Four significant transparency obligations under the Procurement Act 2023 came into force between January and April 2026, affecting every contracting authority and supplier operating in the public sector.

These changes are not aspirational, they carry real deadlines, financial thresholds and reputational consequences for those who fall short. The first publication deadline under section 69 falls on 30 April 2026, with section 70 quarterly reporting due by 29 July 2026. Authorities and suppliers that have not yet reviewed their compliance position should act now.

What the changes mean

1. Contracting authorities are required to publish detailed payment and performance data throughout the contract lifecycle.
2. Suppliers will be subject to increased public scrutiny, with performance records and payment timelines made publicly available.
3. Below-threshold suppliers must register on the Central Digital Platform without delay.

Section 70: Information about payments under public contracts

From 1 April 2026, contracting authorities must publicly disclose any individual payment over £30,000 (inc. VAT) made against new public contracts. These disclosures are published quarterly on the Central Digital Platform.

Key points:

• Applies only to procurements commenced under the new regime from 1 April 2026
• The first quarterly reporting period covers 1 April to 30 June 2026
• Publication deadline: 29 July 2026

Together with wider contract reporting obligations under the regulations, section 70 closes a long-standing gap in visibility over where public money goes once a contract is signed. The statutory requirements can be found in Section 70 of the Procurement Act 2023.

Section 69: Payments Compliance Notices (UK17)

Under section 69, public bodies must formally report their average invoice payment times through the UK17 Payments Compliance Notice, demonstrating adherence to the 30-day payment standard. This replaces the previous regime under the Public Contracts Regulations 2015 and introduces a more structured and publicly accessible reporting framework.

Key dates:

• First reporting period: 1 October 2025 to 31 March 2026.
• Publication deadline: 30 April 2026.

Late payment remains a significant issue across the public sector. According to the government's own data, small businesses are owed billions in overdue invoices at any one time, with public sector payment delays contributing to cash flow pressure for SMEs and VCSE organisations. Section 69 directly addresses this by making payment performance a matter of public record.

The statutory requirements can be found in Section 69 of the Procurement Act 2023.

Section 71: Contract Performance Notices (UK9)

From 1 January 2026, contracting authorities in England and Wales must publish supplier performance for contracts over £5 million using the UK9 Contract Performance Notice on the Central Digital Platform.

This notice serves two purposes:

1. Documenting supplier performance against contractual KPIs.
2. Recording details of significant breaches or failures to deliver under the contract.

Annual assessments and reviews at contract termination are required, with all information feeding into a central register. Poor performance is now a matter of public record – with direct implications for supplier reputation and future contract eligibility.

The statutory requirements can be found in Section 71 of the Procurement Act 2023.

Below-threshold contracts: Supplier registration

From 1 April 2026, suppliers awarded notifiable below-threshold contracts must register on the Central Digital Platform and obtain a unique identifier, which must be included in the Contract Details Notice.

Important points for suppliers:

• Registration is required at contract award, not to participate in the procurement.
• Thresholds are £12,000 for central government and £30,000 for sub-central government.
• Registration is a straightforward, one-time process.
• Suppliers who have previously registered do not need to register again.

Next steps for authorities and suppliers

Whilst the policy intent behind these reforms is clear, operational readiness remains a significant compliance risk for public sector bodies. The deadlines are tight, the data requirements are specific, and the consequences of non-compliance are increasingly visible in a regime built around transparency.

Authorities should ensure their internal processes are robust. Publishing a Payments Compliance Notice or a Contract Performance Notice is not simply an administrative task. It requires reliable data, clear sign-off procedures, and director-level accountability. Those who have not yet mapped their contracts against the new thresholds or integrated publication workflows into their contract management processes should act promptly.

For suppliers, the changes are equally important. KPI performance data and payment timelines will now be publicly accessible and searchable. Suppliers should review their current contract terms, understand what is being measured, and engage proactively with authorities where there are performance concerns, before those concerns become part of the public record.

If you would like to discuss how we can support contracting authorities and suppliers navigating the Procurement Act 2023, please contact our team for further information.