Procurement Act 2023 Changes for Small Business Suppliers

The Procurement Act 2023 changes how small businesses find, bid for and deliver public contracts. It gives suppliers one platform to register on, an earlier view of opportunities, simpler procedures and stronger payment terms. Those changes lower administrative barriers, but they do not remove the need for preparation. Suppliers gain an edge when they make each new rule part of how they bid.

What the Procurement Act 2023 is and who it covers

Since 24 February 2025, new public-sector procurements in England, Wales and Northern Ireland have operated under the Act. It replaces the Public Contracts Regulations 2015, Utilities Contracts Regulations 2016, Concession Contracts Regulations 2016 and Defence and Security Public Contracts Regulations 2011, with the Procurement Regulations 2024 underneath it. Earlier procurements stay under the old rules until those contracts end.

Geography also determines which rules apply to suppliers. In Scotland, the Act covers UK-wide reserved bodies, but devolved Scottish authorities use Public Contracts Scotland and the Single Procurement Document and follow Scottish procurement law. Section 123 defines an SME as having fewer than 250 staff and either turnover or a balance sheet total below the statutory limits. Suppliers should check and declare that status at registration.

Registering once on the Central Digital Platform and why doing it now matters

The Central Digital Platform, or CDP, lets suppliers enter core company information once rather than repeatedly assemble it for individual buyers. Registration is free through GOV.UK One Login. The record includes company details, accounts, connected persons and exclusion information, and the supplier receives a unique identifier. This shared record is the administrative foundation for participating under the new regime.

An old Find a Tender account does not transfer. Suppliers must re-register, using the same email address if they want saved searches to transfer. Delaying this until a tender opens leaves a basic qualification task competing with bid preparation. Because the platform feeds supplier information directly into bid responses, an incomplete or stale record creates risk beyond the registration itself. The practical action is to complete and audit the record now, then keep it current.

How pipeline notices give small suppliers a head start they did not have before

Mandatory pipeline notices give small suppliers a basis for planning 12–18 months ahead. Authorities that expect to spend more than the applicable annual limit must publish within a set time after the year begins, listing the procurements they plan over the next 18 months that are above the relevant value threshold. The 2026 publication round contains richer data than 2025. Its value depends on what suppliers do next.

Suppliers should put suitable contracts on a bid calendar and work backwards from likely mobilisation dates. That creates time to pursue certifications and plan capacity before the invitation to tender arrives. Preliminary market engagement notices provide a separate opening to introduce the business and help shape specifications. A buyer engaging the market must publish a notice first or explain why it has not.

Planned procurement notices call for more immediate preparation. A qualifying advance notice can allow the buyer to shorten the tendering period to a 10-day minimum. Section 54 otherwise sets minimum periods based on how tenders are submitted and whether documents are available, with the longest period for non-electronic submission. The shortest minimum applies only with a qualifying planned notice or urgency, so waiting for the live tender can surrender much of the available preparation time.

The two procedures that replaced five, and what they mean for how a bid is structured

The Act replaces five competitive procedures with two. Under the open procedure, any supplier can submit a tender in a single stage, with evaluation against published award criteria. This is the lower-friction route for first-time bidders. The competitive flexible procedure gives buyers room to design a process with selection stages, limits on participating suppliers, negotiations or presentations.

Consequently, similar contracts may demand very different bid structures. Suppliers should read the notice for its stages, timetable and evaluation logic before drafting, rather than force every opportunity into the same template. Direct award under Section 41 requires a Schedule 5 justification, with a transparency notice first in almost all cases. A supplier that believes it could deliver a proposed direct award should take advice quickly.

Evaluation also creates information suppliers can use afterwards. Every supplier whose tender is assessed should get an assessment summary that explains its score. A standstill period of at least eight working days follows the contract award notice. Suppliers should read the summary even when they win, because lost marks identify weaknesses to address in the next bid.

How the selection questionnaire changed and what disqualifies small suppliers at the first gate

The Procurement Specific Questionnaire, or PSQ, replaces the old Selection Questionnaire and reduces repeated work. It standardises selection information, with core content held in the CDP record and shared through a share code. Qualification still requires more than a complete profile. Buyers add conditions of participation and may ask for written policies, so it still matters that documents are up to date, signed and dated.

Insurance evidence must match the required levels, while case studies need the right scope and value band, with two examples from the last three years. Figures suggesting the buyer would account for more than around a quarter of annual income can raise resilience concerns. A realistic growth plan addresses these resilience concerns.

Suppliers need to get their exclusion evidence ready before a tender opens. The mandatory grounds in Schedule 6 include tax evasion, modern slavery and certain fraud convictions. Schedule 7 discretionary grounds include poor performance, professional misconduct, environmental misconduct and insolvency. Suppliers should run a readiness check against the next opportunity and document how any previous performance issue was identified and resolved.

Why MAT replaced MEAT, and what it means for how bids are scored

Most Advantageous Tender, or MAT, replaces the previous tender assessment standard and expressly allows buyers to give a lot of weight to non-price factors. Public good outcomes, environmental impact, supply-chain resilience and social value can drive scoring. Price is therefore not the whole competitive argument. A small supplier can justify a higher price through stronger evidence against the published criteria.

Public awards in the cleaning sector show how this works, with scores split across price, quality and social value. A stronger method statement and social value response can outweigh a price disadvantage. An SME can earn marks with a credible net-zero plan, local-delivery model or resilient supply chain, giving these a role beyond background information. Bids should connect that strength to the criterion being assessed.

Social value scoring under PPN 002 and the incoming PPN 026 model

Social value now requires a structured, measurable response within the applicable scoring model. Suppliers should align their evidence to PPN 002 for contracts starting before 1 January 2027 and prepare for PPN 026 for procurements starting from that date. The transition needs attention during bid preparation. A generic statement cannot substitute for answering the model and award criterion that apply to the opportunity.

The Route B structure begins with how the commitment meets the specific criterion. It then identifies the target cohort, or explains how that cohort will be defined during delivery. The response must describe how people will be reached through named channels, partners or geographic logic, and how staff, suppliers, customers and communities will participate. SMART commitments are the minimum scoring threshold, requiring measurable targets, a named delivery mechanism and an accountability plan.

Social Value Portal’s analysis describes a shift from bid-stage promises towards delivery, accountability and measurable outcomes throughout the contract lifecycle. That changes the work behind the response itself. Suppliers need a plan for fulfilling and measuring commitments, because delivery is tracked and published rather than left as an untested statement in the winning bid.

The 30-day payment term and what it changes for small suppliers working down the supply chain

The implied 30-day payment term extends from the main supplier down the supply chain to sub-contractors. This gives smaller firms a contractual protection where payment delays have been particularly difficult. Suppliers working below the prime can use this payment term to plan their cash flow with more certainty.

Invoice validity remains an important practical condition. If a buyer considers an invoice invalid or disputes it, it must notify the supplier without undue delay. For pricing, suppliers should include a cost-pass-through clause and a capped CPI uplift mechanism in their schedules. Transparent cost-per-head stacks also make the price easier to assess under MAT than an opaque flat rate, while the payment term supports planning around those costs.

Thresholds, below-threshold rules, and the VAT trap that catches small suppliers out

From 1 January 2026, the works contract threshold is £5,193,000, including VAT. The VAT treatment is essential when classifying any opportunity. A net quote may sit below the relevant threshold while its VAT-inclusive value exceeds it and triggers the full rules.

A contract becomes notifiable at the applicable lower value for central government, including NHS trusts, or the higher value for other bodies. If the buyer advertises such a contract, it must publish on Find a Tender and give suppliers equal time limits.

The CDP replaces Find a Tender as the primary publication service under the Act, while Contracts Finder is being wound down. Contracts Finder still holds notices under the old rules during that transition. Checking both remains prudent for suppliers seeking opportunities across the two regimes.

KPI publication and the debarment list: how the Act changed what happens after a contract is awarded

Contract delivery now has more visible consequences for future eligibility. For most contracts above the applicable value, buyers must set at least three KPIs and assess and publish performance at least every 12 months. Performance is no longer visible only to the buyer. Underperformance triggers a Contract Performance Notice, and published poor performance is a discretionary exclusion ground that can be referred to the Procurement Review Unit for potential debarment.

A Minister maintains the central debarment list, giving exclusion consequences beyond the authority involved in the original contract. Suppliers should document mobilisation issues, record remediation and retain evidence that problems were identified and resolved as a performance-management discipline.

The six practical steps a small supplier should take now to operate under the new regime

Step 1. Register on Find a Tender and complete the full CDP supplier record before the next tender opens. Obtain the unique identifier and establish a current record that can support bid responses. Suppliers who had an account before should use the same email address when re-registering to keep their saved searches.

Step 2. Read pipeline notices each month and put contracts that suit the business and are above £2 million on a calendar 12–18 months ahead. Use that lead time for certifications, capacity and market engagement. Treat a planned procurement notice as the start of preparation, because the live tender may allow very little time.

Step 3. Build a ready-file of qualification evidence before the pressure of a submission deadline. It should contain insurance certificates at the required levels, signed and dated policies, recent accounts and two relevant case studies from the last three years. Add evidence of what changed after any contract that ended badly.

Step 4. Prepare a social value evidence pack against the applicable model, with the PPN 002 and PPN 026 transition in view. Make each commitment specific, measurable, achievable, relevant and time-bound and connect it to delivery and accountability.

Step 5. Set up free Find a Tender searches and alerts for relevant CPV codes and regions, including planned procurement notices. Check VAT-inclusive values before classifying contracts as below-threshold. With Jonty’s Scout tier, suppliers can find live tenders from Find a Tender, Contracts Finder, Public Contracts Scotland and TED (EU) in one place. Its 21-day free trial lets suppliers look at their actual pipeline before they commit to the paid Bid Manager tier.

Step 6. Use Jonty’s Bid Manager to write and submit a bid once a suitable opportunity has been found. Its AI reads the specification, co-writes the response and submits on approval, addressing the paperwork bottleneck after discovery. For a supplier uncertain whether a particular contract is within reach, the founders take discovery calls directly. Book a discovery call to discuss that opportunity with the team.