The Cabinet Office has updated the Procurement Policy Note 02/23: Tackling Modern Slavery in Government Supply Chains (PPN 02/23) to reflect publication of the 2023 Global Slavery Index.

The Cabinet Office has added two new Procurement Policy Notes (PPNs) to the suite of PPNs republished in conjunction with the Procurement Act 2023 (PA 2023) go-live—PPN 020: Guidance on data protection legislation and PPN 021: Payment Spot Checks in Public Sub-Contracts. PPN 020: Guidance on data protection legislation provides updated guidance on relevant data protection requirements under the UK GDPR and the UK International Data Transfer Agreement (IDTA) governing the export of personal data from the UK. PPN 020 applies with immediate effect. It replaces PPN 03/22 which contained streamlined guidance and updated model clauses to take account of the UK’s exit from the EU. It also includes guidance on international transfers of personal data. PPN 020 does not constitute a change in policy, but in-scope organisations should circulate and adhere to the guidance and use the updated model clauses at Annex A for new contracts. PPN 021: Payment Spot Checks in Public Sub-Contracts provides guidance and templates for contracting authorities to spot check public contract supply chains to ensure suppliers meet the payment terms set out in PA 2023. PPN 021 includes additional guidance on how in-scope organisations should conduct spot checks to ensure the correct payment terms are being included and adhered to by suppliers, plus model terms at Annex A which support spot checks being carried out. PPN 021 applies from 1 October 2025. Both PPNs apply to all central government departments, their executive agencies and non-departmental public bodies.

The Cabinet Office has published updates to its guidance on contract payment information, amending paragraphs six and 17. Paragraph six confirms that section 70 of the Procurement Act 2023 applies to payments made under call‑off contracts awarded in accordance with a framework or by reference to a dynamic market, where the contracts are public contracts and the procurement commenced on or after 1 April 2026. Paragraph 17 clarifies that contracting authorities do not need to publish payment information for payments made under public contracts procured under the previous procurement regime or where the procurement procedure commenced prior to 1 April 2026, even if the contract is awarded after that date.

The Cabinet Office has updated its guidance on utilities contracts and exempted contracts under the Procurement Act 2023 (PA 2023). The main substantive changes incorporate guidance on calculation provisions included in the Procurement Act 2023 (Consequential and Other Amendments) Regulations 2025. The utilities contracts guidance includes new material at paragraphs 31–43, about calculations relating to the ‘turnover test’ under regulation 42C of the Procurement Regulations 2024 (PR 2024), SI 2024/692. The turnover test is used to determine whether a supplier is affiliated to a utility for the purposes of the exemption in PA 2023, paragraph 6(3) of Schedule 2. The exempted contracts guidance includes new material at Annex B, on the tests for calculation of activities for vertical and horizontal arrangements, including guidance on the ‘attributable turnover’ and ‘non-attributable turnover’ calculations set out in PR 2024, SI 2024/692, regs 42A and 42B.

The Cabinet Office has updated its Procurement Act 2023 (PA 2023) 'Manage phase' guidance, including its guidance titled ‘Guidance: Contract Payment Information’, to provide further clarity on valuing contracts and payments. The 20 July 2026 update clarifies that, for the purposes of PA 2023, s 70, a framework call-off contract is treated as commencing before 1 April 2026 where, before that date, a contracting authority had contacted a supplier to commence the award of the contract. It also confirms that PA 2023, s 70 applies to payments made under a convertible contract following conversion under PA 2023, s 74(1), provided the procurement commenced on or after 1 April 2026, and explains that where a payment covers more than one in-scope public contract, publication is required only if the £30,000 threshold is exceeded in respect of a single contract, with only the amount relating to that contract to be reported.

The Cabinet Office has replaced its remedies guidance in the Procurement Act 2023 procure phase guidance document collection with a new version.

The Cabinet Office has updated its UK Common Frameworks programme by advancing three frameworks from provisional to fully implemented status. The full operational frameworks are: the Late Payment Common Framework from the Department for Business and Trade (DBT) and two frameworks from the Department for Health and Social Care: one addressing blood safety and quality, and another covering organs, tissues, and cells (excluding embryos and gametes).  These Common Frameworks were established during the EU exit negotiations to manage potential intra-UK divergence in devolved policy areas that were previously regulated by EU law. The frameworks outline intergovernmental working arrangements among the UK and the devolved governments. They detail meeting structures, decision-making processes, dispute resolution mechanisms, information sharing protocols, and review processes.

The Cabinet Office has updated a number of documents in the Procurement Act 2023 (PA 2023) manage phase guidance collection. Subjects covered include: contract modification, key performance indicators, contract termination, contract performance notices, payments compliance notices, and electronic invoicing and payment. Previous versions of the guidance were issued ahead of the PA 2023 go-live in February 2025. A review of the updated documents suggests there are no major changes to the guidance. There are some minor updates to the guidance on contract modification, which are primarily formatting amendments. We will continue to monitor the guidance pages for substantive updates.

The Cabinet Office has issued an update to the National Security and Investment (NSI) notification service guidance. As of 11 November 2024, the section 'Supply relationships with the UK government' in the document 'Guidance on completing and registering a notification form' has been revised. This update is part of ongoing refinements to the National Security and Investment Act 2021 implementation, which requires certain acquisitions to be notified to the government for national security screening. Legal practitioners should note that this change may affect how entities report their supply relationships with the UK government when submitting notifications through the NSI service.

The Cabinet Office has published updated guidance on Payments Compliance Notices under the Procurement Act 2023 (PA 2023). The requirements for contracting authorities to publish payments compliance notices on the central digital platform are set out in PA 2023, s 69 and regulation 38 of the Procurement Regulations 2024. The guidance has been updated to clarify certain policy aspects in response to queries from contracting authorities, including reporting of payments made in compliance with PA 2023, s 68(2). As noted previously, further regulations are required to bring the relevant provisions of PA 2023, s 69 into force. These regulations are anticipated Q1 2026.

The Cabinet Office has published updated guidance on Payments Compliance Notices under the Procurement Act 2023 (PA 2023). The requirements for contracting authorities to publish payments compliance notices on the central digital platform are set out in PA 2023, s 69 and regulation 38 of the Procurement Regulations 2024. The updated guidance clarifies that as part of the phased implementation of PA 2023, contracting authorities are not required to publish payments compliance notices until PA 2023, s 69 comes into force on 1 October 2025 (see para 45). Annex A (template for interim payments compliance notices) has been removed from the guidance accordingly.

The Cabinet Office has published updated guidance on valuation of contracts under the Procurement Act 2023 (PA 2023). The guidance has been updated to reflect edits to the section entitled ‘what has changed?’ (paragraphs 6-9). While the rules and methodologies under PA 2023 are broadly similar to the approach under the Public Contracts Regulations 2015, there are differences, as outlined in this section of the updated guidance. Subjects covered include situations where estimates are not possible, to ensure compliance with international agreements such as the Comprehensive and Progressive Agreement for Trans-Pacific Partnership, and replacement of the concept of ‘Separate Operational Units’ with anti-avoidance mechanisms within PA 2023 which preserve flexibility for contracting authorities regarding aggregation of requirements. Additionally, the guidance recommends considering additional amounts suppliers may receive from third parties when valuing certain types of public contracts, particularly non-concession contracts involving site development or regeneration.