Regulated procurement | UK Regulatory Outlook June 2025

Procurement Act 2023: Exclusion and Debarment – are you at risk? 

Is your business bidding for a public contract in the UK? Confused by the new exclusion grounds and not sure whether you have anything to declare? Our new tool demystifies the exclusion grounds at the click of a button. You will be able to see exactly what conduct is (and is not) caught by the exclusion regime so that you can understand your business's position. 

Skip the confusion and navigate the changes that now apply under The Procurement Act 2023 with confidence. Our new exclusions tool is a key resource for procurement and in-house legal teams. Download the tool.  

Tackling modern slavery in NHS procurement: government response 

The government has published its response to the consultation on the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2024. 

As a reminder, these draft regulations will introduce a legal duty for public bodies to consider modern slavery and human trafficking risks in the procurement of goods and services for the NHS in England. The regulations build upon existing government policies, such as PPN 009: tackling modern slavery in government supply chains, and require public bodies to: 

• Assess the risk of modern slavery.
• Take reasonable steps during pre-procurement and procurement stages.
• Include mitigation measures in contracts to manage identified modern slavery risks. 

The new regulations and guidance will only apply to new procurements and will not retrospectively apply to existing contracts. 

The feedback received from the consultation highlighted the need for: 

• Clearer guidance and actionable steps.
• Stronger enforcement mechanisms.
• Enhanced training and resources for procurement professionals and suppliers.
• Alignment with existing policies and international standards, as well as alignment between this guidance and forthcoming updates to section 54 of the Modern Slavery Act. 

Government's next steps 

1. Amendments to regulations and guidance: Based on the consultation feedback, the government will make necessary amendments to the draft regulations and guidance to improve clarity, practicality, and alignment with existing policies.
2. Supplementary support tools: Development of additional support tools and training programs for procurement professionals and suppliers to enhance their capacity to manage modern slavery risks.
3. Engagement with stakeholders: Continued engagement with stakeholders to refine the guidance and ensure effective implementation.
4. Cross-government collaboration: Sharing feedback with the Home Office, Cabinet Office, and the Independent Anti-Slavery Commissioner to support wider reform and harmonised efforts to tackle modern slavery in government supply chains.
5. Implementation timeline: Informing procurement professionals and suppliers about the implementation timelines to allow adequate preparation.
6. Monitoring and review: Conducting checks on compliance and reviewing the implementation of the regulations to ensure they effectively address modern slavery risks. 

It is interesting to see the government's efforts to tackle modern slavery risks in NHS procurement in a way that supports both procurement professionals and suppliers in understanding what they need to do to manage these risks. 

Industrial Strategy sets out further procurement reform  

The government's Industrial Strategy, published on 23 June 2025, states that it will "use government’s procurement power to strengthen domestic supply chains and support good-quality local jobs, while shaping markets for innovation in the longer term."

The strategy looks to measures introduced under the new Procurement Act and how these fit with the aims of the Industrial Strategy. A new National Procurement Policy Statement instructs public bodies to consider how they can use procurement to support economic growth and the Industrial Strategy. Additionally, there is now a legal duty on contracting authorities to consider how they can remove obstacles to small businesses bidding for public contracts.  

To further enhance transparency, a new online platform has been launched to publish upcoming procurement activity and opportunities for pre-procurement engagement for suppliers interested in bidding. Strengthened requirements have also been implemented to ensure contractors are paid within 30 days throughout the public sector supply chain.

Looking ahead, the government will aim to ensure that procurement strategically supports Industrial Strategy priorities, including creating high-quality jobs and skills in local communities, and supporting sectors critical to national security. To achieve this, a public consultation will soon be launched to explore how to open up contracts to give more weight to firms that can demonstrate their ability to boost British jobs. This will include setting at least one award criterion in major procurements related to the quality of the supplier’s contribution to jobs, opportunities, or skills. Furthermore, at least one social value key performance indicator (KPI) will be set in major contracts, with regular reporting on delivery to ensure that procurement activities align with the broader goals of the Industrial Strategy. 

Strategic Defence Review offers hope of shake up for UK procurement to deliver ambitious security goals 

The Strategic Defence Review (SDR), published on 2 June, sets out the government's ambition for how the UK will respond to critical threats and identifies changes that would speed up defence procurement. 

As the SDR acknowledges, achieving those ambitions must include a genuine and swift improvement of how the Ministry of Defence (MOD) procures equipment and services. MOD's current processes and contracts too often introduce delay, drag and unnecessary cost. The review identifies changes that would speed up procurement, properly harness the strength of the defence industry and deliver better taxpayer value. Read our Insight for more.