Procurement Act 2023 one year on: what's actually changed

One year in: theory meets practice

The Procurement Act 2023 went live on 24 February 2025. Our comprehensive guide to the Act covered what was supposed to change. This article covers what actually has.

One year on, the picture is mixed. Some of the Act’s promises are delivering real benefits for care providers. Others have been slower to materialise. And a few practical challenges have emerged that nobody predicted in the guidance documents.

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What is working

Pipeline notices are delivering real intelligence

Pipeline notices — the requirement for large contracting authorities to publish planned procurements over £2 million within 56 days of their financial year start — are one of the Act’s clearest wins.

For care providers, this means visibility of upcoming frameworks, supported living re-procurements, and domiciliary care contracts months before the tender notice lands. Several local authorities published their first pipeline notices in April 2025, and a second round appeared in April 2026.

What providers should be doing: Check Find a Tender for pipeline notices from every local authority you work with or want to work with. These notices give you time to position relationships, prepare evidence, and make bid/no-bid decisions before the pressure of a live tender.

Find a Tender is functioning as a single platform

The enhanced Find a Tender service has consolidated most procurement notices onto one platform. Registration is straightforward, alerts work, and the platform hosts assessment summaries after contract award.

For providers who previously had to monitor multiple portals across different local authorities, this is a genuine improvement. It does not replace authority-specific portals entirely — many councils still run their own systems alongside FTS — but the central platform captures the mandatory notices.

Assessment summaries provide better feedback

Under the old regime, feedback on unsuccessful bids varied wildly. Some commissioners provided detailed scoring breakdowns. Others offered a sentence.

Under the Act, assessment summaries are published on Find a Tender after contract award. You can see your scores, the winning supplier’s scores, and the rationale. This is more consistent than before, though the quality of commentary still depends on the individual commissioner.

Practical benefit: Use assessment summaries to identify scoring patterns across your target authorities. If you consistently score lower on a specific evaluation criterion, that is actionable intelligence for your next bid.

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What is slower than expected

The competitive flexible procedure is being used conservatively

The competitive flexible procedure was presented as a fundamental change — commissioners designing bespoke processes with dialogue, negotiation, presentations, and innovation stages.

In practice, most authorities in the first year have designed CFP processes that closely resemble the old restricted procedure: a selection stage followed by a written tender. The flexibility exists on paper, but many procurement teams are understandably cautious about designing unfamiliar processes while they are still learning the Act.

This is changing. We are seeing more presentation stages in complex care tenders and some authorities experimenting with co-design elements. But if you expected radical process innovation in year one, it has not happened yet. It will.

The SME duty has not yet changed behaviour

The Act requires contracting authorities to “have regard to the fact that small and medium sized enterprises may face particular barriers.” One year on, it is difficult to point to concrete examples of this duty changing procurement design in the care sector.

Requirements that disproportionately affect SME care providers — compressed timescales, excessive insurance thresholds, high-volume evidence demands — are still common. The duty gives you a basis to challenge these in clarification questions, but it has not yet driven systematic change.

Open frameworks are still rare

The Act introduced open frameworks (maximum 8 years, with periodic reopening for new suppliers) alongside closed frameworks (maximum 4 years, fixed membership). Open frameworks were presented as a significant opportunity for providers locked out of existing arrangements.

Most frameworks launched since February 2025 in the care sector have been closed frameworks or dynamic markets. Open frameworks require commissioners to design reopening criteria and manage periodic re-competitions, which adds administrative burden. Uptake will likely grow as template documents improve and authorities gain experience.

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What has caught providers off guard

Dual-regime procurements ran longer than expected

Throughout 2025, many procurements were running under the old PCR 2015 rules (having started before 24 February 2025) while new procurements launched under the Act. This created a period where providers were working under both regimes simultaneously.

For most providers, this transition period has now passed. But some long-running framework procurements that started under PCR 2015 are still concluding. If you are participating in a procurement that started before February 2025, check which regime applies — the rules are different.

Exclusion grounds are broader and more complex

The Act strengthened and broadened mandatory and discretionary exclusion grounds. Providers with any history of regulatory enforcement (CQC warnings, conditions, prosecutions), financial irregularities, or safeguarding failures need to disclose these and explain remediation.

The practical impact: some providers who would have passed PQQ selection under PCR 2015 are now finding the exclusion assessment more searching. If your organisation has any enforcement history, take legal advice on how to present it under the new framework before your next bid.

Transparency creates exposure

More transparency is generally positive. But it cuts both ways. Published assessment summaries mean your competitors can see how you scored. Published KPI performance notices (for contracts over £5 million) mean your delivery performance is public.

For providers who deliver well, this is an advantage. For providers whose delivery has slipped, it creates a public record that commissioners — and competitors — can reference.

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What care providers should have updated by now

If you have not done the following since February 2025, you are behind:

1. Registered on Find a Tender with current company details, insurance, financial accounts, and SME/VCSE status
2. Updated your exclusion self-assessment to reflect the Act’s broader grounds
3. Built a modular evidence library that can be reconfigured for different CFP process designs
4. Set up pipeline notice monitoring for target local authorities
5. Reviewed your tender response templates to remove PCR 2015 references and align with Act terminology
6. Checked your tender compliance checklist against the new requirements

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What is still coming

The Procurement Act’s full impact will take several years to emerge. In the next 12-18 months, expect:

• More varied CFP processes as commissioner confidence grows. Presentation and interview stages will become more common for complex care contracts.
• Open framework launches in adult social care, particularly as existing closed frameworks expire and are re-procured under the Act.
• KPI performance notices creating a public track record for large-contract providers. This will increasingly influence future tender evaluations.
• Stronger exclusion challenges as the case law develops around the Act’s broader grounds.
• Better pipeline notice data as authorities refine what they publish and how early they signal upcoming procurements.

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The bottom line

The Procurement Act 2023 has delivered on transparency. Pipeline notices, assessment summaries, and the Find a Tender platform are genuine improvements for care providers.

The procedural flexibility — the CFP, open frameworks, bespoke process design — is still in its early stages. Commissioners are cautious, and the care sector has not yet seen the radical process variation that the Act enables.

For providers, the practical message is the same as it was a year ago: read every procurement document carefully, use clarification periods actively, maintain a strong and current evidence base, and do not assume familiarity with how things used to work.

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