Understand when Brazil’s inexigibilidade mechanism may be used for engineering and Consulting Engineering services under Law 14,133: Article 74, recognized expertise, essentiality, price and the Article 72 process.
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Inexigibilidade for engineering services, a Brazilian direct-contracting mechanism based on lack of viable competition, may be used when the Administration can demonstrate in the specific case that competition is not feasible and that the procurement involves a specialized technical service of predominantly intellectual nature whose performance by a professional or company with recognized expertise is essential and demonstrably adequate to fully satisfy the object. Under Law 14,133/2021, it is not enough for the service to be complex, it is not enough for the contractor to have a strong résumé, and the former “singularity of the object” no longer needs to be proven as an autonomous requirement.
The decision must be built as a chain of evidence: which public problem must be solved, why the service requires specialized intellectual work, why recognized expertise is relevant to that object, why selecting that provider is technically justifiable, how the price was demonstrated, and which deliverables will allow the service to be inspected and accepted. When this chain is weak, inexigibilidade becomes vulnerable; when it is consistent, direct contracting can be a legitimate instrument for obtaining high-level Consulting Engineering.
What changed under Law 14,133 for inexigibilidade of specialized technical services
Article 74 of Law 14,133 establishes that competitive procurement is inexigível when there is no viable competition. For specialized technical services of predominantly intellectual nature, item III provides for contracting a professional or company with recognized expertise for activities such as studies, planning, design, technical opinions, consulting, inspection, supervision, management, quality controls, testing, instrumentation and monitoring.
The most important point for those still applying the logic of Law 8,666 is the change in requirements. The Brazilian Federal Court of Accounts (TCU) expressly states that Law 14,133 removed singularity of the object as a requirement for this inexigibilidade ground. Instead, the process must demonstrate three central elements:
- the service is a specialized technical service of predominantly intellectual nature;
- the professional or company has recognized expertise relevant to the object;
- the work of that professional or company is essential and demonstrably adequate to fully satisfy the contracted object.
This change is relevant because it shifts the analysis from the label “singular service” to a more concrete question: do the differentiated characteristics of the need make that provider’s expertise decisive for achieving the intended result?
There is no generic authorization to hire any specialist without competitive procurement. The TCU itself emphasizes that if the object is usual, routine, or does not require a professional or company with recognized expertise, direct contracting is not justified. In that situation, the Administration must structure competition compatible with the nature of the service.
Is Consulting Engineering a common engineering service?
Consulting Engineering should not be treated as a common engineering service. The agency’s challenge is to determine whether the case requires technical competition or whether the requirements of Article 74 make competition unfeasible.
This issue became especially important in 2026. AGU Normative Guidance No. 107/2026 states that Consulting Engineering services falling under Article 6(XVIII), items “a”, “d” and “h” of Law 14,133 are specialized technical services of predominantly intellectual nature and cannot be classified as common engineering services.
This includes, among other activities:
- technical studies, planning, basic designs and executive designs;
- inspection, supervision and management of works or services;
- quality and technological controls, analyses, tests, instrumentation, monitoring and other engineering services falling within that definition.
The practical consequence is not that all Consulting Engineering must be contracted through inexigibilidade. The AGU guidance itself preserves two distinct routes. When competition is viable, procurement should occur through competitive procurement, with quality and price as the general rule for these services, except where additional weighting of technical quality is not relevant. When the requirements of Article 74 are actually present, inexigibilidade may apply.
Therefore, there is an essential difference between two statements:
- “Consulting Engineering is not a common service” — a statement consistent with AGU Normative Guidance 107/2026;
- “Consulting Engineering is automatically eligible for inexigibilidade” — an incorrect statement.
The correct decision depends on the relationship among the nature of the service, the specific need, recognized expertise and the provider’s essential role.
What lack of viable competition means in Consulting Engineering
Lack of viable competition should not be confused with the absolute absence of other professionals or companies in the market. Under Article 74(III), the analysis is linked to the differentiated characteristics of the service and the interdependence between the quality of the result and the provider’s skill, experience, method, team and knowledge.
The TCU explains that selection may depend on a subjective analysis because the technique employed and the provider’s skill are interdependent, making objective comparison difficult when it does not adequately reproduce the technical value of the work. This does not mean unrestricted freedom to choose whoever the Administration prefers. It means that the lack of viable competition must be reasoned and demonstrated.
In engineering, some indicators that may justify a deeper inexigibilidade analysis include:
- need for a technical diagnosis whose result depends heavily on accumulated experience in comparable cases;
- design or study in a critical environment with many interfaces and significant consequences from an inadequate decision;
- acting as Owner’s Engineering on a multidisciplinary project requiring continuous technical judgment;
- inspection, supervision or management in a highly complex situation where the team’s specific experience is decisive for controlling risks;
- feasibility study or planning in which methodology, technical repertoire and the ability to integrate disciplines directly affect the result;
- forensic examination, assessment, technical opinion or failure investigation requiring demonstrably differentiated knowledge;
- technological control, testing or monitoring under conditions requiring specialized methodology, team or equipment.
None of these examples automatically creates inexigibilidade. The record must show why, in that specific case, the expected result requires that level of expertise.
Recognized expertise: what actually needs to be demonstrated
Law 14,133 defines recognized expertise as the quality of a professional or company whose standing in its field of specialization, arising from prior performance, studies, experience, publications, organization, equipment, technical team or other requirements related to its activities, supports the inference that its work is essential and demonstrably adequate to fully satisfy the object.
The analysis must be documentary and linked to the object. It is not about generic fame, marketing or the number of certificates. The Administration needs to build a bridge between the contractor’s evidence and the specific need.
| Evidence | What it may demonstrate | Question the record must answer |
| Experience certificates and previous contracts | experience actually performed | are previous works technically relevant to the current challenge? |
| CAT, ART, RRT and professional records | technical responsibility | did the team that justified the selection have proven responsibility for compatible activities? |
| Key-team résumés | education and career | are individual competencies relevant to the object? |
| Specialized studies and education | technical depth | does the education add specific capability required by the procurement? |
| Publications and technical production | intellectual command and recognition | does the produced content demonstrate consistent knowledge in the field of the object? |
| Comparable projects and cases | prior performance | is there evidence of work on problems of similar nature or complexity? |
| Organization and equipment | mobilization capability | is the available structure adequate to perform the scope? |
| Proprietary methodologies and processes | ability to produce traceable results | does the method provide governance, quality and control compatible with the need? |
The most common error is to gather a large volume of evidence without showing its relevance. A professional may have recognized expertise in one discipline and still not be the essential provider for an object of a different nature.
The provider’s expertise must be essential to the object
This is the core distinction between a robust justification and a generic one. The process does not end when it demonstrates that the company is specialized. It must demonstrate that that expertise is necessary to fully achieve the result of the procurement.
A sound technical justification connects four elements:
- problem — which risk, decision or need the Administration must address;
- relevant complexity — which characteristics make a routine approach inadequate;
- required capability — which experience, method, team or capacity is decisive;
- provider fit — which evidence demonstrates that the selected professional or company has exactly those capabilities.
This logic is particularly useful in Consulting Engineering contracts, where value lies not only in the number of hours produced but in decision quality, error prevention, risk management, technical coordination and the ability to protect the client’s investment.
Which engineering services may fall under Article 74(III)
Article 74(III) lists specialized technical services of predominantly intellectual nature. In engineering, some groups are especially relevant.
Technical studies, planning, basic designs and executive designs
These may be contracted through inexigibilidade when the differentiated characteristics of the need make the work of a professional or company with recognized expertise essential. This may occur in complex feasibility studies, multidisciplinary designs, critical-infrastructure retrofits, asset and critical-system planning, or situations requiring exceptionally relevant experience.
The existence of a design, by itself, does not authorize direct contracting. A usual, readily standardizable design with broad market availability may be fully competitive.
Technical advisory and consulting services
Technical consulting may qualify when the Administration needs specialized intellectual capability to diagnose, structure decisions, assess alternatives, review designs, develop strategies, support procurement or technically govern an investment.
Engineering Technical Consulting and Continuing Consulting Engineering Services may take different scope forms, but the procurement method must always be defined by the agency based on the specific characteristics of the need and applicable law.
Inspection, supervision and management of works or services
The law expressly includes these activities among predominantly intellectual specialized technical services. In complex projects they may require interpretation of designs, interface management, change analysis, quality control, claims assessment, document review and support for high-impact decisions.
Contracting through inexigibilidade, however, will only be defensible when it is demonstrated that recognized expertise is essential to the object. If the work can be sufficiently structured and compared under competitive criteria, competition remains possible.
Quality controls, testing, instrumentation and monitoring
Item III also covers quality and technological controls, analyses, field and laboratory testing, instrumentation and monitoring of specific parameters of works and the environment.
The distinction between standardized and specialized activity remains valid. A routine test available from several laboratories may be competitive; a complex investigation depending on differentiated methodology, interpretation and experience may require a different analysis.
How to structure the direct-contracting process under Article 72
Direct contracting still requires planning. DFD, ETP, risks, TR, estimate, opinions, reason for selection and price justification must form a single chain of decision.
Inexigibilidade does not mean the absence of a process. The TCU emphasizes that direct contracting remains a procurement process, with planning, definition of the object, value estimation, justifications, qualification and control.
Article 72 of Law 14,133 requires the process to be instructed with:
- demand-formalization document and, where applicable, ETP, risk analysis, TR, basic design or executive design;
- cost estimate pursuant to Article 23;
- legal opinion and technical opinions, where applicable;
- demonstration of budget compatibility;
- proof of the contractor’s minimum qualification and eligibility;
- reason for selecting the contractor;
- price justification;
- authorization by the competent authority.
In addition, the authorization act or extract resulting from the procurement must be disclosed under the applicable rules, and a contract resulting from inexigibilidade is subject to transparency requirements in the PNCP.
The process can be visualized as a chain of decisions:
The quality of the process depends on consistency among the documents. It is not enough to justify a sophisticated procurement in one opinion while keeping a generic TR without deliverables, acceptance criteria or definition of the team that will actually perform the work.
The role of the ETP in inexigibilidade
The Preliminary Technical Study should not be used to “prove a decision already made.” Its role is to characterize the need, analyze alternatives and demonstrate why the selected solution is appropriate.
In direct contracting of Consulting Engineering, the ETP may record:
- the problem or opportunity motivating the procurement;
- the impacts of not contracting or of contracting an inadequate solution;
- available alternatives for meeting the need;
- existing internal capabilities and gaps within the Administration;
- technical characteristics of the service required;
- technical, operational, contractual and implementation risks;
- intended results;
- reasons why the solution requires specialized knowledge;
- conclusion on the appropriateness of the procurement method to be submitted to the competent areas.
The legal analysis of the classification should not be replaced by the ETP. The document provides the technical basis on which the Administration and its legal counsel will assess the procurement regime.
The Terms of Reference remain mandatory as a governance instrument
Direct contracting must not be confused with contracting without a scope. The more intellectual and specialized the service, the more important it is to precisely describe:
- the problem to be solved;
- scope and boundaries;
- assumptions and constraints;
- key team where relevant;
- products and deliverables;
- review and approval criteria;
- meetings, workshops and interfaces;
- measurement and payment milestones;
- documentation requirements;
- acceptance criteria;
- responsibilities of the Administration and contractor.
A weak TR creates two simultaneous risks: it makes price justification difficult and reduces the agency’s ability to inspect results. Therefore, Technical Review of Terms of Reference may be useful before formalizing high-complexity procurements, regardless of whether selection occurs through competition or direct contracting.
Reason for selecting the contractor: how to avoid circular justifications
“We selected it because it is a specialist” is not enough. “It is a specialist because it was selected” is not enough either.
The reason for selection must demonstrate the connection between need and evidence. A technically defensible structure can follow this sequence:
| Element | Expected demonstration |
| need | which result the agency needs to achieve |
| differentiated characteristics | why the service is not routine for that need |
| critical capability | which competencies are decisive for the result |
| provider evidence | which experience, team, publications, methodologies or capabilities demonstrate fit |
| essentiality | why this set makes the work demonstrably adequate to fully satisfy the object |
| governance | how the team and attributes that justified selection will remain linked to execution |
The reasoning must be verifiable by third parties. Internal control, legal counsel or a court of accounts should be able to reconstruct the logic without relying solely on the personal perception of the person requesting the procurement.
How to justify price in a Consulting Engineering inexigibilidade
Lack of viable competition does not eliminate the obligation to demonstrate price compatibility. Article 72 requires price justification, and Article 23, paragraph 4 provides that when it is not possible to estimate value through the ordinary methods for direct contracting, the contractor must first demonstrate conformity with prices charged in similar procurements of the same nature, through invoices from other clients within the statutory period or another reliable means.
In Consulting Engineering, the challenge is to ensure true comparability. Two contracts may have similar names and completely different structures. An adequate analysis considers, among other factors:
- scope and number of disciplines;
- seniority and team composition;
- number of technical hours;
- schedule and urgency;
- number of sites or assets;
- technical responsibility;
- number and complexity of deliverables;
- need for travel, testing, software or instruments;
- degree of interaction with internal teams and third parties;
- professional and contractual risk;
- number of review and approval rounds.
For services structured by technical hours, a transparent calculation memorandum can relate professional profiles, HTEs, products, activities and direct costs. For objects with fixed deliverables, the comparison must normalize scope differences before concluding that a given price is equivalent.
A low price is not proof of advantage if it creates technical insufficiency. Likewise, recognized expertise does not authorize a price without justification.
The team that justifies inexigibilidade must perform the service
Article 74, paragraph 4 prohibits, in procurements based on item III, subcontracting companies or using professionals other than those whose qualifications justified inexigibilidade.
This rule is central to contract governance. If the record states that a particular team, experience or knowledge was essential to justify direct contracting, execution cannot simply be transferred to professionals outside that justification.
Therefore, the TR and contract should make clear the relationship among:
- key professionals supporting the selection;
- roles and responsibilities;
- deliverables under each profile’s responsibility;
- rules for any replacement legally permitted;
- inspection of the team’s actual mobilization;
- evidence of participation in key decisions and deliverables.
The Administration must contract the capability it justified, not merely a corporate brand.
When inexigibilidade is inappropriate or risky
The best technical defense against challenges is a record in which need, expertise, scope, team and price are traceable. Inexigibilidade does not correct a poorly defined object.
There are situations in which direct contracting may seem convenient but the reasoning is weak. The most common warning signs are:
- usual or routine object that does not require recognized expertise;
- attempt to classify a common engineering service as consulting only to avoid competition;
- justification based on a previous relationship, trust or prior familiarity with the agency;
- strong résumé without demonstration of relevance to the object;
- generic reference to complexity without explaining which decisions require differentiated capability;
- absence of demonstrated essentiality of the provider;
- ETP produced only to confirm a previously defined selection;
- reason for selection based on unsupported statements;
- price justified using objects that are not comparable;
- generic TR that does not allow result inspection;
- actual team different from the team used to demonstrate recognized expertise;
- subcontracting that empties the basis for inexigibilidade.
Law 14,133 also provides for liability in cases of improper direct contracting involving intent, fraud or gross error. The risk should not be used to paralyze legitimate decisions, but it does require a technically consistent process.
When competitive procurement remains the correct path
Even predominantly intellectual specialized technical services may be competitively procured. The TCU notes that when the provider’s recognized expertise is not essential to fully satisfying the object, the service may be procured competitively, using quality and price or other permitted criteria when appropriate.
AGU Normative Guidance 107/2026 reinforces the particular nature of Consulting Engineering: it is not a common engineering service subject to electronic auction. The general rule is competitive procurement, normally based on quality and price, except in cases of inexigibilidade.
This distinction avoids two opposite errors:
- treating a high-complexity intellectual service as a commodity and reducing the decision exclusively to the lowest price;
- treating any intellectual service as though competition were automatically unfeasible.
A sound procurement strategy starts with the nature of the need, not with a preference for a procurement method.
How an agency can contract high-level Consulting Engineering through inexigibilidade
When the specific case allows inexigibilidade, the agency still needs to contract for results: key team, deliverables, governance, measurement, documentation and acceptance must be clearly defined.
When the specific case meets the statutory requirements, the Administration can structure the procurement in a clear technical and documentary sequence.
1. Characterize the problem before selecting the provider
Describe the need, risks and intended result. The more specific the problem, the more objective the analysis of the type of capability required.
2. Demonstrate the predominantly intellectual nature
Identify where diagnosis, conception, technical judgment, coordination, assessment of alternatives, decision-making or specialized control occur. This distinguishes the intellectual core from routine material execution.
3. Demonstrate why recognized expertise is essential
Explain which attributes of the professional or company make a real difference to the result and why ordinary competitive selection would not adequately reproduce that need.
4. Define verifiable scope and deliverables
Inexigibilidade is not open-ended contracting. The agency must know what it will receive, how progress will be measured, which evidence will be produced and how acceptance will be assessed.
5. Build independent reason-for-selection and price-justification analyses
They are two distinct questions: why this contractor? and why this price?. The answer to one does not replace the other.
6. Submit the process to the competent controls
Technical opinions, legal analysis, authorization, transparency and other controls must integrate the procedure defined by the agency.
7. Inspect execution for adherence to the original justification
The team, method, scope and deliverables that justified the procurement must remain traceable during execution.
This architecture transforms inexigibilidade into an engineering and governance process, not merely an administrative justification.
What A3A Engenharia can provide in this type of procurement
The decision to use inexigibilidade, the formal reason for selection, legal analysis and authorization are responsibilities of the Administration. A3A Engenharia should not replace these functions when it is a potential contractor.
As a Consulting Engineering company, however, it can provide organized technical elements needed for the agency to assess the procurement within its own authority, for example:
- technical and commercial proposal with clear scope and deliverables;
- résumés and composition of the key team;
- professional registrations and technical responsibilities;
- experience certificates and evidence of relevant work;
- portfolio and technically comparable cases;
- technical production and publications related to the specialty;
- relevant certifications and education;
- planning, governance, inspection, QA/QC, document-management or commissioning methodologies;
- price-build-up memorandum and comparable parameters where applicable;
- list of professionals whose experience supports execution;
- monitoring, measurement and acceptance model.
The Administration’s role is to use these elements — together with its own studies, opinions, controls and criteria — to form an independent and reasoned decision.
Inexigibilidade vs. dispensa: why they are not the same
Both are forms of direct contracting, but they arise from different grounds.
| Aspect | Inexigibilidade | Dispensa |
| Basis | competition is not feasible | competition is feasible, but the law authorizes direct contracting |
| Main provision | Article 74 | Article 75 |
| Statutory list | illustrative under Article 74 | exhaustive grounds under Article 75 |
| Consulting Engineering | may apply when the requirements of Article 74(III) are present | depends on a specific ground under Article 75 |
| Central analysis | why is there no viable competition for that need? | which statutory ground authorizes dispensing with competition? |
This distinction deserves separate treatment because the risks, documents and strategies are different. A specific subcluster on dispensa for works and engineering services should address Article 75 grounds separately, without importing the logic of inexigibilidade.
Practical matrix: is the case mature enough for inexigibilidade analysis?
Before taking the procurement for authorization, a technical review can verify whether the documentation answers the essential questions.
| Question | Expected evidence | Warning sign |
| Which public need will be met? | DFD, ETP and justifications | generic problem or solution selected before diagnosis |
| Is the service specialized technical and intellectual? | description of the object and activities | predominance of routine material execution |
| Why is expertise necessary? | risks, complexity and critical decisions | use only of words such as “complex” and “specialized” |
| Does the contractor have relevant recognized expertise? | certificates, team, experience, technical production | broad résumé without connection to the object |
| Why is this provider essential? | fit analysis between need and capabilities | mere preference or prior relationship |
| Is the price justifiable? | comparables, calculation memorandum, invoices or other reliable means | amounts without scope normalization |
| Can the object be inspected? | TR, deliverables, measurement and acceptance | intellectual service without defined products |
| Will the team that justified the selection participate? | key team and responsibilities | intent to replace or subcontract later |
| Did the process pass through the controls? | opinions, authorization and transparency | lack of separation among technical, legal and decision functions |
If several answers depend on generic interpretations, the procurement is not yet mature. The best time to correct it is before authorization.
How Consulting Engineering protects the client’s interest
The discussion about inexigibilidade should not be reduced to “how to contract without a competitive procedure.” For the public agency, the strategic question is different: how can specialized technical knowledge be contracted without losing governance, traceability and the ability to demand results?
Consulting Engineering adds value when it helps the Administration turn a complex need into decisions and evidence. This may include planning, design, independent review, technical procurement support, risk management, inspection, Owner’s Engineering, QA/QC, analysis of amendments, commissioning and technical acceptance.
The legal procurement method is a consequence of the specific case. Technical value lies in the ability to reduce risks, protect the client’s interest and ensure that public investment produces the intended result.
Final considerations
Law 14,133 clarified the procurement of specialized technical services by removing the former singularity of the object as an autonomous requirement and focusing the analysis on the nature of the service, recognized expertise and the provider’s essential role in fully satisfying the object.
For Consulting Engineering, AGU Normative Guidance 107/2026 adds an important point: studies, designs, inspection, supervision, management and certain control and testing activities are predominantly intellectual specialized technical services and should not be treated as common engineering services. This does not authorize automatic inexigibilidade, but it prevents relevant intellectual activities from being reduced to an inappropriate common-service logic.
A defensible direct-contracting process arises from a coherent record: a well-characterized need, ETP, clear object, technical justification, proven recognized expertise, demonstrated essentiality, reason for selection, justifiable price, independent opinions, team linked to execution, and inspection and acceptance criteria.
The objective is not to avoid competition for convenience. It is to correctly identify when the nature of the need itself makes competition unfeasible and, in those situations, structure a procurement capable of withstanding technical, legal and oversight review.
Technical references
[1] BRAZIL. Law No. 14,133 of April 1, 2021 — Public Procurement and Administrative Contracts Law. Available at: https://www.planalto.gov.br/ccivil_03/_ato2019-2022/2021/lei/l14133.htm.
[2] BRAZILIAN FEDERAL COURT OF ACCOUNTS. Procurement and Contracts: 5.10. Direct contracting process. Available at: https://licitacoesecontratos.tcu.gov.br/5-10-processo-de-contratacao-direta/.
[3] BRAZILIAN FEDERAL COURT OF ACCOUNTS. Procurement and Contracts: 5.10.1.3 Specialized technical services of predominantly intellectual nature with professionals or companies with recognized expertise. Available at: https://licitacoesecontratos.tcu.gov.br/5-10-1-3-servicos-tecnicos-especializados-de-natureza-predominantemente-intelectual-com-profissionais-ou-empresas-de-notoria-especializacao-inciso-iii/.
[4] FEDERAL ATTORNEY GENERAL’S OFFICE. AGU Normative Guidance — Normative Guidance No. 107/2026. Available at: https://www.gov.br/agu/pt-br/composicao/cgu/cgu/onsagu.
[5] MINISTRY OF MANAGEMENT AND INNOVATION IN PUBLIC SERVICES. SEGES/MGI Normative Instruction No. 2 of February 7, 2023. Available at: https://www.gov.br/compras/pt-br/acesso-a-informacao/legislacao/instrucoes-normativas/instrucao-normativa-seges-mgi-no-2-de-7-de-fevereiro-de-2023.
Frequently asked questions
No. Consulting Engineering may be a predominantly intellectual specialized technical service, but inexigibilidade requires demonstration in the specific case of lack of viable competition, relevant recognized expertise and the essential role of that provider’s work in fully satisfying the object.
Not as an autonomous requirement under Article 74(III). The TCU notes that Law 14,133 removed singularity of the object and now requires demonstrating that the service is predominantly intellectual and specialized, that the contractor has recognized expertise and that its work is essential and demonstrably adequate to fully satisfy the object.
According to AGU Normative Guidance No. 107/2026, Consulting Engineering services falling under Article 6(XVIII), items a, d and h are specialized technical services of predominantly intellectual nature and cannot be classified as common engineering services.
AGU Normative Guidance 107/2026 identifies competitive procurement as the applicable route, with quality and price as the general rule for these services, except where additional technical-quality assessment is not relevant and other statutory criteria allow a different award method.
Evidence may include prior performance, studies, experience, publications, organization, equipment, technical team and other requirements related to its activities, always demonstrating relevance between that evidence and the object to be contracted.
Not generally. The direct-contracting process still requires planning and must contain the applicable artifacts under Article 72 and relevant regulations. ETP, risk analysis, TR, basic design or executive design may be required according to the nature of the object.
Yes. Price justification is required in the direct-contracting process. When value cannot be estimated through ordinary methods, Article 23, paragraph 4 allows demonstration through similar contracts, invoices within the statutory period or another reliable means.
Article 74, paragraph 4 prohibits, for procurements based on item III, subcontracting companies or using professionals other than those whose qualifications justified inexigibilidade. Team governance is therefore central to execution.
Under inexigibilidade, competition is not feasible. Under dispensa, competition may be feasible, but the law authorizes direct contracting in specific, exhaustive grounds under Article 75.
Supplementary technical materials
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