The Cabinet Office has introduced a new way to investigate and improve compliance with the Procurement Act 2023: the Procurement Compliance Service (PCS). PCS forms part of the wider oversight framework designed to raise standards and increase confidence in public procurement.
In this post, we explain what PCS is, how it differs from existing routes like the Public Procurement Review Service (PPRS), what a PCS investigation can cover, and the practical steps contracting authorities can take now to reduce risk and improve readiness.
What is the Procurement Compliance Service?
PCS focuses on investigating in-scope contracting authorities’ compliance with the requirements of the Procurement Act 2023. It covers both central government and the wider public sector, including organisations such as the NHS, local government and universities.
PCS opened for referrals on 23 February 2026, marking a change in how public procurement is investigated and improved across the UK. PCS is intended to work with contracting authorities to increase capability, improve processes and drive compliance.
PCS sits within the Cabinet Office’s Procurement Review Unit (PRU), which has responsibility for oversight of the new regime.
What role will the PCS have?
PCS sits alongside the Public Procurement Review Service (PPRS) within the PRU structure.
In straightforward terms:
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PPRS investigates supplier concerns about specific procurements and can look at themes such as poor practice and late payment.
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PCS takes a wider view, focusing on systemic or institutional compliance issues under the Procurement Act 2023.
PCS is expected to focus on systemic issues (breaches common across multiple authorities) and institutional issues (recurring issues within one authority).
If you want a wider view of how PRU services sit together, our explainer on the Procurement Review Unit covers the oversight routes and what they mean in practice.
What can the Procurement Compliance Service investigate?
PCS can use the statutory powers in Part 10 of the Procurement Act 2023 to investigate a relevant contracting authority’s compliance with the Act. Where appropriate, PCS may issue recommendations to the contracting authority about the action it should take to comply with the Act, and it may also publish guidance that applies more generally.
There are also clear limits. GOV.UK guidance explains that a PCS recommendation cannot relate to:
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compliance with procurement objectives under section 12
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the National Procurement Policy Statement (or Welsh equivalent)
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the duty to consider SMEs in regulated below-threshold contracts under section 86
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the exercise of a contracting authority’s discretion in procurements
This distinction is important. PCS is primarily about legal and procedural compliance with the regime, rather than second-guessing policy choices or the use of discretion where the Act permits it.
What to expect during a PCS investigation
PCS has the power to require a contracting authority being investigated to provide relevant documents and to give reasonable assistance, using a formal notice where appropriate.
A PCS investigation may lead to:
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Findings and recommendations that will be captured in a report, which may be published on GOV.UK.
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Contracting authorities being asked to provide progress reports, which could include an action plan, and these may also be published.
While the Act does not set fixed limits for investigations, PCS will focus on systemic and institutional issues, but is not limited to them.
Practically, that means your “file quality” and your ability to explain decisions clearly matter. If a process is repeatable, it should also be consistently evidenced.
Why PCS matters for contracting authorities
PCS is not just another complaint route. It is part of a deliberate shift towards continuous improvement and accountability under the new regime.
For contracting authorities, the most immediate implications are that:
Evidence and audit trail will be tested
If you cannot retrieve the key documents and decision trail quickly, responding becomes harder and risk increases. PCS can require documents and assistance, so document management and record retention are no longer back-office details.
Repeat issues are likely to be the focus
PCS is aimed at patterns: the things that show up across multiple procurements, or within one organisation over time.
Governance and capability become visible
The PRU’s stated ambition includes improving the capability and practices of contracting authorities by ensuring compliance with the new rules.
Practical steps to take now
The goal is not to create extra paperwork. It is to make sure your process is compliant, consistent, and easy to explain.
Tighten the “minimum defensible record” for every procurement
Define what you must retain for each stage, then standardise it. In many organisations, the gaps show up in the same places: evaluation records, moderation notes, conflict declarations, clarifications, and sign-off trails.
Stress-test your templates and workflows against the Act and guidance
PCS is about compliance with the Procurement Act 2023 requirements and related guidance. Keeping templates aligned reduces the chance of repeat issues becoming institutional ones.
Make document retrieval easy under pressure
If you received a notice requesting documents, could you pull them quickly and confidently, with version control intact? If not, set a simple folder and naming convention that mirrors your stages and notices.
Run an internal compliance review focused on repeat failure points
A short, targeted review often delivers more value than a broad “check everything” exercise. Prioritise areas where your team runs the most volume, or where judgement is most frequently challenged.
What suppliers and stakeholders should take from PCS
Suppliers will still use established routes like PPRS when the issue is about a specific procurement. PCS, by contrast, is set up to look at broader compliance themes, with an emphasis on systemic or institutional issues.
The Cabinet Office update we received also emphasised that referrals to PCS are not limited to suppliers, which signals a wider approach to identifying compliance risks (Cabinet Office email update provided to us by subscribers, February 2026).
How Thornton & Lowe can help
PCS is designed to strengthen compliance and raise capability under the Procurement Act 2023. For contracting authorities, that makes this a good moment to sense-check the fundamentals: governance, records, templates, and repeatable processes that stand up to scrutiny.
Thornton & Lowe supports contracting authorities with practical, proportionate compliance reviews, template and process improvements, and targeted training, all geared around day-to-day delivery rather than added bureaucracy. If you want to understand your current level of readiness, we can help you prioritise the changes that will make the biggest difference and build an action plan your team can implement.
If you’d like to discuss a Procurement Act 2023 compliance health check or targeted support, get in touch with our team.
