Procurement Act 2023 payment reporting and KPI notices: what suppliers need to know now

The Procurement Act 2023 has been rolling out in stages since February 2025, but the months surrounding April 2026 mark a significant turning point. From 1 April 2026, new transparency provisions come into force, introducing payment reporting, supplier registration on the Central Digital Platform (CDP), and expanded publication of contract performance information. For suppliers delivering public contracts, and for the procurement and compliance professionals who assess them, this is the moment the new regime starts producing genuinely searchable, publicly visible data on how suppliers perform and get paid.

What changed in January 2026 and why it matters

Two of the most consequential provisions came into force on 1 January 2026, before the April changes arrived.

Section 69, which governs payments compliance notices, and section 71, covering assessment of contract performance, were both brought into force for procurements under the Act from 1 January 2026. These two sections sit at the heart of the new transparency architecture.

A payments compliance notice sets out the extent to which, over a reporting period of six months, the contracting authority has paid its invoices in accordance with the implied 30-day payment term under section 68(2) of the Act. It also covers other reporting requirements relating to when invoices were paid. The first reporting period ran from 1 October 2025 to 31 March 2026, and the second runs from 1 April 2026 to 30 September 2026, with each successive six months constituting a new reporting period. The first UK17 Payments Compliance Notice had to be published between 31 March 2026 and 29 April 2026.

A Contract Performance Notice (the UK9 notice) is used to publish information required under section 71. It fulfils two functions: recording the performance of suppliers against key performance indicators (KPIs) where section 52(1) of the Act applies, and recording information relating to particular breaches or failure to perform a public contract.

How KPIs work under the new regime

The introduction of mandatory, published KPIs is one of the most significant structural changes the Procurement Act 2023 brings. This is the first time that KPIs have been legislated for in UK public procurement legislation.

A KPI 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. By setting targets for the desired level of performance against KPIs, a contracting authority can measure and demonstrate a supplier's progress against those targets. Where KPIs apply, they will be set out in the contract between the contracting authority and the supplier.

These requirements expand the current KPI reporting requirement policy for central government contracting authorities and their associated arm's length bodies to the majority of public contracts above £5 million. Where a contracting authority has set KPIs under section 52(1), section 71 requires that it must, at least once in every twelve-month period during the lifetime of the contract and on termination, assess the supplier's performance against those KPIs and publish certain information in relation to that assessment in the Contract Performance Notice.

Each KPI must be rated using a standardised scale. The notice is used to assess the performance of a supplier against the relevant KPIs and must be rated either good, approaching target, requires improvement, inadequate, or "other". The "other" rating can be used, for example, where no KPI data has been recorded for a given period. Once published on the CDP, those ratings are visible to any other contracting authority considering the supplier for a future contract, which is precisely the point.

The assessment regime is the bigger issue for suppliers because section 71 also requires the contracting authority to publish information relating to particular breaches of contract or failure to perform a public contract. Section 71(5) states that if there is a breach of contract which has resulted in termination, the award of damages, or a settlement agreement, the contracting authority must publish that information within 30 days. The publication requirements also apply if a contracting authority considers that a supplier is not performing the contract to its satisfaction, has been given a proper opportunity to remedy the breach or improve performance, and has failed to do so.

The section 70 payment data now going public

Section 70 introduces a duty on contracting authorities to publish quarterly "significant payment notices" detailing payments over £30,000 made under public contracts awarded under the new regime. The requirement applies to contracts awarded following procedures commenced on or after 1 April 2026, with reports to be published on the Central Digital Platform within 30 days of the end of each reporting quarter.

Although the statutory obligation of publication falls on public bodies, the commercial consequences of these new requirements will be felt by suppliers. Payment flows above £30,000 are now, in effect, part of the public record for any contract within scope. A supplier receiving large mobilisation payments or milestone payments on a multi-year contract should understand that those figures will appear alongside their name on a searchable platform, linked to the Contract Performance Notice for the same contract. The combined picture tells a story that other buyers, competitors, and due diligence platforms will be able to read.

The Central Digital Platform and your unique identifier

Find a Tender is the Central Digital Platform, where all UK contracting authorities publish information relating to procurement. It is also the place where identifiers are recorded or issued, and where suppliers input their commonly used information. It is a fully integrated digital platform where noticing, sign-in, registration, and supplier information all work together to support public sector procurement.

The Procurement Act 2023 introduces some key changes for suppliers working with the public sector. One of the most significant is the requirement for new and existing suppliers to register on the Central Digital Platform and obtain a unique identifier. From 1 April 2026, legislation requires contracting authorities to obtain from suppliers their unique identifier and publish it in the below-threshold Contract Details Notice in respect of any supplier awarded a notifiable below-threshold contract.

The "Tell Us Once" system means that once registered, suppliers can review and reuse their data for future tenders, reducing duplication of effort. However, it is the supplier's responsibility to ensure that the data they are sharing is accurate. Find a Tender does not undertake any assurance before the supplier shares it, and it is up to the buying organisation to ensure that the information meets all of their due diligence checks. That last point is important: the CDP is a publication and registration mechanism, not a verification layer.

From KPI failure to debarment: the escalation path

The transparency provisions are not just about information. They create a direct escalation path from poor contract performance to exclusion from future procurement.

Poor performance and early contract termination being in the public domain is likely to be a commercial risk concern for those involved in delivering public goods, works, and services. Poor performance is a discretionary ground of exclusion from any public procurement exercise and results in the exclusion ground being reported to the Procurement Review Unit (PRU), which could lead to a debarment investigation and potential to be added to the Debarment List.

The Debarment List is a wholly new concept introduced under the Procurement Act 2023. It is a list kept by a Minister of excluded and excludable suppliers who have been included on the list following an investigation of their circumstances. "Excluded" suppliers are those to which a mandatory exclusion ground applies, and "excludable" suppliers are those to which a discretionary exclusion ground applies.

Notably, contracting authorities can exclude a supplier as an "excludable supplier" on broader discretionary grounds for poor performance under a relevant contract. This could apply where a supplier commits a sufficiently serious breach of contract, meaning it has led to termination, damages, or a settlement agreement; where a supplier has not performed to a satisfactory level and has failed to improve after being given the opportunity; or where a contracting authority has published a notice relating to breach or poor performance under section 71(5).

While the new framework retains the current concepts of mandatory and discretionary exclusion grounds, new grounds have been added, and a five-year time limit for both mandatory and discretionary exclusion grounds will be applied. A central Debarment List has also been introduced, and a Minister of the Crown may add an excluded or excludable supplier to this list for a specified period of time.

The chain from a published "requires improvement" KPI rating to a debarment investigation is not automatic, but the published data is the raw material that makes it possible. A supplier whose Contract Performance Notices show a pattern of missed KPIs, followed by a section 71(5) notice for failure to remedy, is giving any contracting authority conducting due diligence a clear basis for discretionary exclusion.

What this means for supplier due diligence

For organisations that assess the risk profile of their supply chain, the CDP's published notices now constitute a live data source. Contract Performance Notices, payment compliance records, and significant payment notices will all accumulate over time against specific suppliers, creating a publicly accessible performance history that did not exist under the previous regime.

This sits alongside the existing checks that form the bedrock of good supplier due diligence: Companies House filings, sanctions screening, and financial health indicators. At Senserity, we run automated checks across these sources and surface the findings as structured risk signals. Our compliance-focused features are built for exactly this kind of layered assessment, where a supplier's governance, financial stability, and now their publicly visible public contract performance all need to be read together.

The Procurement Act 2023 has materially raised the stakes for how suppliers manage their performance on public contracts, and for how buyers assess the suppliers they work with. The data infrastructure to support that scrutiny is now in place. The task now is to use it.