Procurement Act 2023: Recent Legislative Changes Explained

Public procurement in the UK has changed significantly over the past year. The Procurement Act 2023 has been rolling out in phases since February 2025, and the most recent wave of procurement changes means the compliance landscape looks very different today from even six months ago.

If you buy or sell public sector contracts, these changes affect you directly. Here is what you need to know.

At a glance: Summary table

What has changed?

When the Act launched, it introduced a framework for greater transparency across the full procurement lifecycle. The latest legislative changes complete that picture. In practical terms, they affect four areas:

• how quickly authorities pay supplier invoices
• reporting of larger payments under public contracts
• recording of supplier performance during contract delivery
• publication of supplier identifiers for certain below-threshold awards

Section 69: Payments Compliance Notices

A Payments Compliance Notice reports a contracting authority’s average time to pay invoices under public contracts. It is intended to show whether an authority is meeting the Act’s implied 30-day payment terms and covers a six-month reporting period. Each notice must include the average days to payment, the share of invoices paid within key time bands, the percentage not paid within the reporting period, and a signed statement from the director or equivalent officer responsible for finance.

Section 69 commenced on 1 January 2026. For the first notice, the government recommends reporting on the period from 1 October 2025 to 31 March 2026, even though the legal requirement only starts from 1 January. That gives authorities a fuller six-month comparison period for future reporting. The first notice must be published between 31 March 2026 and 29 April 2026.

This is one of the clearest signs that Procurement Act compliance now reaches further into day-to-day contract management. It is not just about how a procurement is run at the start. It also reflects how an authority behaves once a contract is live.

Section 70: Contract Payment Information

Section 70 introduces a new obligation to publish contract payment information for individual payments of more than £30,000 including VAT made under public contracts. Unlike the Payments Compliance Notice, this is contract-level data rather than authority-level reporting.

This applies to public contracts arising from procurements that commenced on or after 1 April 2026. Contracts procured under previous regimes are out of scope. Framework agreements, concession contracts, contracts awarded by schools and below-threshold contracts are also excluded. The data must be published quarterly, within 30 days of the end of each quarter, through the Central Digital Platform. Authorities are expected to use the downloadable template in their buyer area rather than submit individual notices for each payment.

The first quarterly submission is due by 29 July 2026, although in practice some authorities may have a little time before the first qualifying contracts generate reportable payments. Even so, this is the kind of change that is easier to deal with early, especially where procurement, finance and contract management teams do not currently share reporting processes.

Section 71: Assessment of Contract Performance

Section 71 requires contracting authorities to publish contract performance notices that record supplier performance. In broad terms, this covers both KPI reporting for certain larger contracts and notices relating to more serious breach or performance issues.

For contracts above £5 million procured under the Act, authorities must publish a Contract Performance Notice at least every 12 months and again on termination. That notice must identify the three KPIs most material to performance, give an assessment against each one, and state the time period covered. There are also circumstances in which breach-related notices must be published within 30 days.

The wider point is that contract management is becoming more visible. Performance is no longer something dealt with only in internal files and review meetings. It is increasingly part of the public procurement record.

Below-threshold supplier identifiers

From 1 April 2026, contracting authorities must collect a unique supplier identifier and publish it in the below-threshold contract details notice where a supplier is awarded a notifiable below-threshold contract. This applies to contracts valued at at least £12,000 including VAT for central government and NHS bodies, and £30,000 including VAT for sub-central authorities.

This change helps close a gap in how supplier participation in below-threshold contracts is recorded. It also links to wider questions around tender notices, particularly where authorities are reviewing how notice workflows fit together under the new regime. For suppliers, especially smaller businesses, this is another reason to make sure registration details are accurate and up to date.

What this means in practice

Taken together, these changes extend the Act’s transparency framework further into contract delivery and reporting. The focus is no longer limited to how procurements start. It also covers how contracts are paid, how performance is recorded, and how supplier information appears in published notices.

For contracting authorities, the immediate priorities are clear:

• review payment processes so data can be matched to the right contracts
• identify who is responsible for compiling and uploading notices
• check that the right people are registered on the Central Digital Platform
• make sure reporting workflows can meet the relevant deadlines

For suppliers, the implications run deeper than they might first appear. Payment timelines are becoming more visible, contract performance records can carry longer-term consequences, and registration requirements will affect how supplier information appears in public data. These wider procurement changes are especially relevant for smaller businesses, which may also want to check the definition of an SME under the Act. The Government Commercial Agency is also worth watching as the wider oversight landscape develops.

Ready to get this right?

The Procurement Act 2023 is reshaping how public contracts are won, managed, and reported. Whether you need to understand your obligations as a buyer or strengthen your position as a supplier, Thornton & Lowe can help.

We work with public sector buyers, third sector organisations, and suppliers of all sizes. Whether you need support with interpreting new legislative requirements or help putting the right internal processes in place, we’re here for your business.

If you are ready to make sure your organisation is ahead of these changes rather than catching up, get in touch with Thornton & Lowe today. Our team will cut through the complexity and help you move forward with confidence.