Procurement Pulse UK – April 2026

Welcome to Procurement Pulse, DLA Piper’s bulletin for clients with an interest in developments in public procurement law. In this issue, we highlight key UK legislative and guidance developments under the Procurement Act 2023, alongside recent devolved and EU developments relevant to procurement planning, compliance and market access.

POLICY, GUIDANCE AND LEGISLATIVE DEVELOPMENTS

Procurement (Amendment) Regulations 2026 made

The Procurement (Amendment) Regulations 2026 have now been made and introduce a series of targeted amendments to the Procurement Act 2023, with a particular emphasis on transparency and publication obligations. The Procurement Act 2023 regime is now live for new procurements, and these Regulations form part of the final tranche of transparency and publication measures being brought into effect.

Key changes include strengthened transparency requirements under section 70 (including the reporting of payments over GBP30,000), the migration of remaining publication duties onto the Central Digital Platform, new registration requirements for suppliers awarded notifiable below‑threshold contracts, clarification of SME and VCSE reservation provisions, and a new ministerial notification duty for contract terminations on national security grounds.

The section 70 transparency changes came into force on 1 April 2026. Contracting authorities should ensure that procurement, finance and contract management processes are aligned to support compliant reporting. Suppliers should be aware of increased transparency around payment data and additional administrative requirements linked to contract award.

Guidance published on contract payment transparency under section 70

Ahead of the section 70 changes taking effect, the Government Commercial Function has published guidance on the publication of contract payment information.

The guidance confirms that contracting authorities must publish details of payments over GBP30,000 (including VAT) for contracts procured on or after 1 April 2026, via a single quarterly report uploaded to the Central Digital Platform within 30 days of the quarter end. It also clarifies the required data fields, the limited circumstances in which redaction may be permitted, and confirms that responsibility for accurate and timely reporting rests with the paying authority.

Authorities should ensure they have appropriate arrangements in place to comply with the new regime, while suppliers should expect greater visibility of payment performance.

Procurement oversight: New Cabinet Office routes

The Cabinet Office has published updated information on Procurement Compliance & Oversight, including two routes for raising concerns. The Public Procurement Review Service (PPRS) allows suppliers to raise concerns about specific procurements, including late payment, while the Procurement Compliance Service (PCS) focuses on systemic or institutional Procurement Act 2023 compliance issues and does not investigate specific procurement decisions.

Outsourcing: New “two‑tier workforce” framework

The Employment Rights Act 2025 has amended the Procurement Act 2023 by inserting a new Part 5A. This creates an enabling framework for Ministers (and the Scottish and Welsh Ministers) to make regulations and issue a statutory code of practice aimed at protecting workers in relation to relevant outsourcing contracts, including preventing the creation of a “two‑tier workforce”. The Government expects the reinstated “two‑tier Code” to be implemented in October 2026, with contracting authorities required to take “all reasonable steps” to include any specified provisions in relevant outsourcing contracts and to have regard to the code. The practical impact will depend on the detail of the regulations and any applicable code. Authorities and suppliers involved in outsourcing should keep this on the radar when planning and pricing outsourced services, and when reviewing contract terms and workforce models.

UK‑India trade agreement added to Procurement Act framework

The Procurement Act 2023 (Specified International Agreements and Saving Provision) (Amendment) Regulations 2026 have been made and came into force on 30 March 2026. The Regulations implement the procurement chapter of the UK‑India Comprehensive Economic and Trade Agreement by adding it to Schedule 9 of the Procurement Act 2023.

Once in force, the agreement expands the UK’s international procurement obligations, with implications for both contracting authorities and suppliers involved in covered procurements, particularly in relation to market access and treaty‑based compliance.

Welsh and Scottish instruments have also been made implementing the agreement as it applies there.

Wales: Statutory guidance published under the Social Partnership and Public Procurement (Wales) Act 2023

On 23 March 2026, the Welsh Government published final statutory guidance under Part 3 of the Social Partnership and Public Procurement (Wales) Act 2023, alongside a summary of consultation responses and supporting materials.

The published package includes guidance on the operation of the socially responsible procurement duties and the Public Services Outsourcing and Workforce Code, which is intended to promote fair work and workforce considerations in the delivery of public services.

Contracting authorities in Wales are required to have regard to the statutory guidance when exercising functions under Part 3 of the Act. Authorities and suppliers operating in the Welsh public sector should therefore review the guidance closely to understand how the new duties and Code are expected to be applied in practice.

England: Increased flexibility to reserve below‑threshold procurements

An order has been made in England permitting local authorities, in specified circumstances, to reserve below‑threshold procurements to local or UK‑based suppliers. This represents a notable policy shift for lower‑value procurements and may be of interest to authorities seeking to support local supply chains, as well as domestic suppliers and SMEs.

EU DEVELOPMENTS

Signals of further EU procurement reform

The European Commission has launched a public consultation on revising the EU e‑invoicing Directive, and the European Economic and Social Committee has published an exploratory opinion on the planned review of the EU procurement directives. While these developments create no immediate new obligations, they signal potential further reform later in 2026 and may be relevant for organisations operating across UK and EU markets.

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