UK Procurement Act implementation: what do the first three months of data tell us?

We take a first look at the new UK procurement data now coming from 2023’s Procurement Act, which went live on 24 February 2025. 

It’s a big improvement on what was there before. The UK has put in a lot of hard work structuring the new notices, adding identifiers, and bringing all the information together on a central digital platform. Vital information for looking at patterns of competition and fairness is now being collected for the first time. 

The UK now needs to go for the win and put that data to use to drive improved performance and to deliver on important social objectives like SME inclusion in the government’s National Procurement Policy Statement. 

Read on for our analysis and recommendations on how the UK can achieve this. 

A once-in-a-generation reform 

We have long been a cheerleader for UK public procurement reform. Despite the government spending over £380bn a year on procuring goods, works and services – one in every three public pounds – the UK has had remarkably little clarity or visibility over this spending, with shocks like the implosion of Carillion and scandals like the Post Office Horizon IT contracts, the spiralling cost of HS2 and the PPE VIP Lane undermining trust. The UK’s new Procurement Act, passed in late 2023, was a once-in-a-generation opportunity to reform and unify the patchwork of different rules that previously governed procurement. 

There are many important changes in the Act. At its core, the Act mandates a set of notices across the whole cycle of planning and delivering procurement in the UK. These form the basis of the dataset on procurement that will be collected and brought together for the first time on a central digital platform, an upgraded version of the UK’s Find a Tender Service. 

The UK’s Cabinet Office, which is in charge of implementing the new procurement regime, put together an excellent paper on ‘Our Transparency Ambition’ that explains how (and why) the UK needs to improve the accessibility and quality of its procurement data. To that end, all the data from new notices is now structured and accessible as machine-readable open data using the Open Contracting Data Standard (OCDS).

The Act also consolidates the number of procurement procedures with a new competitive, flexible tender that allows contracting authorities greater flexibility in designing multi-staged processes involving negotiation, dialogue or a demonstration (as long as the rules are clear upfront). A new National Procurement Policy Statement lays out the government’s wider strategic priorities for public procurement and how contracting authorities should support their delivery. This is complemented by a shift away from awarding contracts from the Most Economically Advantageous (i.e. cheapest) Tender to the Most Advantageous Tender (ie best value); although this also requires more sophistication and market engagement from authorities to achieve. The Act establishes a new Procurement Regulatory Unit to oversee the implementation of this approach and ensure fair play in how the new flexibilities are applied. 

There were also some transformational ideas that we championed as OCP that did not make it into the Act like building a fully digitalised e-procurement system for the country and reforming the UK’s overly long and legal procurement disputes system.

The new regime went live at the end of February. With three months of data in the books, we thought it was a good time to check on how the implementation of the Act is going. You can access the data that underpins our analysis here. 

First, we analyse the UK’s new public procurement data, up to May 31, 2025, then we assess the improved central digital platform. The regime is still in its early stages of implementation, so we make a series of ‘even better if’ recommendations on where the UK can derive more value and impact from the hard work it has done in structuring and improving the data. 

1. The UK’s new procurement data regime

The UK’s new data regime is a major improvement, with new notices, new data fields and better identifiers. 

The first tranche of new notices is now coming through on the central digital platform, generating richer information on the UK procurement than before. 

New notices. The UK’s new regime adds valuable and important new notices across the procurement cycle. Obviously, not all of them are being used yet as we are still early in the new regime. We are seeing good use of the pipeline (UK1) and preliminary market engagement notices (UK2) which are very helpful to get businesses ready for the coming procurement, as well as encouraging buyers to engage with suppliers to understand better what to buy and how to buy it. A new direct award transparency notice (UK5) is also an important addition for public accountability. 

New fields. The UK’s OCDS data publication maps and publishes all the fields in the new notice types as standardised, machine-readable open data. Compared to last year, some 143 new fields have been added, bringing the total to 551 fields covering the planning, tender, awards, and contracts stages of the procurement lifecycle. 

Importantly, the UK is now collecting new data fields that are particularly useful for analysis and which will also be very useful to track the objectives in the National Procurement Policy Statement. These include the tender suitability field, which helps track opportunities for SMEs and VCSEs, and procuring entity identifiers. The UK is also collecting some critically important new information for monitoring the health of the market and patterns of competition such as the number of bids per tender, as well as new fields tracking if public contracts are delivering social value. New fields are also reporting the win fees on framework contracts to improve the transparency on how these work and to assess if they are good value for money (more on that here).

New usability. Our usability analysis of the new data shows that 57 indicators related to understanding the procurement market, competition, supplier performance, internal efficiency, value for money, and 43 red flags (identifying poor procurement practices) can now be calculated. From a previous analysis conducted by OCP in 2021 on FTS data, only 35 competition indicators could be calculated (we don’t have a baseline for red flags). Overall, this is major progress. 

We’ve already extracted some interesting insights from the data: 

• Early success from pre-market engagement. Since February, almost 600 buyers have published 1691 pre-market engagement notices. The number increased from 22 the last week of February to 322 in March, 517 in April and 831 in May. Premarket engagement, talking to potential suppliers is hugely important to inform better buying decisions so this is a positive development. (Here is an example of a pre-market engagement notice related to purchasing agentic AI for gov.uk)

• The new competitive flexible procedure is gaining traction. We are also seeing increasing use of the flexibility that the Act offers, with a growing number of new competitive flexible procedures each month from 67 in March to 315 in May (159 of which are in the pipeline or pre-market stages). Here is a very topical two stage competitive flexible procedure for engineering services to the UK’s Small Modular Reactor program, This is exactly the kind of situation when you need some qualification and testing of providers, and the contract should not be awarded purely on price as this related to critical national infrastructure, but where you still want some competition and demonstration. 

• More opportunities for SMEs and VCSEs. There are new fields to identify lots that are suitable for SMEs (tender/lots/suitability/sme) and VCSEs (tender/lots/suitability/vcse). The proportion of lots tagged suitable for SMEs has increased from 15.4% in March to 32% in May, and the suitability for VCSEs has increased from 6.8% to 13.7% over the same period. Over a longer time series, we would want to track if SMEs and VCSEs are winning these tenders and, if not, how to help them do so. 

• Quality vs lowest price criteria. The shift from MEAT (Most Economically Advantageous Tender) to MAT (Most Advantageous Tender) signifies a greater emphasis on social value and other non-price considerations. Since the new regime went live, the use of quality criteria has increased in lots from open procedures, from 48.3% in February to 72% in May. However, only 9.5% of lots in open procedures with quality criteria have detailed information about the weights assigned to quality. We recommend encouraging the use of this field (for instance, by adding guidance on how to use it) to be able to better track how quality criteria are being used. 

• Information on direct awards and below-threshold procedures is now being published in one place allowing us to understand patterns for the first time. 15% of procedures published (active and completed) in March were direct awards and it increased to 24% in May. Interestingly, comparing councils that have published at least 30 tenders in the past 3 months, we see significant differences in the use of different procurement methods: 90% of Surrey County Council’s 143 tenders were competitive; compare that to the Mayor Office of the City of London or Bedford Borough Council where the majority or all of their tenders are reported as selective or direct awards. This is exactly the kind of pattern that we should be checking to improve the fairness and competition in the UK procurement market. 

2. Even better if…

We found some data quality issues, which is understandable given that this is a new regime and that there is a significant expansion of information being reported. There are several relatively easy fixes and we would encourage the government to prioritise these. 

• Data dictionary

The UK dataset is comprehensive, with many UK specific extensions to the OCDS relevant to the Procurement Act. It is important to give users a clear explanation of the dataset and what the definition of a particular field is. This is often done with user guidance and a data dictionary. Here’s a great example from the City of Portland’s OCDS publication. Note the Data User Guide and the Glossary and Basic Concepts guidance all of which will be helpful to data users. 

• Data modelling: Standardising new fields and using codelists improves data clarity, usability, and interoperability. Some of these recently added fields will need another look to improve how they’re structured. For example, the data on what non-price or social value criteria are shaping procurement decisions is collected through the tender/awardCriteria/criteria/name, but it’s often left incomplete or filled inconsistently due to its free-text format. 

To give an example from one procurement notice, the award notice says: “The Tender returns will, in part, be evaluated on the basis of tenderers’ approach to delivering social value. Further guidance will be provided in the detailed tender documentation.” So we know some social value metrics are being applied but we don’t know what or how without a detailed, human review of the documents which will limit our ability to draw insights or map connections to the NPPS objectives etc. 

Example of the tender award criteria field 

A codelist is being used more consistently in the tender/lots/awardCriteria/criteria/type, although there are still some null values here. We recommend making this a mandatory field with a standardized codelist to ensure better accuracy and consistency and to encourage the use of the field tender/lots/awardCriteria/criteria/numbers/weight to assign weights to the criteria.

• Make data more accessible via bulk download and in different formats.

Currently, notices are available for download in the Open Contracting Data Standard (OCDS) JSON format using the Find A Tender Service API, allowing users to conduct their own detailed analyses directly from the raw data but using an API assumes quite a level of sophistication from users. The dataset should be bulk downloadable too using a simple ‘click here’ icon. 

Similarly, data will only be available in structured JSON and XML formats on the platform. While these are great for application development, many less sophisticated users prefer simpler tabular formats like Excel or CSV. This is an easy fix. Our OCP UK Data Registry page for Find a Tender Service already provides bulk download, a flattening tool (to convert structured data to simpler spreadsheet formats) as well data profiling tools highlighting quality and coverage issues. All these could easily be adapted and put directly on the UK’s central digital platform enabling suppliers and civil society to download the data for analysis. 

• Organizational identifiers: Identifiers are a core part of the new regime to track tenders, buyers and suppliers but coverage can still be improved. The good news is that buyer IDs have shot up from 12% in the notices published in January 2025 to 43% in March. For suppliers, coverage should improve as registration increases on the new platform, since it reached 36% in May, but has dipped slightly since then.

We noticed cases where the same buyers are using different identifiers and names, which is something to iron out. For example: 

Data availability: We’ve noticed a big improvement in how often new fields are populated in the latest data. While it is expected that some fields are populated with different frequencies depending on the notice types or procurement methods used, we recommend checking the coverage of fields that are most relevant for specific objectives. For example, tender/lots/awardCriteria/criteria/numbers/weigh is not populated on 80% of open procedures, which limits the capacity to understand how quality criteria is being used. For fields with very low usage, it will be important to review their definitions and guidance, and work with procuring entities to clarify when these fields should be filled in. Setting clear expectations and possibly including validation checks in the data collection process will help improve coverage. 

Document coverage: An important change introduced by the Act is in the rules on information disclosure: information may only be withheld on sensitive commercial grounds if the need to protect the data outweighs the public interest in disclosing it. That said, some of the other changes in the Act raised the value threshold for publishing contracts and other documents. 

Currently, document coverage is low, meaning stakeholders might miss important insights into contract tendering, award and management. For example, only 58% of the tenders since the launch of CDP contain links to tender documents. Our quick testing of 100 links suggest that most go to the right documents but about 10% go to registration walls or generic home pages. Overall, better coverage for award and contract documents will be important to improve transparency and accountability. 

3. The new Central Digital Platform

The Central Digital Platform (CDP), the online system referenced in the Procurement Act 2023 has also gone live. The CDP is effectively an upgraded Find a Tender Service with an enhanced UX to make navigation simpler and more intuitive. Search filters have been enhanced to provide additional features, such as a contract suitability filter, which enables SMEs and VCSEs to quickly find relevant opportunities. Clear help messages guide users through procurement concepts and requirements. 

There are several key changes coming from the Procurement Act, principally that all procurement notices and related documents must be published on the platform. Notices are only accepted when all mandatory fields are completed which should improve data quality and compliance. The platform also enables contracting authorities and suppliers to register and receive unique identifiers, ensuring that all public buyers, vendors, procurements, and contracts are consistently linked. These changes are critical to creating a unified, coherent and usable procurement dataset for the UK.

Even better if…

We know the CDP is a work in progress. Here are two things that we would prioritise improving:

• Search functionality, with a procurement’s eye view. We know the platform team is aware of this but the search functionality could be considerably improved on the platform. This could support more structured and detailed conditional query options, including by searching by IDs. We also think there are options to improve how related notices are displayed together to be more user friendly, by showing details from the notices across different phases of a procurement together. 

A unique procurement identifier using the OCID concept is generated when a contracting authority publishes the first notice for a procurement. Every subsequent notice must include this identifier, which links all the procurement’s data into a continuous record that captures activity across the entire lifecycle, which makes it easier for users to monitor the procurement process from start to finish. Find A Tender now gives a helpful ‘Procurement View ‘ of the process, that includes links to each notice (examples here and here).  

However, the user needs to navigate in separate pages to explore the information of a single procedure. Procurement platforms in, for example, Ecuador and Rwanda have made clever use of the OCID by displaying not just the notice types but their data in a single view, with tabs representing different procurement phases. Users can click through each tab to access detailed information for each stage as demonstrated below. This, for example, could help an SME follow a planning notice to the relevant pre-market engagement or tender more easily and track key details.  

• Data analytics and business intelligence. We have saved our most important recommendation to the end: now that the UK has done the hard work of structuring its data and bringing it all together for the first time, we think it is important to go for the win and offer proper business intelligence and analytics from the data on the platform. This is key to delivering on the government’s transparency ambition of going from just collecting data to generating insight and improving procurement performance. 

This should add more value especially for publishers who should be able to set up their own contracting dashboards, and to businesses seeking to understand particular segments of the UK market. We also think this will be important to control authorities like the Competition and Markets Authority and the new Procurement Review Unit at the Cabinet Office to make their monitoring efforts more automated and data-driven. Importantly, good analytics and red flags can detect the warning signs of poor procurement practices and help fix them before things go wrong. 

The costs for doing this will be small (we estimate these at c. GBP100-200K for the CDP) relative to the potentially huge benefits of delivering better procurement performance monitoring and competition in the UK. 

We provide an open source library of many of the performance flags that can be calculated using the OCDS and the new UK data. The new Central Digital Platform is the perfect place to make them accessible to the relevant users. Imagine, for example, if the UK had real-time reporting on patterns of SME inclusion or competition vs backwards looking data.

Giving publishers their data back in an easy to use form will be key to transforming attitudes to transparency, from being seen as something extractive and for other people to catch you out, to something proactive and useful to publishers themselves. We think there is major value here and the UK should prioritize delivering this to the benefit of all the UK’s many buyers, suppliers and procurement watchers. We have seen the benefits of this on competition, fairness and inclusion in countries like Ukraine, Chile, Paraguay, the Dominican Republic and in major cities like Boston and Portland and would be happy to help deliver this in the UK. 

In summary, it is great to see the new UK procurement regime go live and we think there are significant opportunities for added value data analysis and insight from the new regime. Do you agree with our take? Are we missing any other key insights from the data? Want to run your own analysis using the new OCDS data from the UK? You can download it from our Data Registry here!