The latest PA23 requirements: What contracting authorities need to know in 2026

When the Procurement Act 2023 (PA23) came into force in February 2025, it marked the most significant overhaul of public procurement in decades. But for many contracting authorities, the real turning point came at the start of 2026, when the final notice requirements were introduced and the regime became fully operational.

Now, midway through 2026, the focus has shifted from understanding notice types to managing a continuous, highly transparent reporting environment. The question is no longer what needs to be published – but how to do it consistently, accurately and at scale.

January 2026: the final notice types come into effect

From 1 January 2026, the final core notice types were brought into force, completing the legislative framework:

• Payments Compliance Notices (UK17) – requiring authorities to publish how quickly they paid suppliers
• Contract Performance Notices (UK9) – introducing mandatory reporting on supplier KPIs and delivery performance

These additions extended reporting requirements beyond procurement activity into contract delivery and supplier performance.

Contracting authorities now had a clearer view of how notice requirements would apply across the procurement lifecycle, with greater transparency extending beyond contract award.

April 2026: completing the transparency model

From 1 April 2026, the final components of the regime were introduced. These were formally described by Government as the “remaining transparency regulations”, confirming that this was the last phase of rollout rather than the start of a new one.

These changes extended transparency into financial flows and below-threshold activity, completing an end-to-end model that now covers procurement planning through to payment.

With these requirements in place, the notice framework moved beyond procurement activity alone. Payment data and below-threshold awards became part of formal reporting, increasing the level of detail available and the need for consistent data across procurement, contract management and finance functions.

Mid‑2026: the practical implications become clearer

With the framework in place, the practical implications of PA23 became clearer as the first reporting cycles began.

Payments Compliance Notices began to be published in April 2026, covering reporting periods extending into early 2026.

This was the first time that procurement, performance and payment data were brought together in a structured and consistent way across the contract lifecycle.

For contracting authorities, this brought the operational reality into focus. Reporting requirements were no longer theoretical – they required timely, accurate data and coordination across teams to meet publication deadlines and maintain consistency across notices.

This phase reflected the completion of the notice rollout rather than the introduction of further notice types. No additional statutory notice categories were expected, and the emphasis moved from rollout to ongoing delivery.

Upcoming reporting deadlines

The introduction of contract payment reporting brings with it specific, recurring publication deadlines. The first deadline for publishing detailed payment data under section 70 falls on 29 July 2026, covering the period from 1 April to 30 June 2026.

From this point, payment data must be published on a quarterly basis, with authorities required to submit information within 30 days of the end of each reporting period.

For contracting authorities, this establishes a fixed reporting rhythm. Meeting these deadlines depends on having accurate, up‑to‑date data and clear processes in place to ensure information is captured, validated and published at the right time.

From notice issuance to notice management

With the statutory notice framework complete, the challenge for contracting authorities has shifted from introducing new requirements to managing an ongoing flow of reporting obligations across the contract lifecycle.

This has introduced new pressures:

• Increased reporting volume and frequency, with multiple notices required at different stages and on recurring cycles
• Higher exposure to compliance risk, as missed deadlines or inconsistent data become publicly visible and subject to scrutiny

These pressures reflect a broader shift under PA23. Compliance is no longer something that happens at a single point in time. It becomes continuous, data-driven and increasingly visible outside the organisation.

Why this signals a need for more modern approaches

As procurement teams move through their first full reporting cycles, it is clear that the challenge is operational as much as regulatory.

Managing notice requirements across procurement, contract management and finance functions requires consistent data, clear ownership and reliable tracking of deadlines. Manual processes make this difficult to achieve in practice.

This means a more sector-aligned solution is becoming increasingly important. Rather than relying on manual tracking and fragmented systems, best-practice source-to-contract solutions should have the required notices embedded directly into the system, with clear approvals and processes as the user moves through each stage.

A new phase for public procurement

With the final notice types in force and the first reporting cycles completed, 2026 marks a transition point for contracting authorities.

The focus moves from understanding the requirements of the Act to operating effectively within them. In an environment where procurement activity, supplier performance and public spending are all visible in unprecedented detail, the ability to manage information accurately and efficiently becomes increasingly important.

Those organisations that evolve their operating models – particularly by adopting more structured, end-to-end approaches – are better placed to reduce risk, maintain consistency and demonstrate value in a more transparent procurement landscape.  

Find out more…

Don’t miss our dedicated PA23 hub page, regularly updated with all the latest news and developments.