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This article started life back in 2023, when the Act was still a future promise and everyone was debating exactly when it might land. It’s now well over a year into life as the real, working rulebook for UK public procurement, so here’s our updated take on what it actually means for your day-to-day business, your approach to bidding, and how to keep your go-to-market strategy sharp under the new regime.
When did the Procurement Act come into force?
The Procurement Act 2023 received Royal Assent in October 2023, but its start date slipped twice. It was originally pencilled in for 28th October 2024, then pushed back to give the government time to finalise a new National Procurement Policy Statement. It finally went live on 24th February 2025.
Anything that started life as a procurement before that date (essentially, anything where the invitation to tender had already gone out) continued under the old Public Contracts Regulations 2015. Everything commenced since 24th February 2025 runs under the new rules. So if you’re still bidding into a framework or contract that pre-dates that switch, don’t be surprised to see old-style language and processes hanging around for a while yet.
What changed for suppliers?
Here’s where the Act has genuinely bitten, now that buyers and suppliers are living with it day to day.
Your performance really is out there for everyone to see
Contract management transparency is no longer a “coming soon” feature. Buyers must now publish notices whenever a contract is modified, including increases in total value, and this activity flows through the enhanced Find a Tender Service, which now covers the full contract lifecycle rather than just the tendering stage.
For contracts over £5 million, suppliers are held to at least three KPIs, measured and reported in the public domain throughout delivery. That means your competitors and prospects can see what you’ve sold, how you’ve delivered it, and whether you’ve overrun on budget. There’s real reputational risk in being seen to under-perform, and it hands ammunition to sharper-eyed rivals approaching your buyer at renewal time. In the worst cases, sustained poor performance is a discretionary ground for exclusion and can be referred for debarment.
If you haven’t already, it’s worth reviewing your bid qualification and capture planning processes to build in monitoring of this published performance data, both yours and your competitors’. It’s also worth taking an honest look at which KPIs you can currently measure and report on cleanly, and where the gaps are.
You’re (de)barred!
The central debarment list, which can bar suppliers from bidding for future public work, is now a real, operating feature of the regime. Suppliers who trigger an excludable offence (the familiar mandatory exclusion grounds like bribery, corruption, conspiracy and fraud, plus some newer additions such as modern slavery offences) can be added to it by a Minister, for a set period, and suppliers can challenge their listing in court. Persons of Significant Control, parent companies, consortia and subcontractors are all tested against the same grounds, and suppliers get a chance to rectify and replace an excluded subcontractor before losing out entirely.
In practice, take-up of the list has been slow: at various points since go-live it’s had few, if any, suppliers named on it. That’s not a reason to be relaxed about it. It’s a young mechanism that’s likely to see more use as case law and enforcement bed in, and being named on it, even briefly or on a narrow ground, carries reputational risk that outlasts the listing itself. It’s still worth reviewing your issue resolution processes now: communication channels, response times, escalation routes and service credits that let you get ahead of a problem before it becomes a formal exclusion ground.
MEAT is out, MAT is in
Buyers now assess bids against the “Most Advantageous Tender” (MAT) rather than the old “Most Economically Advantageous Tender” (MEAT). It’s a small change in wording with a real effect on how tenders are scored: value for money is no longer read as primarily a financial calculation, and there’s more room for buyers to weight innovation and social value, even where those are harder to cost out in the short term.
In our experience this has genuinely shifted what’s rewarded in evaluation, particularly for technical, social and cultural value that a purely economic assessment used to underweight. If you haven’t revisited your organisation’s social value strategy in the last year or so, now’s a good time. Buyers are leaning on it more heavily than before, and it needs leadership buy-in, clear goals and initiatives, and a credible way to measure and report on delivery. Quality over quantity still wins here.
New routes to market are now open
The framework landscape has genuinely started to shift. Open frameworks, running for up to eight years and periodically reopening to new suppliers rather than being fully re-run, are now a feature of the live regime. That’s good news if you’re already on one, since you avoid a full re-application, but it also means fresh competition can join at each reopening, so it’s worth keeping a close eye on who’s newly listed alongside you each time.
Dynamic markets are also now operating under published government guidance. They work like the Dynamic Purchasing Systems many suppliers will already be familiar with, except the scope now extends to complex services rather than just commodity goods and services, and suppliers can typically join with only around two weeks’ lead time. That makes them a useful route if you can react quickly to early market engagement and want to get listed in time to bid on live opportunities, rather than waiting for the next full framework re-run.
One more thing worth flagging: procurement thresholds themselves were revised from 1st January 2026, and for most contract types (works, for example, dropped from £5,372,609 to £5,193,000 inclusive of VAT) they came down rather than up. That pulls a slightly wider pool of contracts into scope of the Act’s full requirements, so it’s worth checking whether anything you’d previously treated as below-threshold now needs the full Procurement Act process.
Want a fuller walkthrough of how to build a public sector bidding strategy that works under the current rules? Our Ultimate Guide to Public Sector Bidding is a good next stop.
