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The first year of the Procurement Act 2023 has shown that many public sector organisations are still operating on assumptions that no longer hold.
Recent Public Procurement Review Service (PPRS) data from the Cabinet Office reveals four emerging risk patterns that should concern every public sector procurement professional. While absolute complaint numbers remain relatively low, the underlying trends point to fundamental shifts in supplier behaviour, regulatory expectations, and the consequences of inadequate governance.
Whether procurements fall above or below statutory thresholds, PPRS cases provide essential insights into sector-wide maturity levels and compliance discipline. The themes emerging from this data demand immediate attention.
Between 2018 and 2022, complaint volumes declined steadily, partly reflecting pandemic-era disruptions and emergency procurement protocols. Since 2023, numbers have edged upward as organisations adapted to PA23 requirements. But volume metrics tell only part of the story.
The real alarm bell? The PPRS upheld rate has jumped from 41% in 2023 to 56% in 2025.
What’s driving this shift:
The proportion of upheld complaints has more than tripled since 2020, even as total volumes remain below pre-2019 levels. This isn’t a statistical anomaly it’s a fundamental recalibration of what constitutes acceptable practice.
Implications for public sector organisations:
An absence of complaints is no longer an indicator of procurement excellence. Often, it simply means suppliers lack visibility into your processes or don’t believe challenge is worthwhile.
When complaints do arrive, the odds are increasingly against you. An upheld rate above 50% suggests systemic deficiencies: weak evaluation frameworks, insufficient audit trails, or inadequate debriefing practices.
Immediate actions required:
The bottom line: Relying on old templates, undocumented decisions, or informal ways of working is now a real risk. Organisations that strengthen their governance early avoid becoming part of next year’s upheld statistics.
Transparency-related complaints still represent a smaller share of total PPRS cases than procedural or payment disputes. However, they’re growing faster and increasingly serve as an early warning for broader compliance weaknesses.
This is no accident. PA23 was designed to surface inconsistencies, not suppress complaints. Enhanced notice requirements, expanded data publication, and improved supplier access to procurement information mean that gaps in documentation, contradictions between published materials, and unclear rationales are easier to detect and impossible to obscure.
Many recent PPRS transparency cases don’t reflect deliberate non-compliance. Instead, they expose insufficient organisational readiness: unclear role definitions, misaligned messaging between teams, or documentation created retrospectively rather than in real time.
Implications for public sector organisations:
Transparency is now a frontline compliance risk, not just an admin task.
Immediate actions required:
The bottom line: Transparency has become the main indicator of procurement maturity. Getting it right builds market confidence. Getting it wrong invites challenge and damages reputation.
Despite sustained policy focus and ministerial attention, late payment continues to feature prominently in PPRS complaint data across councils, NHS organisations, and other public bodies.
Unlike evaluation disputes, payment complaints are:
This makes late payment complaints more likely to succeed and more damaging to organisational credibility.
While PA23’s formal payment reporting requirements apply only to above-threshold contracts, many public sector organisations are adopting broader supply chain reporting for consistency. This means payment performance will become more transparent — and more scrutinised than ever before.
Implications for public sector organisations:
Late payment is no longer confined to finance departments. It’s now a:
Suppliers interpret payment performance as a proxy for organisational culture. Poor payment practices undermine trust and discourage future competition, even when procurement processes themselves are otherwise sound.
Immediate actions required:
The bottom line: Late payment is where procurement policy meets operational delivery. When the two don’t align, supplier confidence erodes and governance credibility suffers.
A small subset of contracting authorities appear repeatedly in PPRS data across multiple years. High procurement activity alone doesn’t explain this pattern. Instead, recurrence typically indicates:
Under PA23, such patterns carry greater weight. Regulators, boards, and suppliers increasingly assess organisations based on behaviour over time, not isolated incidents.
Implications for public sector organisations:
If similar issues recur across multiple procurements, even smaller, lower-value ones, this isn’t a procurement problem. It’s a governance signal.
Boards and audit committees will increasingly be evaluated on whether they:
Immediate actions required:
The bottom line: Repeat complaints are rarely coincidence. They indicate deeper organisational vulnerabilities that PA23’s transparency requirements will increasingly expose.
The latest PPRS data tells a consistent story: expectations are rising, scrutiny is intensifying, and suppliers are better informed and more willing to challenge than ever before.
Across upheld complaint rates, transparency failures, payment performance issues, and repeat patterns, one message emerges clearly:
Procurement compliance is no longer about avoiding challenge. It’s about demonstrating maturity, fairness, and accountability.
Public sector organisations that act early to strengthen governance, build capability, improve documentation, and work better with suppliers will:
Those who delay will discover that the market and regulators are already forming judgments.
Ready to identify potential gaps in your organisation’s PA23 compliance approach?
Download our Procurement Compliance Checklist, by entering your details on the form above, to evaluate your processes, strengthen your governance, and build resilience under the Procurement Act 2023.
