same stretch of 2025, 33% fewer, and one channel is missing —: we normalised proportionally and repeated everything over a panel of the 63 bodies with at least 150 awards in both periods (there the band goes from 5.23% to 9.18%), but we cannot rule out that what is missing is skewed. (4) Whether the repetitions are contract splitting: someone has to read the item detail of the 7 Maciel-SANYFICO awards and the 6 education-board ones and see whether it is one object split or separate purchases. That is 13 records and we did not read them.

Who has to answer

The state procurement agency, for two distinct things: why the procurement method does not travel in the award release of the open data, being the fact that decides whether a purchase was competitive, and whether it is monitoring the effect of the new ceiling, which is the natural counterpart of having raised it. The national education council's governing board, for the direct purchases pinned at exactly $654,000 to the peso: if it is an administrative practice of authorising up to the ceiling, saying so is enough. The Court of Auditors, as external auditor, on whether the jump in the ceiling entered its 2026 oversight plan.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-tope-directa.verify.ts

What we measured

In calendar year 2025 the corpus holds 109,465 releases with an award and a valid amount, worth 178,059 million pesos; 539 of them (11,642 million, 6.5% of the total) carry no supplier at all, and 538 — 11,641 million — belong to the state telecom company: 99.5% of everything it published as awarded that year (11,697 million, the State's third-largest buyer). It is not a hole in our ingestion and it is not new: downloading the agency's official archives (ocds-2021/2024/2025.zip), the government's own data has 593 of 626 records with no winner in 2021, 613 of 615 in 2024 and 587 of 613 in 2025 — the award carries a value and a PDF, but neither suppliers nor items — while the rest of the State adds up to 17, 2 and 1 case respectively. The control closes the question: in the same publication channel (ocid ocds-yfs5dr-i…) during 2025 the state insurance bank publishes a winner in 100% of its 2,806 records, the state bank in 100% of 2,117, Montevideo's city government in 98.1% of 15,457, the state oil company in 97.6% and the water utility in 92.2%; the telecom, in 0% of 587. We opened three official records and the winner is indeed published, but only inside the resolution: i477309 ($781,474,029, exception purchase under art. 33.3, Resol. 1045/2025) and i465874 ($661,791,664) to Compañía Ericsson Uruguay S.A., and i481126 ($366,000,000, public tender P103376/2022, Resol. 371/25) to A y M Santa Lucía Limitada; the procurement pages show the amount and «awarded in full» and nothing else, and the PDF for i477309 is a scanned image with no text layer. Of the 587 resolutions from 2025, 306 are PDF, 256 TXT, 2 ZIP and 23 purchases have no document at all (516 million pesos plus 5.27 million dollars), and there the winner is published nowhere on the agency's site: the largest is i477201, public tender P103975/2023 for $219,600,000, whose record offers no resolution file (we tried .pdf, .PDF, .txt and .zip: 404).

Which law it would engage

TOCAF (Decreto 150/012), article 50, second paragraph, verbatim: «Todas las administraciones públicas estatales deberán dar publicidad en el sitio web de compras y contrataciones estatales, al acto de adjudicación, declaración de desierta o de rechazo de ofertas, a todos sus procedimientos de contratación de monto superior al 20% (veinte por ciento) del límite de su procedimiento de compra directa, incluidos los realizados por mecanismos de excepción, así como las ampliaciones y los actos de reiteración de gastos observados por el Tribunal de Cuentas, en la forma que disponga la reglamentación. Estos organismos contarán para ello con un plazo de diez días luego de producido el acto que se informa». And Law 18,381 on access to public information, article 5 item E, active transparency, verbatim: «Concesiones, licitaciones, permisos o autorizaciones otorgadas, especificando los titulares o beneficiarios de éstos». How they play: for the 564 purchases where the telecom did publish the resolution, TOCAF 50 is probably satisfied — what the rule requires is publicity of the act, and the resolution names the winner — and what is engaged there is art. 5 item E of Law 18,381, identifying the beneficiary rather than leaving it inside a scanned image, plus the agency's OCDS publication policy. For the 23 purchases from 2025 with no supplier and no resolution file at all — all far above 20% of any direct-purchase ceiling, the smallest being $16.1 million — TOCAF article 50 is directly engaged.

TOCAF Decreto 150/012 art. 50 (redacción dada por el art. 58 de la Ley 20.212 de 6/11/2023; fuente: art. 31 de la Ley 18.834). Ley 18.381 de 17/10/2008, art. 5 lit. E. Competent bodies: ARCE (runs the site and the OCDS publication), Unidad de Acceso a la Información Pública (UAIP/AGESIC) under Law 18,381, and the Tribunal de Cuentas, which per the resolutions themselves reviews these awards in advance.

What is missing before asserting it

Five concrete things, none of them a bare «let the body explain it». (1) An answer from the telecom and the agency to one specific question: why the telecom's integration with the procurement system sends header, amount and PDF but not the winner nor the items, since when, and whether they will backfill the 2014-2025 records. (2) Knowing whether the practice is still alive in 2026: we cannot claim it ended, because the 2026 annual archive is only published in January 2027 and our live scraper does not capture the «i…» ids; all we see is that the telecom's structured channel grew (24 awards with a supplier in December 2025, 184 so far in 2026 worth 2,327 million, including an exception purchase of USD 15,280,500 where the record does show «Proveedores participantes: KYNDRYL URUGUAY S.A. RUT 218778790016» and items with unit prices). Someone has to request the 2026 list from the agency or wait for the archive. (3) For the 23 purchases with no resolution (516 million pesos plus 5.27 million dollars), a freedom-of-information request for the award decision and the winner's name in each. (4) To say how much each company took someone has to read the 587 resolutions: we checked 3, and at least one is a scan with no text layer, meaning OCR and human review are needed; today we cannot claim concentration by supplier, only absence of supplier. (5) A warning about our own database, which the story has to carry: our corpus shows an amount of 0 for these pre-2025 telecom records, so our own series understate the telecom in 2014-2024; we measured the 2024 and 2021 amounts in the agency's raw archive, not in our database, and before publishing them the ingestion has to be fixed to read awards[].value when there are no lines.

Who has to answer

The telecom: its contracting division and board, which sign these resolutions, and its public information access unit. The state procurement agency, which runs the procurement site and the OCDS publication: why it accepts award records from a body with no winner and no items, and what it checks on receiving them. Subsidiarily, the public information access unit (active transparency, art. 5 item E of Law 18,381) and the Court of Auditors, which reviews these awards in advance and therefore does know the winners.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-antel-sin-adjudicatario.verify.ts

What we measured

The social security bank (buyer.id 28-1) has 1,457 awarded purchases with wheelchair items between 2016 and 2026, worth 289,630,923 pesos; 1,369 of them (94.0%) and 255,782,057 pesos (88.3%, apportioning the purchases with more than one winner) went to MEDI IMPORT S.A. (tax id 212291040019). These are not bulk purchases: 1,205 of the 1,216 purchases under catalogue code 15230 are for a single chair, and of the 1,125 purchases where the corpus records the method, 1,117 are price competitions (5 direct purchases, 3 abbreviated tenders), a more competitive procedure than the legal ceiling would require of it. Two things run against the finding and belong here: today there is competition and the price fell. Of the 129 tenders where the government record published the «participating suppliers» block, there was a single bidder in 1 of the 65 from 2025 (1.5%) and in 8 of the 64 from 2026 (12.5%), with 2.9 and 2.3 bidders per tender; the second firm by appearances, SAMURIO MOLINA CARMEN YOLANDA, bid 115 times against MEDI IMPORT's 125. And the median unit price MEDI IMPORT charges under code 15230 went from 233,607 pesos in 2022 to 131,148 in 2026.

Which law it would engage

No law appears to be broken, and that comes first: the procedure the bank uses is the legal one and it is more competitive than the minimum required. The resolutions invoke the price competition of TOCAF article 33 item B «en la redacción dada por el art. 314 de la Ley 19.889», and with chairs from 150,000 to 300,000 pesos the bank could buy directly (item C, ceiling $630,000 at January 2025 prices) and opens a tender anyway. What the finding would engage, if it were confirmed that the specifications were written around one importer's catalogue, is the principle in TOCAF article 149, item B, which orders: «Publicidad, igualdad de los oferentes y concurrencia en los procedimientos competitivos para el llamado y la selección de las ofertas». Competitive access is the legal interest at stake, not the legality of the chosen procedure. In the background: the tender document weights price at 45 of 100 points (40 «lowest weight», 15 warranty period, up to −20 for supplier-registry sanctions) and awards «por renglón a la oferta que obtenga mayor puntaje», a legitimate discretionary decision by the body that the bank should be able to justify when the result is 94% of the purchases going to one supplier.

TOCAF (Decreto 150/012), art. 149 lit. B — principios de publicidad, igualdad de los oferentes y concurrencia; art. 33 lit. B y C — concurso de precios y compra directa, topes según Ley 20.446 de 16/12/2025. Reference tender document read in full: Concurso de Precios ODOO N° 2026-28-CR-10383, BPS Gerencia de Salud, sections 1.3, 1.4 and 1.5. Oversight bodies: Tribunal de Cuentas (reviews the expenditure, per the tender document itself, point 5.2) and ARCE. Benefit framework: Reglamento sobre Ayudas Extraordinarias, R.D. N° 3-33/2015 del BPS.

What is missing before asserting it

Five concrete things, none of them a bare «let the body explain it». (1) THE BIDDER HISTORY BEFORE 2025 DOES NOT EXIST IN THE DATABASE: only 129 of the 1,457 purchases have the «participating suppliers» block read, and none is earlier than 2025. So we cannot claim there was less competition before: it is not measured, and not measured is not zero. Closing it requires probing the 2016-2024 tenders with the job that already exists, after checking that no other process is running against the government site. (2) THE PRICES OF THE LOSING OFFERS: the corpus has the winner's price and nothing else, and the agency's online offers are not public; without that one cannot claim MEDI IMPORT wins expensively. It is resolved by reading the award resolutions (all at /Resoluciones/acta_{id}.pdf) or requesting the comparison sheets under Law 18,381. (3) THE PRICE SERIES IS NOT A COMPARABLE PRICE: the catalogue has a single code for every wheelchair, so the fall from 233,607 to 131,148 pesos mixes different models and may reflect a change of mix rather than a real drop. (4) THE 2019-2024 TENDER DOCUMENTS: the corpus holds only 224 of them, all from 2025-2026, so the question of whether the specifications narrowed in some period and widened afterwards cannot be answered without downloading the earlier ones and comparing them. (5) WHETHER MEDI IMPORT IS THE EXCLUSIVE REPRESENTATIVE of the awarded brands (Sunrise Medical/Quickie, Stealth, Leggero, Ki Mobility): it does not say so on its site and we did not find it published; if it is, exclusivity explains almost everything and the finding shrinks to a question about how chairs are prescribed.

Who has to answer

The social security bank — health purchasing section, health division, which runs the tenders. The outpatient care unit, which writes the technical specifications for each chair and signs the assessment that rejects offers. The health administration and control division, the competent officer that signs the award resolutions. And the bank's board, which approved the extraordinary aid regulation R.D. 3-33/2015 and the delegation R.D. 21-2/2023. Secondarily, the state procurement agency, on whether a series of more than a thousand price competitions for one unit each is the right way to buy a recurring benefit, or whether an open supplier register is called for, of the kind the bank itself already uses for compression stockings and CPAP machines.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-bps-sillas.verify.ts

What we measured

Between 23/02/2023 and 14/05/2026 the National Food Institute (buyer.id 15-3, social development ministry) awarded catalogue code 31999 «CANASTA DE VIVERES SECOS» eight times for $193,095,700 before tax (187,400 parcels), and all eight times to the same supplier: DISTRIBUIDORA SANTA ANA S.A., tax id 211603980013. Those eight awards correspond to five procedures — abbreviated tender 15/2023, abbreviated tender 41/2023 (coeliac parcels), public tender 14/2024, exception direct purchase 173/2024 (coeliac parcels) and public tender 1/2026 —; the other three are second resolutions on the same tender, with identical unit prices, worth $58,135,850 (30.1% of the money) and with no new call. There was a competitive call in four of the five procedures and, read on each one's record, between 3 and 5 bidders appeared: 5 in tender 15/2023, 4 in tender 41/2023, 3 in public tender 14/2024, 3 in the exception purchase and 5 in public tender 1/2026. The price of the emergency parcel — with composition identical product by product, 11 items in the same quantities, verified in the 2023, 2024 and 2026 tender documents — fell from $1,179 (February 2023) to $1,066 (September 2024) and to $971 (May 2026) in constant pesos of August 2026, deflated by the indexed unit: 17.6% less in three years. In 2021 that same supply was split between the TA TA and Macromercado retail chains and Santa Ana.

Which law it would engage

No law appears to be broken by what we measured. The only procedure without an open call — exception direct purchase 173/2024, $19,404,000 — invokes in its own tender document «ARTICULO 33 LITERAL D NUMERAL 2 DEL TOCAF», which enables direct contracting «cuando la licitación pública, abreviada o remate resultaren desiertos, o no se presentaren ofertas válidas o admisibles, o que las mismas sean manifiestamente inconvenientes», and requires that «la contratación deberá hacerse con bases y especificaciones idénticas a las del procedimiento fracasado y, en su caso, con invitación a los oferentes originales, además de los que estime necesarios la Administración». All three requirements can be checked from outside: public tender 20/2024 (the same 12,000 coeliac parcels) ended with all offers rejected by Resolution 188/2024 of 29/11/2024; the exception's tender document is titled «COMPRA DIRECTA DE EXCEPCIÓN DERIVADA DE LA LP 20/2024» and repeats the parcel composition item by item (14 products, same net contents); and three bidders appeared (Santa Ana, JUNPOL, SANQUILCO), not one. The other rule engaged, if anyone wanted to question the three second resolutions for the same amount, is TOCAF article 74 on contract extensions, which we could not read verbatim.

TOCAF (Decreto 150/012), art. 33 literal D numeral 2, invoked verbatim in the exception purchase's tender document (pedido_1206642.pdf). Art. 74 del TOCAF for the extensions. Competent bodies: Agencia Reguladora de Compras Estatales (ARCE) and Tribunal de Cuentas de la República (preventive expenditure oversight).

What is missing before asserting it

What is missing is the ability to read three documents that exist but are PDFs scanned without a text layer, and without them nothing can be asserted about the one doubtful stretch. (1) Resolution 188/2024 of 29/11/2024, which rejected every offer in public tender 20/2024 for coeliac parcels: the resolution downloaded from comprasestatales.gub.uy/Resoluciones/acta_1180071.pdf has 2 pages and exactly 1 extractable character, and without that text there is no knowing whether the offers were rejected for technical non-compliance or for a «manifestly inconvenient» price — that difference decides whether paying $1,617 per parcel a month later was the result of a thin market or the endorsement of a price the body had just deemed inconvenient. (2) For the same reason the losing bidders' prices are missing: the corpus keeps only the winner and the opening records are scans (acta_1206642.pdf: 4 pages, 74 characters), so there is no saying whether Santa Ana won by being the cheapest. (3) It remains to be confirmed that the three repeated awards (releases adjudicacion-1034087, adjudicacion-1100868 and adjudicacion-1252900, same unit prices as the original, between 2 and 10 months later) are article 74 extensions and not republications of the same expenditure: the record for purchase 1017145 states in text that «la compra incluyó una ampliación el 10/04/2023 por el mismo monto», but the other two only show a second resolution (175/2023 and 137/2025) on the same tender. If they were republications, the total drops from $193.1M to $135.0M. Besides, 2026 is incomplete in the corpus, so what the parcels represent of the institute's spending that year does not compare against previous years.

Who has to answer

The food institute's supply office and its directorate, on two concrete things: why every offer in public tender 20/2024 was rejected and at what prices, and whether the three second resolutions are article 74 extensions. The state procurement agency, for two publication problems this case exposes: the resolutions deciding awards of this size are published as scanned images with no text, and the OCDS feed lost the buyer in five 2021 parcel awards worth $336,257,896 (releases adjudicacion-856765, -865232, -868514, -893194 and -878322, all with no buyer field) that the government record does attribute to the institute.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-inda-canastas.verify.ts

What we measured

On 21/05/2026 the state procurement portal published award 1315467 by the state power utility (abbreviated tender 103519/2026, provision of staff for driver services, to ESTILO S.R.L., tax id 215529660017) with «Cantidad: 27.000.000,00 UNIDAD» at «Precio unitario sin impuestos: $ 454,29» and a «Monto Total de la Compra: $ 14.964.312.600,00»; our corpus stores it as $12,265,830,000 before VAT. The resolution approving that same purchase — acta_1315467.pdf, Resolution G.R. N°123/26 of 13/04/2026, linked from that very page — says «Valor hora/persona $ 454,29» and «Monto total a adjudicar por el periodo de contratación ITEM 1 Y 2: $ 27.000.000,00 / IVA 22% $ 5.940.000,00 / TOTAL incluido IVA $ 32.940.000,00»: what is published is exactly 454.29 times what was awarded, and 454.29 is the unit price, because the «quantity» field carries the total amount in pesos and the portal multiplies it by the hourly rate. There are 12 utility records from 2026 with that pattern (driver, administrative staff, security, cleaning) worth $29,485,387,226 as published; we downloaded the resolutions of 8 of them: $29,005,044,875 published against $67,278,080 in the resolutions, a factor of 431 and $28,937,766,795 of spending that does not exist. With that, 74% of everything the utility reports having bought in 2026 — $39,221,265,989 across 617 records — is a mis-entered field: corrected it comes to $10,283,499,194 and the utility stops being the year's largest buyer (the state oil company, $12,443,520,232). None of those records is in our anomalies collection: the 1,945 anomalies from 2026 are all price spikes and $454.29 an hour for a driver is a normal price, because our detector scores the unit price and uses quantity only to suppress false positives, never to detect. The utility itself uses the harmless convention in 2026 — unit price 1, quantity in pesos — in 360 lines worth $967,011,833.

Which law it would engage

No law penalises a mistyped number, and it has to be put that way. What is engaged is the duty of publicity: TOCAF (Decreto 150/012) art. 50, verbatim: «Todas las administraciones públicas estatales deberán dar publicidad en el sitio web de compras y contrataciones estatales, al acto de adjudicación, declaración de desierta o de rechazo de ofertas, a todos sus procedimientos de contratación de monto superior al 20% (veinte por ciento) del límite de su procedimiento de compra directa, incluidos los realizados por mecanismos de excepción, así como las ampliaciones y los actos de reiteración de gastos observados por el Tribunal de Cuentas, en la forma que disponga la reglamentación. Estos organismos contarán para ello con un plazo de diez días luego de producido el acto que se informa». What is published has to be the act, and here the act says $32,940,000 and the site says $14,964,312,600. The second point is that the published record, read literally, describes an impossible procedure: it is an abbreviated tender, and the 2026 ceiling is $13,705,000 (art. 33 item A) or $68,525,000 under the extended regime of art. 44 that applies to an autonomous entity like the utility, so what is published ($12,265,830,000 before VAT) is 179 times the extended ceiling. What was actually awarded ($27,000,000) sits comfortably within the ceiling: the purchase is legal, the published figure is the one that cannot exist.

TOCAF, Decreto 150/012, art. 50 (fuente: Ley 18.834 art. 31, en la redacción del art. 58 de la Ley 19.889). Ceilings: statistics institute, «Montos Límites de las Adquisiciones Estatales, Enero–Diciembre 2026» (30/12/2025, under Ley 20.446 of 16/12/2025), item h) abbreviated tender $13,705,000 and item i) extended abbreviated tender art. 44 $68,525,000. Body competent over the system where the datum was entered: Agencia Reguladora de Compras Estatales (ARCE), owner of the SICE. Expenditure reiteration: TOCAF art. 114.

What is missing before asserting it

Four concrete things, none of them «let somebody explain it in general». (1) That the procurement agency answer whether the system has a field for «amount awarded» when a purchase is awarded by amount rather than by quantity — the resolution says «12 meses … o hasta agotar el monto adjudicado, lo que ocurra primero» and payment is by hours actually worked — and what the current instruction is for that case; without it we do not know whether the utility's operator improvised or followed the only way out the form offered. (2) That the agency say whether it will correct the 12 records and regenerate the OCDS feed, or whether the figure stays published: today anyone downloading the 2026 open data takes away the $28,937 million that do not exist. (3) Whether the official 2026 procurement statistics the agency publishes are computed from that same field, because then the official figure for the year's state spending is inflated too; that is asked through a freedom-of-information request, not by observation. (4) We are missing 4 of the 12 records in the class (adjudicacion-1103510, 1103395, 1158012 and 1335094): we did not download their resolutions, which is why the figure we publish is the one for the 8 verified. And one more piece of honesty: the resolution sets a spending cap, not an execution, so we do not know how much the utility actually paid ESTILO S.R.L. and we do not assert it. The percentages against the 2026 national total also carry the warning that the year is distorted in the feed.

Who has to answer

The state procurement agency, owner of the procurement system, which computes and publishes the «Monto Total de la Compra» and produces the open-data feed: it falls to it to say whether the system allows entering an awarded amount without inventing a quantity, and whether it will correct the records. The power utility, purchasing and contracting sub-management and the supplies and services division — the requesting unit the resolution itself names —, which entered the datum and which in 2026 uses both conventions at once. As context and not as a complaint: the Court of Auditors' delegate accountant at the utility already intervened in this purchase — flagging the expenditure for lack of budget availability, which the utility reiterated by Resolution G.R. N°124/26 under TOCAF article 114 —, meaning the oversight chain worked on the correct figure. The only place the $14,964 million appear is the publication.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-ute-choferes.verify.ts

What we measured

Across 212 public bodies with at least 300 awards between 2019 and 2025, the median signs 0.10% of its purchases with a resolution date of 31 December, and the 97th percentile reaches 1.56%. The Dirección General Impositiva, the tax office, signs 13.03%: 215 of 1,650 awards, and 472 of 1,807 million pesos, 26.1% of its money. The second body on the list stands at 4.64%. Within the tax office's own Decembers, 215 of 465 awards — 46.2% — fall on the 31st; across the rest of the State that share is 2.33%, and December is, on the national average, the month in which the LEAST is resolved on the last day of the month: 2.63%, against 3.08% to 4.93% for the others. We went to see what those 215 records are on the state procurement portal, one by one: 201 of the 215 — 93.5% — carry the «Ver Compra Original» banner, meaning they are extensions of an earlier purchase. What is being extended is an abbreviated tender in 92 cases, an exception purchase in 59, a public tender in 34, a price competition in 10 and a direct purchase in 6: 59 of those 201 extensions prolong a procedure that had already avoided competition. In a control group of the tax office's 100 largest awards that do not carry that date, the extensions number 18. The administrative explanation covers a good part of this and comes before any other reading: service contracts run from 1 January to 31 December, next year's extension has to be resolved before the fiscal year closes because the budget credit that pays for it dies with the year, and 31 December is the last day on which it can be signed. The data points that way: suppliers repeat year after year, and INFOTECH appears for the same amount, US$ 280,600, in 2022, 2023 and 2024. That is the shape of a contract renewal. Two things fall outside that explanation. The first is that the share of the annual value resolved on 31 December went from 7.3% in 2019 to 15.6%, 22.0%, 29.2%, 37.7% and 46.6% in 2024, whereas a stable portfolio of annual contracts would give a stable share. The second is that those resolutions are published with a median delay of 52 days: 142 of the 215 take more than a month, 34 more than six months and 14 more than a year, with a maximum of 1,120 days, while the rest of the tax office's own resolutions are published the same day or the next, and those of the rest of the State the next day. It is the same body, the same system and the same publication channel. Measurement details: the date used is the resolution date (the «Fecha Resolución» field of the official record, `awards[].date` in the feed), present in 789,454 of the period's 793,956 awards; the histogram by day of the year shows everything rests on a single day, with 215 records on 31/12 and 24 on 26/12, the next busiest; and the series is read up to 2024, because in 2025 the tax office shows 2 records dated 31 December and, with a 52-day median delay, those resolutions land in the following year's feed, which in 2026 is incomplete because one channel is missing.

Which law it would engage

None. Resolving a purchase on 31 December breaks no rule, and extending a contract does not either: the TOCAF allows it and, for a service starting on 1 January, 31 December is the last possible date to sign the extension. What the date reveals is not an infringement but a sequence: the tax office contracts the same supplier again by extending an earlier tender instead of returning to the market, and it does so on the day the fiscal year closes. Two rules would be engaged: the one setting how far an awarded contract may grow before it stops being an extension, and the one defining when an exception purchase applies, because some of these extensions prolong precisely an exception. That is settled contract by contract, comparing the original amount against the accumulated extensions, and it is not settled with the date.

TOCAF (Decreto 150/012), art. 33: defines which procedure applies according to the amount and which are the grounds for exception to tendering. TOCAF, art. 74, on increasing contracted services: contracts may be increased «hasta un máximo del 20% (veinte por ciento)» of their original value and, with the awardee's agreement and under the same pre-established conditions, «en ningún caso los aumentos podrán exceder el 100% (cien por ciento) del objeto del contrato» (impo.com.uy/bases/tocaf2012/150-2012/74). For these cases we did not measure how much each contract accumulated: the record of an extension does not publish the running total, so the figure is neither on the portal nor in the feed.

What is missing before asserting it

Four things, and two of them are preconditions for publishing. (1) The prior-press-coverage check, which is not complete: the session in which this was measured ran out of its search budget and the alternative engines returned CAPTCHAs. What we did verify is that the site's own curated news collection has nothing on this, and that our corpus of cases and investigations mentions the tax office only in passing and never as a buyer; before publishing, one must search «DGI ampliación contrato», «DGI licitación informática» and the suppliers' names (ATEL, GXC, INFOTECH, SEVITEC, PULSO) in Búsqueda, la diaria, El Observador and Montevideo Portal. (2) The contract-by-contract verification of the accumulated extensions against the original amount: it is the only thing that can say whether any of these extensions exceeded the ceiling of art. 74, and that figure has to be requested because it is not published. (3) The tax office's answer: there may be a documented administrative explanation — for instance, that extension resolutions are signed in a single year-end act — that reduces the finding to a one-line note, and nobody has asked yet. (4) The years 2025 and 2026: the series is comparable up to 2024 and must be shown that way, because of the 52-day publication delay and the missing channel in the 2026 feed.

Who has to answer

The Dirección General Impositiva, the tax office: why 93.5% of what it resolves on the last day of the fiscal year are extensions of earlier purchases, and why the share of the annual value resolved on that day went from 7.3% to 46.6% between 2019 and 2024. And the state procurement agency, which runs the portal where those resolutions are published: why a resolution dated 31 December can take six months — and in fourteen cases more than a year, with a maximum of 1,120 days — to become public, when the same body's other resolutions are published the same day or the next.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-dgi-31dic.verify.ts

What we measured

Between 2020 and 14 August 2026, 3,732 exception purchases were awarded — the art. 33 TOCAF route for not tendering — for 27,048 million pesos: 5.6% of the money whose purchase method can be identified, and more than the 14,616 million of all ordinary direct purchasing, with 3,732 contracts against 126,844. That total is always shown alongside another: without the largest record (a purchase by the state bank BROU from ATEL, 6,037 million, 55,000 hours at US$ 2,740.93 an hour, a price we did not verify and which may be a peso amount labelled as dollars) the total falls to 21,010 million. Most of that route is not discretionary, and this comes before any other reading. We read 609 official records, one by one: a census of the 120 awards of 20 million or more, plus some 70 drawn at random per year. The most frequent ground, 31.7% of the records, is item 26: purchases the health ministry makes in compliance with court decisions, of medicines and devices not on the therapeutic formulary. That explains the route's largest user, the national health directorate, and the four suppliers that concentrate their billing there, all of which sell medical devices to that same body. The second ground, 19.9%, is item 33: the schools authority maintaining teaching premises. And the one that moves the most money in the census, 42.4%, is item 2: the tender was held and no bids came in. What is not in the open data is the ground. The OCDS field that exists for exactly this, `tender.procurementMethodRationale`, is empty in all 2,184,332 records of the corpus, and so are `tender.legalBasis`, `tender.rationale` and `tender.procurementMethodJustification`. Each purchase's HTML record does print the item number and its legal text: in the 609 we opened it was always published, 584 citing an item of art. 33 and 25 citing another law. There is no way to count the country's urgency purchases without opening pages one at a time. Urgency appears where it is expected and in the proportion that can be measured: only 30 of those 609 records, 4.9%, invoke urgency (art. 33, letter D, item 10), and only 5 of the 120 large awards, for 320 million, 1.7% of that money. The health emergency did not come through here either: of the 204 tender documents from 2020 that name covid, coronavirus, pandemic or health emergency, 172 are direct purchases and only 12 are exception purchases, and 2020 is the year with the lowest exception spending of the whole series, at 918 million. Nor does the word «emergencia» or «urgencia» in the tender text identify the procedure: it appears in 1,466 of 269,788 tender documents since 2020 and describes the thing being bought — emergency medical cover, an emergency door, a resuscitation trolley — not the route. One open fact remains, and it is the same size as the rest. In 2025 the state telecoms company ANTEL concentrated ninety-nine exception awards worth 6,456 million — 23.9% of all exception money in the period — with no awardee either in the open data or on its public record: those purchases reach the feed as a tender with an amount and an empty supplier list, and the five records we opened show neither the participating-suppliers block nor the awarded-items block, only the amount. At least four of them invoke item 5, «obras de arte, científicas o históricas»; among them a three-year VMware licensing purchase, US$ 11,344,906, record 105286/2024. That item has a tail reading «o deban confiarse a empresas o personas especializadas o de probada competencia», so a licence renewal can be framed there even though the heading speaks of works of art.

Which law it would engage

What is at stake is not an illegality in the purchases but the duty to state reasons and to publish them. The TOCAF requires that the ground for exception be justified «en forma detallada» and be «un aspecto sustancial en la motivación del acto»; for urgency it further requires prior certification by the finance ministry as to the ground being met and as to market prices. That justification exists — each purchase's HTML record prints it — but it does not travel to the open data, even though the OCDS standard Uruguay chose to publish has the exact field for it and it is empty in all 2,184,332 records. We verified no rule specifically obliging the ground to be carried into the OCDS feed, so this is a data-policy gap and not a violation. The 99 ANTEL awards worth 6,456 million with no published awardee are a different matter: there it is fair to ask under what rule the winner's name appears neither in the open data nor on the record.

TOCAF (Decreto 150/012), art. 33, letter D, item 10, verbatim: «Cuando medien probadas razones de urgencia no previsibles o no sea posible la licitación, concurso de precios o remate público, o su realización resienta seriamente el servicio, extremos cuya invocación deberá fundamentarse en forma detallada, constituyendo un aspecto sustancial en la motivación del acto que dispone el procedimiento de excepción» (impo.com.uy/bases/tocaf-tcr/150-2012/33). Item 5, the one invoked by ANTEL: «Para adquirir, ejecutar, restaurar, transportar, montar obras de arte, científicas o históricas, cuando no sea posible el concurso de méritos o antecedentes o deban confiarse a empresas o personas especializadas o de probada competencia». Item 26, the most frequent: «Las compras que realice el Ministerio de Salud Pública, en cumplimiento de decisiones jurisdiccionales, de medicamentos o dispositivos terapéuticos no incluidos en el Formulario Terapéutico de Medicamentos ni en los programas integrales…». The requirement of prior finance-ministry certification for item 10 is published by the procurement agency in its own manual and attributed to Decreto 90/000, art. 11: we took it from the agency's documentation and did not verify the original text. Open Contracting Data Standard 1.1, field `tender.procurementMethodRationale`.

What is missing before asserting it

Five things. (1) The count of grounds is a sample and not a census: we read 609 of the roughly 3,750 exception awards with an amount, and to publish a firm national percentage one must read the remaining 3,150, which is about an hour of reading at one request per second and where extraction works 100% of the time. The script accompanying this card redraws 60 records every time it runs, so that the shape of the distribution can be checked without redoing the census. (2) The largest record (BROU-ATEL, 6,037 million, 22% of the total) has 55,000 hours at US$ 2,740.93 an hour; the official record reproduces that multiplication, but the price looks like a peso amount labelled as dollars — 2,741 pesos an hour is about US$ 62 — and it has to be confirmed against the minutes before using the 27,048 million total, which is why the total without that record, 21,010 million, is shown as well. (3) The PDF minutes of ANTEL's 99 purchases from 2025 still have to be opened to learn who collected the 6,456 million, and it must be asked whether the absence of the awardee is a publication rule for bodies operating in competitive markets or an error. (4) The finance ministry's certifications for the 30 purchases with an urgency ground still have to be requested under the access-to-information law: without them nothing can be said about whether urgency was properly invoked. (5) The known null-currency error does not appear in this set — every row carries a declared currency — but part of the amount is in dollars and depends on the exchange rate applied.

Who has to answer

The state procurement agency, which publishes the OCDS feed and which prints the ground on the HTML record: why the `tender.procurementMethodRationale` field of the standard it chose goes empty in 2,184,332 records, and whether it intends to fill it. ANTEL: why its 99 exception purchases of 2025, worth 6,456 million, show no awardee either in the open data or on the public record, and on what criterion it framed the VMware licensing purchase of US$ 11,344,906, record 105286/2024, under item 5 — «obras de arte, científicas o históricas». And the Ministry of Economy and Finance: how many of the item-10 urgency purchases arrived with the prior certification the State itself requires.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-excepcion-motivo.verify.ts

What we measured

First of all, what this angle does not show. The largest cases by money in our own measurement collapse on opening the official record: the top ones are oncology medicines that the national health directorate buys dose by dose and patient by patient — 2 vials of pembrolizumab, 56 tablets of axitinib — and the State's page declares them «Compra por Excepción» (art. 33, letter D), a figure that has no ceiling, so there is no ceiling to dodge; another is the professional stamp duty, which we have already published; and the social-security institute's wheelchairs are, in the two records we opened, «Concurso de Precios», a competitive procedure. Publishing that raw ranking would be telling a different story. The measurement: since 1 January 2024 there are 578 combinations of public body, supplier and article with six or more separate purchases of the same article within 15 days, all of them below that year's direct-purchase ceiling; 156 of those combinations reach ten or more. Those windows hold $302 million awarded, and $2,732 million adding up every purchase of those 578 pairs since 2024. Three cases survive verification against the official record. The first is the state health provider ASSE. The Bella Unión auxiliary hospital awarded, on 9 July 2026, twelve direct purchases to the same provider, the Sociedad Médico Quirúrgica de Salto, with consecutive numbers between 10813 and 10830/2026. They add up to $7,122,915 including tax; nine of the twelve fall between $640,000 and $654,000, and three are exactly $654,000, which is the legal maximum for a direct purchase in 2026. The explanation the record itself suggests is in plain sight: the hospital has no trauma service, it operates on its patients in a private clinic in Salto, and each record is a different procedure — open reduction of a bone fracture, major osteosynthesis with external mini-fixators — on a different patient, so it enters as a separate purchase. The price on the same day varies between $353,146 and $654,000, so it cannot be asserted that the amount was set by the ceiling rather than by the complexity of each operation. The second is DINACIA, the civil aviation authority. Between 2019 and 2024 it contracted the cleaning of its premises with one annual purchase — the last, $8,193,349 including tax, an extension of Public Tender 10/2022 — and since 28 August 2025 it buys it month by month and site by site: 22 direct purchases, several of them for exactly $263,000 including tax, which is the 2025 ceiling. The usual administrative explanation is that the annual contract ran out and the service cannot be cut off while the new tender is being processed. The third is the child-welfare institute INAU. Its Paysandú departmental office awarded, on 22 December 2025, five direct purchases to the same supplier for building maintenance, $1,060,420 in total, four of them between 96.1% and 99.8% of the ceiling. There is a methodological by-product worth having on its own: this check is impossible with the open data. The award release does not carry `tender` — zero of all those reviewed — and in a random sample of 300 award ocids only 71 have a sibling release with the method, so the type of procedure is not in the feed; and the feed publishes amounts excluding tax while the ceiling is measured including tax, so purchase 1281409 appears with $215,574 in the feed and $263,000.00 on the official record. To know whether a purchase sits at the ceiling one has to open the record one at a time: we opened 42. Moreover, the burst is measured on the resolution date and not on the release date: in a random sample of 60,000 releases only 33.1% share a day, and measured on the release date large false positives appear that are bulk loads of the feed. Nothing measured shows that anyone split a purchase. That judgement belongs to the spending officer and to the audit court, and it requires the files, which are not published. On the same buyer there is prior coverage that did not come from our measurement: El País reported on 29 June 2025 that ASSE pays $280,000 for each specialised medical transfer by private ambulance from Bella Unión to Montevideo — another supplier and another angle, the price rather than the splitting — and that pair also appears in our ranking. LaRed21 reported on 8 June 2026 on direct contracting at the Salto departmental government.

Which law it would engage

TOCAF (Decreto 150/012). Art. 33, letter C sets the ceiling for the ordinary direct purchase, which the statistics institute updates each year by inflation (art. 156). Art. 32 establishes that splitting a purchase artificially so that the operation fits within certain limits is a serious offence. The rule would only be engaged if it were confirmed that the contracted object was a single one and that it was split to avoid the competitive procedure its amount required: twelve direct purchases on the same day for $7.1 million from a single provider would amount, taken as a single contract, to an abbreviated tender ($13,705,000 ceiling in 2026, with a price competition mandatory above $1,371,000); DINACIA's $263,000 monthly cleaning per site amounts to several million a year, which is what used to be contracted by public tender. Nothing measured proves that condition on its own: the TOCAF itself requires the splitting to be artificial, and that judgement belongs to the spending officer and the audit court, not to the data. The exception purchase, by contrast, has no ceiling, which is why the national health directorate's cases fall outside this analysis.

TOCAF, art. 32: «La comprobación de que se fraccionare el gasto artificialmente para que la operación encuadre en determinados límites será considerada falta grave a efectos de las sanciones que correspondan». Ceilings in force according to the statistics institute, «Montos Límites de las Adquisiciones Estatales», art. 33 letter C: 2024, $251,000 (other public bodies) and $940,000 (departmental governments); 2025, $263,000 and $987,000; 2026, $654,000 and $1,024,000 (Ley 20.446 of 16/12/2025). Extended direct purchase (art. 44): $1,254,000 in 2024, $1,317,000 in 2025, $1,371,000 in 2026.

What is missing before asserting it

The files, in all three cases. For Bella Unión: the detail of the invoices the twelve purchases regularise — how much they came to, how many operations — and whether they correspond to twelve distinct surgical procedures or to instalments of a single debt; the official record names neither patients nor surgery dates. For DINACIA: whether a tender was under way between August and December 2025 and at what stage, and whether the monthly purchases correspond to different sites; the official record says only «LIMPIEZA INTEGRAL DE LOCALES» and the amounts repeat identically month after month without identifying the place. For INAU: what works each of the five same-day purchases covered. In all three it remains unknown whether the audit court formally objected to this spending: the objection lives in the file and in the court's PDF, not in the feed, so we can never write that the court objected to something on the basis of the data. And the prior-coverage check still has to be closed: the search budget ran out halfway through, and the check was done via Google News RSS in Uruguayan Spanish without sweeping the archives of Búsqueda, la diaria or Brecha; before publishing it must be redone with the exact names: «Sociedad Médico Quirúrgica de Salto», «DINACIA limpieza», «INAU Paysandú mantenimiento».

Who has to answer

ASSE, the management of the Bella Unión auxiliary hospital and its purchasing department: for the twelve direct purchases of 9 July 2026 and for the accumulated volume with that same provider since 2024. DINACIA, of the Ministry of National Defence: for the shift from an annual public tender to 22 monthly direct purchases between August and December 2025. INAU, Paysandú departmental office: for the five purchases of 22 December 2025. And the Tribunal de Cuentas de la República, the audit court: whether any of this spending was formally objected to. The request for comment from all three bodies goes inside the story.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-directas-mismo-dia.verify.ts

What we measured

The OCDS feed publishes awarded items under two classification schemes. One, `x_catalogo_arce`, carries the article code from the SICE catalogue (for instance 6194, SERVICIO DE SANITARIA). The other, `x_ODG` (object of expenditure), always carries the code «0» — that is, none — and only free text. Between 2016 and 2025 the State awarded $1,275,483 million; of that, $697,006 million — 54.6%, across 214,230 records — carry no article code on any of their lines. Two thirds of that block is ANCAP, the state oil company: $467,433 million, 67.1%, almost all of it crude and fuel purchases. And there the explanation is complete: a cargo of «CRUDO BONNY LIGHT» or «CRUDO WTI MIDLAND» is not a catalogue article, it is paid against the day's Brent or WTI and not against a history of Uruguayan purchases, so coding it would enable no comparison. The same, to a lesser degree, holds for the power company's diesel and for the turnkey works of the water and ports authorities, where the «article» is an entire project. Discounting ANCAP, $229,573 million remain without a code, 18.0% of everything awarded in the decade, and that is the figure that does not have that explanation. The route is institutional and not a data-entry oversight: no record mixes the two schemes — either everything is coded or nothing is — and only 9 public bodies use `x_ODG`: ANCAP (99% of its own spending), the water authority OSE (99%), the ports authority ANP (100%), the Canelones departmental government (100%), the Montevideo city government (89%), the power company UTE (56%), the state insurer BSE (50%), the state bank BROU (14%) and the central bank BCU (2%). They are autonomous entities, decentralised services and two departmental governments, with their own systems connecting to the feed through a different pipeline from the central administration's procurement system. The description is published all the same and is often specific («SULFATO DE ALUMINIO LIQUIDO», «CRUDO QUA IBOE», «ÁCIDO SULFÚRICO»). The proportion was not always like this: it went from 0.3% of the money in 2014 and 1.5% in 2015 to 33.8% in 2016, 48.0% in 2019 and 60.0% in 2020, and stayed near that level up to 2025 (53.1%). Where the explanation stops holding is in the labels that are not commodities: the state bank's «NO CATALOGADO» appears on 14,424 lines, and «RUBROS GLOBALES», «RUBROS UNITARIOS», «LL SS» and «IMPREVISTOS» from the water authority, the Montevideo city government and the ports authority take up entire purchases under a heading that does not say what was bought. The free text does not aggregate either: between 2020 and 2025 there are 156,910 distinct descriptions for 348,466 lines under `x_ODG`, and 72.0% appear only once, against 22.3% on the catalogued side. We do not publish an amount per label because the amount lives on the record and a single purchase carries several of those labels at once: attributing the total to each would inflate them all. The consequence is measurable and is not an insinuation: the price-baseline collection holds 40,829 entries and not one for the code «0». A line without a code cannot be compared against any reference price, by construction. Half of the State's money is incomparable, not because of us and not because of anyone. Two more things, and one is about us. The hypothesis we started with — that generic articles of the «other» or «miscellaneous» type were absorbing large amounts inside the catalogue — was ruled out: they are 20 codes and $232 million, 0.04% of coded spending. The catalogue is specific; what does not pass through it is half the money. And our own products page is built on a rollup that excludes that block, calling it a «junk sentinel», without telling the reader it leaves out more than half of the spending. That warning goes on the products page the same day as this card. One last limitation: 2026 falls outside the whole series because that year the feed carries a null classification scheme on 100% of the lines, so it is not comparable.

Which law it would engage

No rule is clearly broken, and it is worth saying that before anything else. The only provision engaged is art. 331, item 4 of Ley 19.889, which creates the state procurement agency and charges it with «desarrollar, publicar y coordinar con las diversas entidades estatales, la efectiva aplicación de un catálogo único para la adquisición de bienes». Two important limits: the obligation falls on the agency — to coordinate effective application — not on each public body as a sanctionable duty to code every line; and the text speaks of «bienes», goods, not of services or works, which is where much of the uncoded block is concentrated. The agency itself maintains on its site that since that law came into force the catalogue of goods, services and works applies to all state public administrations, but that is an administrative interpretation and not the legal text. What the data measures, then, is not a breach: it is the degree of effective application of a catalogue the law charges the agency with making effective, and which over half the money is not.

Ley N° 19.889 of 9/7/2020 (Ley de Urgente Consideración), «Compras Públicas» section, chapter IV «Creación de la Agencia Reguladora de Compras Estatales», art. 331 item 4: «Desarrollar, publicar y coordinar con las diversas entidades estatales, la efectiva aplicación de un catálogo único para la adquisición de bienes» (impo.com.uy/bases/leyes/19889-2020/331). The agency's interpretation on its «Reestructura del catálogo» page, on gub.uy: «A partir de la vigencia de la Ley 19.889, el catálogo de Bienes, Servicios y Obras es de aplicación para todas las Administraciones Públicas Estatales». General framework: TOCAF and the agency's powers, arts. 329 to 339 of the same law.

What is missing before asserting it

Four things, all answerable in writing. (1) What `x_ODG` is: whether it is a foreseen and accepted publication mode, a technical limitation of each body's integration, or a granted exception; the data does not distinguish between the three, and they are three different stories. (2) Whether the code exists internally and is lost on export, which is the hinge question: if ANCAP, the water authority or the Montevideo city government classify internally and the code does not travel to the OCDS, it is a publication problem; if it never existed, it is a procurement-management problem; from the database it cannot be known, because we only see what the feed brings. (3) What the non-commodity labels cover: «RUBROS GLOBALES (I, II, III)» and «RUBROS UNITARIOS» from the water authority, «LL SS», and the state bank's «NO CATALOGADO» on 14,424 lines; there no international-market explanation is possible and each one's tender document is needed. (4) The 2016 break: the jump from 1.5% to 33.8% of the money between 2015 and 2016 looks like new bodies joining the feed through a different route, or a change in the exporter, and it has to be confirmed against the agency's integration history before being read as a deterioration. A limitation of our own: 2026 falls outside the whole series because that year the feed carries a null classification scheme on 100% of the lines, so it is not comparable. And what depends only on us is still missing: saying on the products page what share of the spending is not there.

Who has to answer

The state procurement agency, first of all, because the law charges it with the effective application of the single catalogue and it runs both the procurement system and the OCDS publication: why 54.6% of the money awarded between 2016 and 2025 is published under the `x_ODG` scheme with no article code, whether that is foreseen, and whether there is a plan to map it. The four bodies with the highest share of their own spending — ANCAP (99%, $467,433 million), the water authority OSE (99%, $89,838 million), the ports authority ANP (100%, $19,391 million) and the Canelones departmental government (100%, $20,679 million) — each of them: whether they classify their purchases internally with the catalogue and the code does not reach the open data, or whether they simply do not use it. The water authority, on what «RUBROS GLOBALES (I, II, III)» comprises; the state bank, on what «NO CATALOGADO» means across its 14,424 lines; and the power company, on why 56% of its spending goes without a code when the other 44% does use the catalogue, being the same body and the same system. And ourselves: our products page is built on a rollup that discards that block, calling it a «junk sentinel», and never told the reader they were looking at less than half of the State's spending. The warning goes on that page, and this card is not published before it.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-sin-codigo.verify.ts

What we measured

We worked on the 1,638 award lines of catalogue code 41238, BREAST ULTRASOUND, between 2007 and 2026. All 1,638 are in pesos, so the null-currency trap does not apply. We excluded 6 lines with a unit price of 20,000 of today's pesos or more — whole agreements entered into the unit-price field — and 29 lines with a unit price of 250 or less, which are professional stamp duties filed under this code: the stamp's legal value is 170 in 2026 and 160 in 2025. That leaves 1,603 lines. In 2026 there are 126 clean lines across 12 buying units: the median for the same scan runs from 875 pesos at the Pando auxiliary centre to 3,087 at the Florida departmental centre, 3.5 times. The spread holds with the same seller. GASTROCLINICA S.R.L. (tax id 213506820011) sold code 41238 to seven units of the public health service in 2026: 875 in Pando, between 2,290 and 3,105 in Rocha, 2,290.7 at the San Carlos hospital, 2,460 at the Colonia primary-care network, between 2,405 and 3,105 at the San José primary-care network, 3,105 in Florida and 3,105 at the Cerro hospital. Same firm, same code, same year, same currency. It is not only the breast scan: for adult abdominal ultrasound (code 104040) the 2026 median runs from 831 in Pando to 2,460 at the Colonia network and 4,097 in Rocha; for soft tissue (104048), from 875 in Pando to 2,290 in Rocha and 2,460 in Colonia; for testicular (42807), from 796 in Pando to 2,405 in Rocha. The price moves within a single unit too: Pando paid 2,524 in 2024, 2,345 in 2025 and 875 in 2026, in nominal terms and for the same scan, 65% less in two years; Rocha went the other way, from 750 in 2021 and between 950 and 1,248 from 2022 to 2025 to 2,290 in 2026, on changing provider. The shape of the purchase: of the 180 sibling tender documents from 2024 to 2026, 168 are direct purchases, 93%; and of the 109 ocids with a 41238 line in 2026, only 13 have any tender release at all. We checked both ends on the State's own page. Pando, purchase 1312418: direct purchase, GASTROCLINICA S.R.L. tax id 213506820011, 63 breast ultrasounds at 875 pesos before tax. Rocha, purchase 1310750: direct purchase, the same firm and the same tax id, 18 breast ultrasounds at 2,290 pesos before tax, with a single participating supplier. Neither record mentions a radiologist's report. The competing explanation goes here: volume and bundling, in a system decentralised by design. The 875 in Pando is one line inside a contract that in 2026 bought thousands of scans across the whole ultrasound menu from GASTROCLINICA; the 2,290 in Rocha comes out of dozens of direct purchases of about three scans each. A supplier quoting differently for guaranteed volume is ordinary economics. On top of that, the health service's purchasing is decentralised by executing unit: there is no single price, there are twelve departmental markets with different costs, distances and availability of sonographers, and Rocha's previous provider was an individual professional, without a company's cost structure. Two facts limit that explanation. The Colonia primary-care network bought more scans from the same firm than Rocha did, and through an abbreviated tender — that is, through the competitive procedure — and pays 2,460, more than either. And Pando itself was paying 2,524 in 2024 and 2,345 in 2025 before dropping to 875 in 2026, with no change in the scan.

Which law it would engage

The general rule for State purchasing is the competitive procedure; the direct purchase is the exception. Under this code, 93% of the sibling tender documents from 2024 to 2026 are direct purchases, and the Rocha purchase we verified lists a single participating supplier. The second rule engaged is the one that forbids splitting expenditure so that each operation fits under the direct-purchase ceiling: Rocha bought more than a hundred breast ultrasounds in dozens of separate purchases, from the same supplier, over the year. A necessary clarification: we did not measure whether any unit exceeded the direct-purchase ceiling. The ceilings are updated every year and we did not check them against each executing unit's aggregate. The pattern of repeated purchases from the same supplier is a question, not an accusation, and the word «fraccionamiento» is not used here as an assertion.

TOCAF (Decreto 150/012), art. 33: «Las contrataciones se realizarán mediante licitación pública u otro procedimiento competitivo expresamente previsto...». TOCAF, art. 32: «La comprobación de que se fraccionare el gasto artificialmente para que la operación encuadre en determinados límites será considerada falta grave...». Consulted in the TOCAF published by the state procurement agency (comprasestatales.gub.uy/ManualesDeUsuarios/manual-procedimiento-compras/TOCAF.html) and on IMPO (impo.com.uy/bases/tocaf2012/150-2012/33). Competent bodies: the public health service as the spending authority, the Court of Auditors as external control.

What is missing before asserting it

What each price includes. The feed does not describe the service: we do not know whether Rocha's 2,290 includes the radiologist's report, the sonographer's travel, on-call or emergency cover, and Pando's 875 does not. The only documentary clue points against the report explaining the expensive end — the one buyer whose tender documents state verbatim that the report is included pays 1,916, below Rocha, Flores, Florida and San Carlos — but it is a single buyer, and it is settled with the tender documents and purchase orders, not with the feed. Whether other prices were sought in Rocha: purchase 1310750 appears as a direct purchase with a single participant, and in 96 of the 109 ocids of 2026 there is no tender release at all, so we can assert that no public record was left of other prices being sought, not that they were not sought. The direct-purchase ceiling per executing unit, which we did not check. Whether GASTROCLINICA delivers the service with a different structure in each department — its own equipment in one place, subcontracting in another — which is the explanation the feed cannot measure. 2026 is incomplete: it is January to August, and this year is missing a feed channel; the 2026 levels hold (126 clean lines, 12 units, both ends verified on the State's site), the annual total of scans does not. And every amount is before tax, because the OCDS feed does not carry the tax-inclusive total: both ends of the comparison are on the same basis, so the ratio between them is unaffected, but no figure here is a final price. A method warning for anyone repeating this: the same tax id lives in the feed under two identifiers, «R213506820011» and «R/213506820011»; filtering by only one loses 82 or 149 of the supplier's 231 lines depending on which you pick, and grouping by name never works.

Who has to answer

The public health service's procurement directorate, and the directorates of the executing units involved: the Rocha departmental centre, the Pando auxiliary centre, the Florida departmental centre, the Cerro hospital and the Colonia primary-care network. The questions: why the same firm charges 875 in Pando and 2,290 in Rocha for code 41238 in the same year; what each price includes and whether the radiologist's report is in or out in each case; why Rocha bought more than a hundred scans in dozens of separate direct purchases instead of an annual contract like Pando's; and whether the service has or intends to have a central reference price for outsourced imaging. GASTROCLINICA S.R.L. (tax id 213506820011), to explain the price difference between departments.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-ecografia-precio.verify.ts

What we measured

We measured budget line 15 in full — the five executing units of the Ministry of Social Development — between 2021 and 2026, and the other thirteen ministries with the same rule. We attribute the money per award: each one gets the share of the normalised amount proportional to its raw total, and only then is it split among its suppliers; in this line no award has more than one supplier, 0 of 8,063, so there is no ambiguous split. In the period the line awarded 23,634,950,532 pesos to 1,354 distinct awardees. 42.4% of that money went to entities whose registered name carries an explicit non-profit legal form (cooperative, foundation, association, welfare society, congregation, parish, rural development society). The second of the fourteen ministries is agriculture, at 10.0%. The other twelve sit at 8.3% or below: education and culture 8.3%, defence 6.8%, the presidency 4.2%, interior 3.8%, health 2.4%, labour 2.0%, industry 1.5%, tourism 1.0%, foreign affairs 0.6%, transport 0.3%, economy 0.1%, housing 0.1%. The mirror of the same fact: only 19.1% of the social development ministry's money went to suppliers with a commercial-company name (S.A., S.R.L., Ltda., SAS, EIRL), the lowest of the fourteen by fifteen points — the second lowest is labour, at 34.0% — while economy reaches 91.2% and housing 87.3%. The 42.4% is a floor, because the rule classifies by name. The ministry's largest supplier, OTRAS MANOS (tax id 216136900010, 1,844,215,526 pesos, 7.8% of the line), is a civil organisation whose name carries no legal-form word and is therefore not counted; it is among 600 suppliers, holding 38.2% of the money, in the same situation: CENTRO DE INVESTIGACIÓN, INFORMACIÓN Y ESCUCHA (722 million), FACTOR SOLIDARIDAD (543), CLAEH (471), CENTRO PARA EL DESARROLLO DE INTERVENCIONES Y ESTUDIOS SOCIALES (445), CENTRO DE EDUCACIÓN POPULAR (392). We verified the mechanism by opening, one by one, the 50 official records of the line's largest awarded purchases of 2026, which add up to 3,374,385,225 pesos, 75.2% of what the line awarded that year — that count comes from reading documents, not from our measurement. Of those 50, 44 are exception purchases invoking verbatim «Art. 33, 30: Contratación de bienes y servicios del MIDES con pequeñas empresas, asociaciones u organizaciones civiles», for 2,783,428,065 pesos, 82.5% of that money; inside the Social Development Directorate it rises to 93.3%. Five are public tenders and one is an exception purchase under a different item. In 42 of those 44 the «participating suppliers» block lists a single organisation, which is the awardee: in an exception purchase there is no call for bids, so that does not mean only one applied. The comparison that opens the question is from the same ministry and the same service, by two routes. Public Tender 5/2024 (purchase 1135850), a call open to entities of any legal form to run up to three 24-hour shelters and one mobile team in Montevideo: eight organisations applied and it was awarded to Fundación A Ganar for 86,842,297 pesos. Public Tender 13/2024 (purchase 1160325), technical teams for the gender-violence services network: ten organisations applied and it was awarded to Fundación Voz de la Mujer for 90,736,740 pesos. Exception Purchase 29/2026 (purchase 1323802), article 33 item 30, running 24-hour shelters for homeless people: a single organisation appears, OTRAS MANOS, for 399,597,517 pesos, and it is the ministry's largest contract of 2026. Exception Purchase 260/2025 (purchase 1332102), same item, up to 700 places in overnight and 24-hour contingency shelters: a single organisation, OTRAS MANOS, 56,750,501 pesos. This is not a practice of this government nor of the previous one: the share of the ministry's money going to non-profit entities by name is 44.6% in 2015, 40.7% in 2019, 50.8% in 2021, 42.5% in 2024, 46.9% in 2025 and 39.9% in 2026; it spans three governments of two parties and predates the current wording of item 30, which is from December 2023. Three things we measured that are NOT a signal, published so they are not read as one: the ministry's ten largest suppliers hold 35.7% of the money, less than health (56.6%), labour (63.4%) or housing (91.1%); of the suppliers that ever sold to line 15, 15.5% sold to no other line, and the median across the 60 lines with more than 100 suppliers is 17.4%, so having exclusive suppliers is ordinary; and 91 awardees are present in all six years, out of 1,354 distinct ones, holding 56.3% of the money, barely above education (53.2%), health (51.1%) and defence (50.0%). The competing explanation was written by Parliament, and it goes here. A 24-hour shelter is not a purchase of paper: there are people inside, and re-tendering every year means changing the team, the key workers and the relationship with people living on the street. Item 30 exists so that continuity of care does not depend on a tender calendar, and it names the social development and agriculture ministries, which are exactly the top two of the table. The entities able to sustain an overnight shelter with educators and social workers are few and are, by design, non-profit: the State decided to deliver social policy through civil society rather than hire civil servants, and that explains why in this ministry commercial companies do not dominate the spending. Every one of these purchases is published with its number, its subject, its resolution in PDF and its awardee on the State's site, and all pass through the Court of Auditors' prior control. Press datum, not our measurement: Fundación A Ganar, awardee of Public Tender 5/2024, has prior coverage over other matters — La Red 21 on a direct agreement of December 2024, El Telégrafo on its total contracting with the State, Caras y Caretas on its political ties; that coverage is about that organisation, not about the mechanism we measure here.

Which law it would engage

TOCAF (Decreto 150/012), article 33, letter D), item 30, as worded by Ley 20.245 of 29 December 2023: it authorises direct contracting, with no call for bids, of goods and services by the social development or agriculture ministries with cooperatives, associations or civil organisations, in all cases non-profit, under agreements to deliver their sectoral policies. They are the only two ministries named in the item, and they are the top two of the non-profit purchasing table (42.4% and 10.0%; the third drops to 8.3%). Nothing we measured is a breach: the route exists because Parliament created it, and what the card shows is how much it is used and against which alternative it compares.

«La contratación de bienes y servicios que realicen el Ministerio de Desarrollo Social o el Ministerio de Ganadería, Agricultura y Pesca, con cooperativas, asociaciones u organizaciones civiles, en todos los casos sin fines de lucro, en el marco de convenios o acuerdos específicos para el cumplimiento de planes que se relacionen en forma directa con la ejecución de las políticas sectoriales de dichos Ministerios.» — TOCAF, art. 33 lit. D) num. 30, text given by Ley Nº 20.245 of 29/12/2023 (impo.com.uy/bases/tocaf-tcr/150-2012/33). Each purchase record labels it: «Art. 33, 30: Contratación de bienes y servicios del MIDES con pequeñas empresas, asociaciones u organizaciones civiles». Source warning: the old TOCAF version still published at impo.com.uy/bases/tocaf2012/150-2012/33 shows a different text under item 30, about vocational training; the «tocaf-tcr» base is the updated one to cite. Oversight bodies: the state procurement agency and the Court of Auditors.

What is missing before asserting it

We could not measure whether the exception costs more than the tender. The subjects are not comparable: Public Tender 5/2024 contracts up to three shelters and a mobile team, Exception Purchase 260/2025 up to 700 places, and 29/2026 shelter management with no published unit. There is no common unit price, so any price comparison would be invented, and this card does not make one. Competition cannot be measured from the precomputed collections: of the 4,173 ocids of line 15 since 2021, the competition collection holds 0, the bidders-per-tender collection 13 and the bidders-per-minutes collection 2; the participant counts we use come from reading 50 State records by hand. The procurement method does not live in the feed either: only 24.4% of line 15's ocids since 2021 have procurementMethodDetails on any sibling release, which is why the records had to be read. The 82.5% is measured on the 50 largest purchases of 2026, which are 75.2% of the year's money: it is a census of the large tranche, not a sample of the whole year, and it cannot be extrapolated to the count of small purchases. 2026 is incomplete: the line's awards run to August and that year's feed is missing a channel. Name-based classification is not a legal register: there is no legal-form field in the database — the supplier registry carries corporate name, address and status, not company type — the rule was applied identically to all fourteen ministries and underestimates the social development ministry more than the rest, so the gap is a floor. And we did not check whether the organisations winning by exception compete against each other in other tenders outside these 50 cases. A trap for anyone repeating the measurement: there is also a buyer.id 24-15 named «Ministerio de Desarrollo Social» with 7 releases, which is line 24 and not 15, and stays out.

Who has to answer

The Ministry of Social Development, its General Secretariat and its Social Development Directorate — unit 15-2 concentrates 17,280,329,455 of the line's 23,634,950,532 pesos: why the ordinary route for running 24-hour shelters is the exception purchase and not the open call, when the open call they ran in 2024 attracted eight and ten organisations. The state procurement agency: whether it keeps a record of the use of item 30 by ministry and by amount. The Court of Auditors: whether it observed any of these exception purchases; the ruling is not in the feed, only in its resolutions. And the largest awardee organisations — OTRAS MANOS, Fundación Plenario de Mujeres del Uruguay, Fundación A Ganar, CIIE: whether they would rather compete in a tender.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-mides-cooperativas.verify.ts

What we measured

In our corpus, Montevideo's city government has 29,079 releases in 2024, 19,584 in 2025 and 82 in 2026. Canelones, 1,669 / 1,554 / 0. The National Ports Authority, 947 in 2025 and 0 in 2026. The other 17 departmental governments have a normal 2026: Paysandú 937, Colonia 449, Florida 330, Maldonado 238. It is not a departmental-government problem: it is three bodies. Those bodies publish through a second agency channel whose identifiers carry an «i» prefix (ocid ocds-yfs5dr-i483583), and that channel does not appear in the OCDS RSS. We downloaded and parsed the feed: ocds/rss/2026/07 carries 14,556 releases and in it there are zero identifiers with an «i» prefix and zero award cancellations — while in the database cancellations are 3,417 in 2024 and 3,146 in 2025. Nor are they in the per-release API: GET /ocds/release/adjudicacion-i483583 returns 404 even though it is a 2025 record we already hold, and the control GET /ocds/release/adjudicacion-1307316 returns 200. The only place it lives is the annual archive: on catalogodatos.gub.uy, the agency's historical procurement dataset has 24 resources and the last one is 2025 — ocds-2023.zip created 15/01/2024, ocds-2024.zip 27/02/2025, ocds-2025.zip 19/01/2026; ocds-2026.zip does not exist. How much it weighs: measuring by the ocid prefix and with the normalised amount between 0 and 50 billion, the «i» channel is 59.0% of the spending recorded in 2023, 59.5% in 2024 and 55.4% in 2025. In 2026 it is 0%. Seen through the RSS arrival marker, which only exists from 2025: of the 178.1 billion pesos recorded in 2025, 116.2 billion (65.2%) arrived in releases the RSS never published, and within that tranche the oil company contributes 66.8 billion, the telecoms company 11.6, Montevideo's city government 9.8, the state casinos board 7.2, the water authority 6.1, Canelones 2.0 and the ports authority 1.9. That 65.2% cannot be flipped into «2026 is missing 65% of the money»: annual totals are lumpy — a single award by the power company moves a whole month — and 2026 already adds up to 100.0 billion pesos through RSS alone. The figure that holds is the channel's: between 55% and 59% of the spending recorded in each of the three closed years travelled through a channel that 2026 does not have. It is not by body, it is by purchase: the power company runs 94.6% through RSS, Montevideo's city government 0.6%, and Canelones and the ports authority 0.0%; with at least 100 releases in 2025, only those three bodies have under 5% presence in the RSS. And the data exists today on the State's site: the same query to the agency portal for budget line 98 unit 1, which is Montevideo's city government, returns 4,085 publications for all of 2025 and 3,258 between 1 January and 14 August 2026, with detail pages hanging off the same identifier space; there is also a portal RSS filterable by body which returned 106 items from the city government over the last seven days, 106 of 106 with an «i» identifier, among them Abbreviated Tender A193590/2026 published on 13/08/2026. The portal's units and ours are not comparable to each other: the 4,085-to-3,258 pair works as the portal's internal evidence that the city government keeps publishing, and the 19,584-to-82 pair works as evidence of what the open data shows. The competing explanation goes here, and it is strong. The agency publishes two things because they are two things: a real-time OCDS feed of purchases processed inside the central procurement system, and a consolidated historical archive that also includes the purchases certain bodies report rather than process. Those bodies have contracting autonomy and their own systems; the agency receives their data as a periodic report, not as a live transaction, so there is nothing to emit in real time. The annual archive was published every year: January 2024 for 2023, February 2025 for 2024, January 2026 for 2025. And meanwhile no purchase goes unpublished: tender A193590/2026 has been on the site since the day before this measurement. What is missing is not public information, it is a bulk-download format for a year that has not ended yet. What stands after conceding that: the cost falls on whoever looks at the current year. You can see one tender by the city government; you cannot see its 2026 spending pattern, or compare it, or detect an anomaly, until 2027. And the data is already structured, already has a stable identifier and already has its own per-body RSS on the same site. This includes us, with a date and a line of code. Our spending-trend page marks 2026 as partial, but for the wrong reason: src/jobs/refresh-spending-trend.ts:811 sets «partial: year >= currentYear» and the text says it is a year in progress, not that it is missing an entire channel. On top of that, our site's 2025 line was incomplete until 16 July 2026 — the 2025 «i» channel releases all entered in a single run that day, and the archive had been published since 19 January — and the 2024 ones entered on 7 August 2025, with the archive available since 27 February. Importing the annual archive is manual (scripts/sync-year-zip.ts), it is not on the cron, and nothing warns when the new archive appears.

Which law it would engage

Ley 18.381 (Right of Access to Public Information), article 5, permanent and proactive disclosure on websites, including tenders. That obligation is being met: Montevideo's city government purchases are on comprasestatales.gub.uy today. The gap is not one of publicity but of open data: the agency's commitment to publish in the OCDS standard was born in the 3rd Open Government Plan (2016-2018) and was reinforced in the 5th Plan (2021-2024) with the commitment to strengthen the openness, visualisation and download of public procurement data. What fails is that channel's cadence, not the duty to publish.

Ley 18.381, art. 5: «Los sujetos obligados deberán prever la adecuada organización, sistematización y disponibilidad de la información en su poder, asegurando un amplio y fácil acceso a los interesados. Los organismos públicos, sean o no estatales, deberán difundir en forma permanente, a través de sus sitios web u otros medios que el órgano de control determine, la siguiente información mínima: (…) Concesiones, licitaciones, permisos o autorizaciones otorgadas, especificando los titulares o beneficiarios de éstos.» Documentary complement, not our measurement: in the OCP Data Registry (data.open-contracting.org) the publication «Uruguay: ARCE (Historical)» is listed with update frequency «Annually» and range «Jan 1970 - Dec 2024» (last retrieved 12/01/2026); the «ARCE (API)» publication is listed as «Real time», range «Nov 2017 - Aug 2026».

What is missing before asserting it

What is missing is for the «i» channel — the purchases that state enterprises and departmental governments report to the agency instead of processing inside the central system — to be published as open data at the same speed at which it is already published in HTML on the portal itself. Concretely: that releases with an «i» identifier enter the monthly OCDS RSS, or at least that GET /ocds/release/adjudicacion-iNNNNNN stop returning 404, today even for 2025 records the agency has already published in its annual archive; that the consolidated archive stop being annual, with a monthly or quarterly cut that makes the current year analysable; and that award cancellations enter the live feed, because they are 3,417 in 2024 and 3,146 in 2025 and zero in the RSS of any month. On our side, what is missing is labelling the current year for what it actually lacks — a whole channel, not the fact that the year has not ended — automating the annual archive import with an alert when it appears, and evaluating ingestion of the portal's per-body RSS so as not to depend on January. A limitation of the measurement: we only began marking RSS arrival in 2025, so 2023 and 2024 come out 100% unmarked by construction, and the channel's weight in those years has to be read from the ocid prefix, which is what we do. And the agency's side of the story is missing: we did not ask before measuring.

Who has to answer

The state procurement agency, which runs both channels and decides the consolidated archive's cadence. Three questions: why reported purchases do not enter the OCDS RSS or the per-release API, given they already have a stable identifier and are already published on the portal the same day; whether a cut more frequent than annual is planned; and when ocds-2026.zip will be published. And it answers to us. We publish a spending-trend page that shows 2026 with a year-in-progress label, when what is measurable is that 2026 lacks the channel through which between 55% and 59% of the spending recorded in each of the three previous closed years travelled. And we published a closed 2025 that was missing the entire channel until 16 July 2026, and a 2024 that was missing it until 7 August 2025.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-im-canal-anual.verify.ts

What we measured

We measured the distance between the date of the award resolution and the date that award was published on the state procurement site, across the 480,178 awards published between 1/1/2022 and 13/8/2026. First we validated that the release date field is the publication date, rather than assuming it: in the 221,595 records that carry the attached minutes, that date matches the publication date of the award document exactly in 221,547 cases, 99.98%; we also checked two records against the State's site and they match to the minute. Of the 480,178, 4,502 carry no award and fall out: we measured 475,676. The resolution date comes as a date in 420,045 and as text in 55,631, all from 2025 and all parseable; 18 records carry impossible years, which ruins any average, which is why we work with medians and thresholds and never with means; 265 records (0.06%) have publication earlier than the resolution. The median is 1 day, the 75th percentile is 7, the 90th is 35 and the 95th is 88. Across the whole universe, 79.57% is published within ten days (378,512): 97,164 fall outside, one in five. With fourteen calendar days, the ceiling of ten working days without holidays, it rises to 82.99%. 23,240 awards (4.89%) took more than 90 days and 5,155 (1.08%) more than a year. Article 50 only requires publication above 20% of the direct-purchase ceiling: restricted to that band, using 130,800 pesos — 20% of the 2026 ceiling applied flat over the whole period — across 145,985 awards compliance falls to 68.95%, with 45,332, almost three in ten, out of time, and it falls year by year: 70.2% in 2022, 72.8% in 2023, 68.7% in 2024, 67.8% in 2025 and 60.3% in 2026. The finding is the gradient: the more formal and the larger the purchase, the later the public finds out. Crossing each award with its sibling tender document by ocid (126,594 cases, 26.6% of the total): direct purchase, 89,705 awards, 88.1% within ten days, median 0 days, p90 14, over 90 days 2.1%; exception purchase, 2,791, 68.6%, median 3, p90 40, 3.1%; price competition, 19,521, 59.9%, median 7, p90 46, 3.9%; abbreviated tender, 12,216, 30.3%, median 27, p90 137, 16.6%; public tender, 1,403, 15.7%, median 56, p90 208, 32.4%. The same by amount: under 100,000 pesos, 84.6% in time and a median of 1 day; between 100,000 and a million, 76.5% and 2 days; between one and ten million, 45.3% and 14 days; between ten and a hundred million, 29.8% and 33 days, with a p90 of 153. The band above a hundred million gives 43.4% and we do not use it: it is contaminated by the lump-sum artefact we already documented. Two cases verified against the State's official record, not against our database. The water authority OSE, Public Tender 17311/2021, «Contratación de Servicio de Seguridad y Vigilancia en el Departamento de Rivera», awarded to SECURITAS URUGUAY S.A. for 212,557,261.48 pesos: the record says «Fecha de la Resolución: 27/07/2021» and «Publicación: 21/04/2025 23:02hs», 1,364 days. The state casinos board (finance ministry), exception purchase under article 33 item 3, awarded to CIA RIOPLATENSE DE HOTELES S.A., resolution of 24/03/2023, published on 17/12/2025 at 14:25, 999 days; for this second one we cite no amount, because the record carries the lump-sum artefact pattern. There are bulk uploads and they must be read as such: on 19/03/2024 the state insurer published 3,261 awards in one day, 2,372 of them more than 90 days after the resolution, and that same day Montevideo's city government published 2,646, the oldest 753 days back, plus 2,331 on 15/07/2024 and 1,262 on 01/10/2024. A good share of the 2024 drop in the total is those two bodies catching up. Recent behaviour by body, 2025-2026, only the 135 with 200 awards or more: Veterinary Faculty 6.3% (287), Science Faculty 7.6% (370), Armed Forces Health Service 8.1% (904), Northern Littoral University Centre 8.6% (278), Florida departmental government 11.6% (553), the technical education council 12.9% (1,220), Agronomy Faculty 17.2% (221), the water authority 18.4% (1,962), the secondary education council 21.2% (481), Colonia departmental government 22.1% (734). At the other end: the Soriano (648) and Lavalleja (427) police headquarters at 100%, San Carlos hospital 99.8% (2,641), Maldonado police headquarters 99.8% (825). The competing explanation is strong, it is measured, and it goes here. Article 50's clock starts «luego de producido el acto», and in a formal procedure the act does not end the day it is signed: the resolution goes to the Court of Auditors for prior intervention; if the Court observes it, the body reiterates; only then are bidders notified. A body may read «the act» as the final, intervened act and publish at the end of that chain. The data supports it: of the 221,595 releases with attached minutes, the 5,134 that carry an expenditure-reiteration document — that is, those the Court observed — meet the ten days 26.7% of the time, against 70.7% of the 216,461 that do not, and exceed ninety days 14.9% against 7.7%. It also explains why the gradient follows the procedure and the amount: the larger the purchase, the longer the chain of prior controls. On top of that, the article says ten days without clarifying whether they are working days, the 2024 spikes have the shape of an administrative catch-up and not of concealment, and a small body can fall behind because of a leave or a system change. Where that explanation does not reach: article 50 itself requires publishing, besides the award act, the extensions and the acts reiterating expenditure observed by the Court of Auditors, so passing through the Court adds a publication, it does not suspend the first; cases with reiteration are 2.3% of the universe with minutes, so they explain the shape of the tail and not the bulk of the volume; and if the problem were only how the deadline is counted, we would expect publications at 20, 40 or 60 days, not also 5,155 published more than a year later and a 212-million-peso public tender published three years and nine months after its resolution.

Which law it would engage

TOCAF (Decreto 150/012), article 50: it requires publishing the award act on the state procurement site within ten days of the act, for every procedure whose amount exceeds 20% of the body's direct-purchase ceiling, including exception mechanisms, extensions and the acts reiterating expenditure observed by the Court of Auditors. Two clarifications that bear on what can be asserted. The article says «diez días» and does not clarify whether they are working or calendar days, while articles 51 and 52 do say «días hábiles» when they mean working days: which is why we give both figures, 79.57% at ten calendar days and 82.99% at fourteen. And below 20% of the ceiling there is no obligation to publish at all, so the direct purchase's 88.1% compliance is partly self-selection: what is easy to publish and what nobody requires gets published fast. The number the rule addresses is the other one, 68.95%.

TOCAF, art. 50, second paragraph: «Todas las administraciones públicas estatales deberán dar publicidad en el sitio web de compras y contrataciones estatales, al acto de adjudicación, declaración de desierta o de rechazo de ofertas, a todos sus procedimientos de contratación de monto superior al 20% (veinte por ciento) del límite de su procedimiento de compra directa, incluidos los realizados por mecanismos de excepción, así como las ampliaciones y los actos de reiteración de gastos observados por el Tribunal de Cuentas, en la forma que disponga la reglamentación. Estos organismos contarán para ello con un plazo de diez días luego de producido el acto que se informa». Verified at impo.com.uy/bases/tocaf2012/150-2012/50 and reproduced in the state procurement agency's procedures manual. Drafting contrast: arts. 51 and 52 of the same text do specify «días hábiles». Direct-purchase ceiling in force January-December 2026: 654,000 pesos (departmental governments 1,024,000), published by the agency; 20% is 130,800.

What is missing before asserting it

Survivorship bias, which is the main thing. We can only measure what was published: an award that was never published is not in the corpus and by definition never appears as late, so the 31% non-compliance in the mandatory band is a floor. Closing it requires cross-checking against another source of the spending and seeing how many resolutions never reached the portal; we did not do that. We cannot distinguish «resolved and published the same day» from «the system copied the date»: 178,782 records (37.6%) have a zero difference, and some bodies are at 99% or 100% zero difference; it may be genuine — in a direct purchase the act and its recording are almost the same act — or it may be autofill, and either way the error runs in one direction only, it inflates compliance. The cut by procedure holds over 26.6% of the universe: only 126,594 of 475,676 awards have a sibling tender document by ocid, what is lost is mostly extensions and exception purchases to which the agency gives a new identifier, and the gradient is monotonic and large but the exact percentages come from that subset. Working days versus calendar days is not settled by data: we give both figures and do not choose. The legal threshold is approximate: we use 130,800 pesos, 20% of the 2026 ceiling, flat over 2022-2026, when the ceiling is indexed each year and is different for departmental governments, so the subset we measure is inside the obligation but does not exhaust it. The cut by amount is affected by two known corpus traps, awards with a null currency counted as pesos and the lump-sum artefact in the upper band, which we report and do not use. 2026 is distorted — a feed channel is missing and Montevideo's city government has a handful of awards in the whole year against fifteen thousand in 2025 — so 2026's 60.3% is not comparable and does not go in the headline. And we asked nobody for their side: not the agency, not the Court of Auditors, not the bodies.

Who has to answer

The state procurement agency, which runs the site and defines the publicity regime: whether it measures and publishes compliance with article 50's deadline; whether there is any control over a publication made 1,364 days after the resolution, which the system accepted without flagging; and whether it will publish the per-body compliance metric, which it can compute from its own data. Also, its position on whether the deadline counts working or calendar days, and from which act. The bodies of the 2025-2026 period: the university, for its Veterinary Faculty (6.3%), Science Faculty (7.6%), Northern Littoral Centre (8.6%) and Agronomy Faculty (17.2%); the Armed Forces Health Service (8.1% over 904); the technical education council (12.9% over 1,220); the Florida departmental government (11.6%); the water authority (18.4% over 1,962, and the Securitas case of 1,364 days); the power company (23.8% over 1,633, with 69 published more than a year late); the state casinos board (and the Rioplatense case of 999 days). The state insurer and Montevideo's city government, over the 2024 episode: what happened for 5,907 awards to be published on the same 19 March. The Court of Auditors: whether delay in publicising the award act is a matter for observation and whether it ever observed one. We have the body and the buying unit, not the person: there is no proper name in this finding.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-plazos-publicacion.verify.ts

What we measured

For five and a half years two statutory provisions said the price to be paid could not exceed «los precios publicados por la Agencia Reguladora de Compras Estatales». We measured what was published. On the document side: the agency's complete announcements archive holds 57 entries, and exactly 2 are reference prices — both for the same product, fresh milk: finance ministry Resolution 104/023, in force from May 2023, and 162/024, in force from June 2024. A third entry indexed by search engines returns HTTP 403 today, «access denied». The other 55 are framework agreements, extensions, annual procurement plans, and notices about the procurement and supplier systems: none carries a price. The price lives inside an .xlsx that is an order form: in the June 2024 one, the «Precio ajustado a la fecha» column reads $42.34 per litre «delivered by the supplier» and $37.26 «collected at the plant». There is no CSV, no API, no historical series, no HTML table. And the agency does not calculate the price: the attached PDF is finance ministry Resolution 162/024 published in the Official Gazette, which sets the maximum sale prices of «leche pasteurizada envasada en bolsitas de polietileno, con un tenor graso no inferior a 2,6%» across the country — over the counter $43.00, home delivery $43.30, to the retailer $42.34, at the plant loading bay $37.26; it is the general price control on regulated milk, and the agency relays it. The announcement itself cites art. 8 of Decreto 130/008: «el precio de la leche será actualizado en forma semestral por el Poder Ejecutivo». Between May 2023 and today about seven half-yearly adjustments fall due; the agency published two announcements. There is also a loose file on the agency's server, «Resol Precio Leche Fresca 19.3.2025.pdf», which we did not find linked from any section: we downloaded it and it has 0 font objects and 2 images — it is a scan with no text layer, not machine-readable. In open data, the national catalogue's API returns 10 agency datasets — the supplier register 2020-2026, historical procurement data, site publications and the article catalogue — and zero on prices; the agency's own site search returns 0 results for «precios de referencia». On the corpus side, the universe the cap claimed to cover: the single catalogue holds 90,368 articles, of which 80,788 are goods and 74,770 are current. The agency published a price for one product: 0.001% of the catalogue. Spending on goods between 2021 and 2025 — the universe of LUC article 318, which reached every catalogue article including direct purchases and petty cash — was 215,682,798,431 pesos across 1,001,565 award lines (2021: 38,049,215,741; 2022: 49,667,671,946; 2023: 53,571,285,958; 2024: 38,747,871,021; 2025: 35,646,753,766), and it is a floor, because it only counts lines with a catalogue code and a plausible amount. The universe of TOCAF art. 33 D) item 16, food: the corresponding sub-family holds 1,823 articles, 852 of which were actually bought between 2021 and 2025 for 17,766,912,252 pesos across 96,172 lines. And nobody invokes the cap: searching for exact phrases over the text index of the corpus's 2,184,332 records, «precio máximo de adquisición» returns 0, «precio testigo» 0 and «precios máximos» 0; «precios de referencia» returns 13, «precio de referencia» 6 and «precio máximo» 7, and we reviewed all 26 one by one — 11 are the water authority's stock phrase («participar en el Concurso de Precios de referencia»), 7 are indicative quotation requests from one hospital, 2 are 2003-2004 regularisations and the 7 «precio máximo» hits are the tender document's own caps: none invokes a price published by the agency. The only verifiable case shows both things at once. Fresh pasteurised milk for human consumption, catalogue code 2988, in pesos per litre and without a single null-currency line: 2023 n=27, range 26.72 to 180, median 44.30; 2024 n=31, range 33.90 to 125, median 45.90; 2025 n=75, range 35.25 to 90, median 48.38; 2026 n=50, range 38.52 to 180, median 44.47. The June 2024 reference price appears verbatim in the corpus: there are 12 lines at exactly $42.34, all from the national dairy producers' cooperative selling to Rocha, Florida, Bella Unión and the Florida departmental government. That is, the instrument exists, is used, and can be seen working. In the same period the same code was bought 44 times at 60 pesos a litre or more, up to 180, above even the maximum home-delivery retail price ($43.30). And here goes the warning that kills the easy headline: the finance ministry resolution caps only polyethylene-bag milk with 2.6% fat or more, and the OCDS record does not state the presentation. Therefore it CANNOT be asserted that those purchases breached a cap: what can be asserted is that nobody can know with what is published. The competing explanation is strong and goes above everything. Article 318 was never operative because it was never implemented by decree, and implementing it was the Executive's job, not the agency's: the article itself says the Executive «reglamentará la aplicación de este instrumento», and without a decree the agency had no legal instrument to publish anything, so the body's silence may be, literally, somebody else's silence. The definition was also technically fragile, and milk proves it: «the lowest purchase price in force for each catalogue article» assumes a code identifies a comparable product, and code 2988 covers regulated bagged milk, bottles, different fat contents, home delivery and plant collection, with legitimate prices from $37.26 to over $60; publishing the lowest price as a cap would have blocked perfectly correct purchases and pushed bodies into justifying almost every purchase in writing, petty cash included, so the repeal may be a sensible correction of a badly designed rule and not a step backwards. Item 16 is not obvious negligence either: that cap applied to a very narrow ground, and for the products in that basket there is no administered price the agency could copy — only milk has one, because regulated milk has been price-controlled since Ley 10.940 — and publishing prices for tomatoes or squash would have required standing up an agricultural price observatory that is not the agency's remit. And something that cuts against us: the information exists, only not as a cap; every awarded unit price is in the feed and on the procurement site, and a diligent buyer can see today what others paid for the same code — our own site is the proof — so the State could argue that price transparency is already solved by publishing the awards. What none of those explanations covers: why, if the instrument was unworkable, it was left five and a half years in the Code with an express obligation on every purchasing authority; and why the one price that was published is published inside an Excel file, twice, with a broken link and a text-less scan. Prior coverage, to be clear about what is ours: the milk price adjustment is covered as a consumer story by Montevideo Portal and El Observador, without mentioning that the price is the legal cap on State purchasing; and the repeal appears as a bullet point in two law-firm bulletins of December 2025 and January 2026, with no measurement at all. We found no Uruguayan news piece saying the agency never published those prices, nor one crossing the cap against actual spending.

Which law it would engage

There are two legal caps tied to «precios publicados por la ARCE», both in force between July 2020 and 31 December 2025, and both repealed by the same Budget law. The first: TOCAF art. 33, letter D), item 16 — direct purchase of nationally produced food and fresh provisions offered by family producers, worker cooperatives and organisations qualified under Ley 19.292 — whose last paragraph set a price cap referred to what the agency publishes, as worded by art. 35 of Ley 19.996, and which was repealed by art. 29 of Ley 20.446 with effect from 1 January 2026. The second, the more ambitious: art. 318 of Ley 19.889 (LUC), «Precio máximo de adquisición», which defined the maximum price as the lowest purchase price in force for each article in the single catalogue of goods, required the purchasing authority to place the agency-published value in the file on every purchase — including small direct purchases and petty cash — and to justify any difference in writing before awarding; repealed by art. 24 of Ley 20.446, same effective date. Nothing we measured is anyone's breach: what the card shows is that a control written into law left no verifiable trace, and that it was repealed without a single official measurement of its application.

TOCAF art. 33 lit. D) item 16, last paragraph (wording of art. 35 of Ley 19.996; identical in art. 314 of the LUC): «En cualquier caso, los precios a pagar no podrán superar los precios publicados por la Agencia Reguladora de Compras Estatales para ese producto». Ley 19.889 (LUC), art. 318: «Se define como “precio máximo de adquisición” al menor precio de compra vigente a un momento dado, para cada artículo contenido en el catálogo único de bienes adquiridos por el Estado. En todo trámite de compra que refiera a un artículo contenido en dicho catálogo único, el ordenador respectivo deberá incorporar en las actuaciones el valor del precio máximo de adquisición publicado por la Agencia Reguladora de Compras Estatales… Quedan comprendidos por este requisito todas las operaciones de compra, aun las dispuestas como compras directas por monto menor y las que se realicen con cargo a fondos fijos… El Poder Ejecutivo, con el asesoramiento de la Agencia Reguladora de Compras Estatales y del Tribunal de Cuentas, reglamentará la aplicación de este instrumento». Ley 20.446, art. 24: «Derógase el artículo 318 de la Ley N° 19.889, de 9 de julio de 2020.»; art. 29: «Derógase el último inciso del numeral 16) del literal D) del artículo 482 de la Ley N° 15.903…»; art. 3: «Esta ley regirá a partir del 1º de enero de 2026…». Source warning: a law-firm bulletin attributes the repeal of art. 318 to art. 25; on impo it is art. 24 — art. 25 repeals the last paragraph of art. 40 of Ley 20.075 and art. 26 repeals art. 330 of the LUC. Complementary rule for the one published case: Decreto 130/008, art. 8, and finance ministry resolutions 104/023 and 162/024 issued under Ley 10.940 and arts. 31, 33 and 44 of Ley 18.242.

What is missing before asserting it

The series does not exist in any format: there is no dataset, no page, no API holding the list of «precios publicados por la ARCE» that two statutory provisions used as a cap, and the only price published in the body's entire history is fluid milk's, which comes inside an order spreadsheet. Article 318's «maximum acquisition price» was never published for any article: zero announcements, zero datasets, zero mentions across 2.18 million files; it is an obligation written for 90,368 articles and met for none. The implementing decree is missing: art. 318 instructed the Executive to implement it with advice from the agency and the Court of Auditors, and impo's updated page for that article records only the repeal and its effective date, with no «implemented by» note; we found no implementing decree, and if there is one, let them show it. The record is missing: even where the cap existed and was used, the OCDS file has no field saying «applicable reference price» or «product presentation», which is why a purchase of code 2988 at 90 pesos a litre and another at 42.34 are indistinguishable to anyone trying to check — it cannot be known whether the first is unregulated milk or regulated milk bought above the maximum. Accessibility of the little there is, is missing: one of the three milk-price announcements returns HTTP 403, and the March 2025 PDF is a scan with no text layer that is not linked from any section we could find. And the reckoning nobody did is missing: Parliament repealed both instruments in December 2025 without a single public report of how many times they were applied, how much they saved, or why they did not work. Three reservations of our own, carrying the same weight as the numbers. First: no purchase measured is in breach; the milk cap covers only polyethylene-bag milk with 2.6% fat or more and the OCDS record does not state the presentation, so purchases at 60-90 pesos a litre are an open question and never a violation. Second: the 17,766 million in food is the sector's upper bound and not the amount actually reached by item 16, because that ground is narrow and the feed does not allow isolating it. Third: the «zero» mentions is measured over the OCDS text fields — title, description, items, names — not over tender documents in PDF, so a tender document may invoke the cap without our seeing it.

Who has to answer

The state procurement agency: did it ever publish a «maximum acquisition price» under LUC art. 318? For how many articles of the single catalogue? Where? And why does the only reference price it did publish travel inside an order .xlsx rather than as open data, when the body already publishes ten datasets on the national catalogue? The agency again: between May 2023 and today about seven half-yearly milk-price adjustments fell due under Decreto 130/008; why did only two reach an announcement, and why does one of them return «access denied» today. The Ministry of Economy and Finance, which sets the milk price and signed the repeal into the Budget: what assessment of art. 318 was made before repealing it, and whether any application report exists. The Executive: whether the implementing decree art. 318 itself required was ever issued and, if not, why for five and a half years. The Court of Auditors, which art. 318 named as adviser on the implementing decree: whether it ever observed an award for lack of the maximum-price record that article required to be placed in the file. And the bodies that buy food from family producers and cooperatives under item 16 — the food institute, the education authority, the health service, the departmental governments: against which published price did they check the cap between 2021 and 2025.

Measured on 2026-08-14 · Re-measure it with: npx tsx tests/unit/hallazgo-arce-referencia.verify.ts