New year, new notices, new thresholds
7th January 2026
Now that we're all settling in to 2026, here's a reminder of some important practical procurement changes that kicked in from 1st January.
The Procurement Act 2023 (Commencement No 4) Regulations 2025 (SI 2025/1316) brings two more notice requirements into effect from 1st January:
1. Payments Compliance Notices (Procurement Act 2023, s.69)
This is an authority-level transparency requirement: authorities must publish twice-yearly notices summarising how promptly they pay invoices during each 6 month reporting period (including key payment-timing metrics).
Timing point to note: while s.69 takes effect from 1 January 2026, Gov guidance states that the first reporting period is 1 October 2025 to 31 March 2026, and the first Payments Compliance Notice must be published by 29 April 2026.
For procurements regulated by the Welsh Ministers, this notice comes into effect 1st April 2026.
2. Contract Performance Notices (Procurement Act 2023, s.71)
This notice has two functions:
a) KPI Performance related reporting for above-threshold contracts over £5m awarded under the Procurement Act 2023. Authorities must assess performance against the KPIs set out in the contract (at least annually and on termination) and publish the required information on the Gov site.
b) Reporting of breaches and/or failure to perform (except where the breach results in termination). This applies to all public contracts, not just those above £5m and must be published within 30 days of the day on which section 71(5) first applies
For procurements regulated by the Welsh Ministers, this notice comes into effect 1st April 2026.
Thresholds reminder
Procurement thresholds have also changed via the Procurement Act 2023 (Threshold Amounts) (Amendment) Regulations 2025 from 1st January 2026. The new thresholds are a reduction on the previous levels, so a greater proportion of spend will now fall under the regulated regime. Authorities should ensure their internal procedures and approval routes reflect these new limits.
See previous news article (below) for details on the threshold amounts.
If you would like further information or advice on the changes to public procurement please contact our consultants:
Claire Paton on 07828 143935 or
cpaton@cirruspurchasing.co.uk
Tashi Jackson on 07904 674499 or
tjackson@cirruspurchasing.co.uk