UK Contract Management and the Procurement Act 2023

The UK Procurement Act 2023 came into force on 24 February 2025, and it changes what "managing a public contract" means for anyone selling to, or buying for, a UK public body. This guide is published by Adira, which makes contract lifecycle management (CLM) software, so we have a commercial interest in you finding this useful. Adira's deepest jurisdiction is India, not the UK, and this page is written honestly on that basis: it explains the Act's contract management obligations in enough detail to be useful, without pretending we have UK-specific product depth we do not have yet.

The short version: the Act does not just change how contracts are awarded. It creates ongoing obligations that run for the life of the contract, publishing performance data, tracking notice deadlines, and getting modifications approved before you make them. Miss one and the exposure is not abstract, it is a notice on a public platform, or a contract that cannot legally be varied the way you assumed it could.

What the Act actually is, and its current status

The Procurement Act 2023 (also called the Procurement Act 2023, Chapter 54) received Royal Assent in October 2023 but did not take effect immediately. Its commencement was delayed once, from an original go-live of 28 October 2024, to allow time to finalise the National Procurement Policy Statement and secondary regulations. It came into force on 24 February 2025, replacing the previous regime built on the Public Contracts Regulations 2015 and related instruments. Procurement Act 2023, legislation.gov.uk.

The Act consolidates rules that used to sit across several separate regulations (public sector, utilities, concessions, defence and security) into one statute, and it applies across England, Wales, and Northern Ireland (Scotland runs its own regime). It governs roughly £385 billion a year in public spending, from central government departments down to NHS trusts and local councils. Transforming Public Procurement, GOV.UK. As of this writing the Act has been live for about a year and a half; check the commencement and amendment history on the legislation.gov.uk page above before relying on any specific figure here, since procurement regulations get amended often.

Five things that change for contract management, not just contract award

Most coverage of the Act focuses on the award stage: new procedures, new exclusion grounds, a new "most advantageous tender" test replacing "most economically advantageous tender." That is real, but it is not what breaks teams after the ink is dry. The five changes below are the ones that create ongoing contract management work.

One: transparency notices run through the whole contract lifecycle

Under the previous regime, most of the paperwork stopped once a contract was awarded and the award notice was published. Under the Act, notices continue through performance, modification, and termination, and a contracting authority has to publish a defined notice at each of these points, not just at the start.

Two: KPIs are mandatory and public for contracts above £5 million

Section 52 of the Act requires that "before entering into a public contract with an estimated value of more than £5 million, a contracting authority is generally required to set at least three KPIs in respect of the contract." A KPI itself is defined in the Act as "a factor or measure against which a supplier's performance of a contract can be assessed during the life-cycle of the contract" (section 52(1)). Section 52, Procurement Act 2023.

The KPIs a contracting authority regards as most material have to be published in the Contract Details Notice, and then performance against them has to be publicly reported (see below). Section 52(6) exempts frameworks, utilities contracts awarded by private utilities, concession contracts, and light touch contracts, and it also does not apply where performance genuinely cannot be measured against KPIs.

The test you can run: take the estimated total value of your public contract over its full term, including any renewal periods already built in. If that figure is above £5 million, search Find a Tender for the contract's Contract Details Notice. If at least three named KPIs are not listed there, either the contract is exempt under section 52(6), or the notice is incomplete and worth raising with the contracting authority.

Three: performance gets published, not just measured

Section 71 sets the reporting rhythm once KPIs exist. "At least once in every period of twelve months during the life-cycle of the contract and on termination of the contract," the contracting authority must assess performance against the KPIs and publish that assessment. Section 71, Procurement Act 2023. Separately, a breach leading to termination, damages, or a settlement, or unsatisfactory performance left unremedied, has to be published within 30 days. For a supplier, this means your performance record on this contract is a Contract Performance Notice, published and visible to competitors and future buyers when you bid for the next one.

Four: the Central Digital Platform is where all of this lives

Instead of notices scattered across separate portals, the Act routes required notices through a single Central Digital Platform, accessed through the Find a Tender service, where Contract Details Notices, KPI data, performance notices, and change notices all land in one searchable place. Transforming Public Procurement, GOV.UK. Section 53 sets the deadline for the first of these: a Contract Details Notice must be published within 30 days of the contract being entered into, or within 120 days for a light touch contract. Section 53, Procurement Act 2023. For contracts above £5 million, the authority also has to publish a copy of the contract itself, with appropriate redactions, a meaningfully higher transparency bar than before.

Five: conflicts of interest and exclusions are an active, ongoing duty

Section 81(1) requires that "contracting authorities must take all reasonable steps to identify, and keep under review, in relation to a procurement, any conflicts of interest, or potential conflicts of interest," where an "interest" includes "a personal, professional or financial interest that may be direct or indirect" (section 81(4)). Section 81, Procurement Act 2023. "Keep under review" is the operative phrase: this is not a one-time check at bid stage, it runs for as long as the procurement and the resulting contract exists. Where a conflict gives a supplier an unfair advantage that cannot be mitigated, or the supplier refuses the mitigation steps asked of it, section 82(3) and (4) require that supplier to be treated as excluded.

Alongside this sit the exclusion grounds: Schedule 6 lists mandatory grounds (relevant criminal convictions, tax non-compliance, certain competition law infringements), and Schedule 7 lists discretionary grounds (professional misconduct, poor performance on an earlier contract, labour and environmental misconduct). Schedule 6 and Schedule 7, Procurement Act 2023. A supplier's poor performance on one contract, evidenced by the Contract Performance Notices under point three, can become a discretionary exclusion ground on the next one; transparency and exclusion feed each other by design.

Six: modification rules apply to routine changes too

Section 75 requires a Contract Change Notice before modifying a public contract, unless the change moves the contract's value by 10% or less for goods and services, or 15% or less for works. Section 75, Procurement Act 2023. Above that, the modification must fit one of ten permitted grounds in Schedule 8, such as urgency or a known risk that materialises. Schedule 8, Procurement Act 2023. A scope change a contract manager once handled as a routine variation now needs checking against Schedule 8 and, in most cases, public notice before it takes effect, not after.

What this means for suppliers and buyers

If you hold or bid for a public contract in scope, the practical obligation-tracking list is: know your contract's value against the £5 million KPI threshold and your next 12-month assessment date; track the 30-day breach-notice clock separately from that annual one; check any scope, price, or term change against section 75 and Schedule 8 before agreeing it, since a modification made without a required notice is vulnerable to challenge even if your buyer contact said it was fine; keep conflicts-of-interest disclosures current through the life of the contract, not just at bid stage; and expect a published Contract Performance Notice about you to be read by your next buyer.

For a contracting authority, the burden shifts from a single award-stage compliance exercise to a standing reporting operation: KPI publication before signature, annual and breach-triggered performance notices, a Contract Change Notice workflow before any material variation, and a documented, ongoing conflicts review. Missing a deadline does not usually void the contract, but it is exactly the gap a losing bidder looks for when challenging an award or a modification.

Red flags in how a UK public contract is being managed

Normal	Red flag	Why it matters
KPIs named and published in the Contract Details Notice for a contract over £5 million	"KPIs to be agreed post-award" or no KPIs published at all	Section 52 requires at least three KPIs be set before the contract is entered into, not after
A named owner and calendar reminder for the 12-month performance assessment	Nobody owns the annual review; it gets done "when the buyer asks for it"	Section 71 sets a fixed 12-month cadence; missing it is a compliance gap the authority, not just the supplier, is exposed on
A breach or performance issue reported through the proper channel within 30 days	An informal email chain instead of a Contract Performance Notice	Section 71(5) requires public notice within 30 days for terminations, damages, or unremedied poor performance
Every scope, price, or term change checked against Schedule 8 before it is agreed	"We'll just email confirming the change" for anything material	An unnotified modification outside the de minimis thresholds is not a permitted modification and can be challenged
A conflicts-of-interest register reviewed through the life of the procurement	A one-off conflicts declaration collected at tender stage only	Section 81 is a continuing duty to identify and keep conflicts under review, not a box ticked once
Prior Contract Performance Notices checked before submitting a new bid	A supplier assumes past poor performance on another public contract is invisible to the new buyer	Schedule 7's discretionary exclusion grounds include poor performance on an earlier public contract, and it is now a matter of public record

A contract clause: bad versus better

A KPI and reporting clause written for the old regime, dropped unchanged into a post-Act contract, is a common failure point.

Bad: "The Supplier shall use reasonable endeavours to meet the performance standards agreed between the parties from time to time, and the Authority may review performance as it considers appropriate."

What is wrong: no specific KPIs, no measurement or publication cadence, and discretion over when review happens, none of which satisfies a statutory duty that runs on a fixed 12-month clock regardless of what the parties privately agree.

Better: "The Supplier's performance of this Agreement shall be measured against the key performance indicators set out in Schedule [X], which reflect the KPIs published in the Contract Details Notice under section 52 of the Procurement Act 2023. The Authority shall assess the Supplier's performance against these KPIs at least once in every 12-month period, and on termination, and shall publish that assessment as a Contract Performance Notice under section 71. Where the Supplier is in breach of this Agreement resulting in termination, an award of damages, or a settlement, or where the Supplier has not remedied unsatisfactory performance within the period notified by the Authority, the Authority shall publish that information within 30 days as required by section 71(5). No modification to the scope, price, or term of this Agreement shall take effect unless it is a permitted modification under Schedule 8 of the Act, and any Contract Change Notice required under section 75 has been published."

What changed and why: it ties the clause's KPIs to the ones actually published in the statutory notice, fixes the review and publication cadence to the statutory clock instead of the authority's discretion, and makes the modification restriction explicit so a contract manager cannot accidentally agree a change the Act does not permit.

How the compliance and reporting burden compares to India

If your organisation also manages contracts in India, the honest contrast is that India has no single equivalent to the Procurement Act 2023. Public procurement by central government ministries and departments runs on the General Financial Rules, 2017 (GFR 2017), an administrative rulebook issued by the Ministry of Finance, not a standalone statute passed by Parliament. Rule 149 of the GFR mandates that procurement of goods and services available on the Government e-Marketplace (GeM) go through GeM, with the process tiered by value: direct purchase, bidding, or reverse auction. General Financial Rules, 2017, Department of Expenditure.

The practical difference is that India's regime concentrates transparency at the procurement and award stage, through GeM's own portal, rather than mandating ongoing, statutory, public KPI reporting through the life of the contract the way sections 52 and 71 of the UK Act now do. A supplier managing both a UK public contract and an Indian government contract is dealing with two genuinely different obligation shapes, not the same rules under different names, and treating them as interchangeable is where compliance calendars go wrong. This is also the honest limit of what Adira can tell you here: Adira's statutory depth, quoted, linked, case-verified obligations tracking, is built for India first, and this UK explainer is written to be accurate and useful without claiming UK-specific product depth Adira does not yet have.

How a CLM helps, and what it does not remove

None of the five obligations above go away because you own software. What a CLM can do is put the deadlines and owners in one place instead of scattered across email threads and a contract manager's memory, attaching the KPI review date and the modification-notice check to the contract record itself, so the 12-month clock in section 71 does not depend on someone remembering it. Adira's paid plans (Practice at $89 to $109 per seat per month, Firm at $179 to $219, Enterprise on custom pricing, all with a 7-day trial, as published on adiralaw.com, last verified 4 September 2026) build this kind of obligation tracking for contracts generally, across 40+ jurisdictions, though the UK-specific statutory checks described here are early for us, not a claimed depth. To check, for free, whether a UK public contract's KPI and modification clauses are drafted the way this guide describes, you can mark the document up in Weave, which flags missing dates, undefined review triggers, and vague modification language on the contract itself, no account needed.

For the obligation-tracking discipline this guide assumes (owners, deadlines, evidence of compliance) in more general terms, see what obligation management actually means. For a closer look at contract management software built specifically for the UK market, see contract management software UK.

FAQ

When did the Procurement Act 2023 actually come into force? 24 February 2025, after being delayed once from an original date of 28 October 2024. Check legislation.gov.uk for amendments made after this guide was written before relying on a specific figure.

Does the £5 million KPI threshold apply to the whole contract value or a single year? The contract's estimated total value over its full term, including built-in renewal periods, not annual spend. Section 52(6) also exempts certain contract types regardless of value: frameworks, some utilities and concession contracts, and light touch contracts.

If a contracting authority misses the 30-day Contract Details Notice deadline, does that void the contract? No. It does not automatically void the contract, but it is a compliance failure that can attract a legal challenge, particularly from a losing bidder, and it undermines the transparency the Act is built around.

Can a public contract's scope be changed without a Contract Change Notice? Only if the change stays within the de minimis thresholds (10% or less for goods and services, 15% or less for works) or fits one of the ten permitted grounds in Schedule 8. Outside those, a Contract Change Notice under section 75 is required first.

Does Adira have the same statutory depth for UK procurement contracts that it has for India? No, and this guide says so plainly. Adira's deepest, most specific statutory coverage, quoted sections, named cases, checkable obligations, is built for India. This page is accurate on the UK Procurement Act 2023 as of its last verification date, but it is not evidence of that same depth for UK law.

This guide explains what the Procurement Act 2023 requires for contract management in general terms, with the specific sections and thresholds that were current when this was last verified. It does not tell you whether your specific contract is in scope, which exclusion or modification ground applies to your situation, or how a UK public procurement dispute would actually be decided. Confirm the current position on legislation.gov.uk and the Find a Tender service, and talk to a lawyer qualified in UK public procurement law before you rely on this for a real contract. This is not legal advice.