Procurement Act 2023 Compliance Reviews
Know how much of your spend is on contract, where the exposure sits, and what to fix first.
A Procurement Act 2023 Compliance Review reconciles your spend to your contracts, identifies the non-compliant and uncontracted spend behind the numbers, quantifies the savings available, and gives your leadership team a roadmap to compliant, efficient spending and contracting.
Where the standard now sits
The Cabinet Office's Procurement Compliance Service investigates systemic non-compliance, can require your documents, issues recommendations you must have regard to, and publishes what it finds. The authorities in the strongest position can state, with evidence, how much of their spend is on contract and what is being done about the rest.
What you get
Five key outputs for your board and executive leadership team.
| Output | What it gives you |
|---|---|
| Compliance position | Analysis of contracted against non-contracted spend across the organisation, by supplier, category and budget holder, and the compliance score that summarises it. |
| Uncontracted spend | Spend with no recorded contract behind it, ranked by value and risk, with the procurement route that should have applied. |
| Non-compliant spend | Contracts awarded, extended or varied outside the Act or your own contract procedure rules; artificial splitting of requirements below thresholds; spend that should have been in scope of a procurement but was never identified as such. Bringing it under contract also creates the economies of scale that fund future savings. |
| Efficiency opportunities | Duplicate suppliers, cumulative spend bought in pieces, auto-renewals, price drift and the administration cost of small payments, quantified as a savings case. |
| Roadmap to compliance | Prioritised actions, owners and dates for compliant, efficient spending and contracting, written so it can go to your board or committee as it stands. |
Where the exposure usually sits
In the spend that never went through a process, and in the contracts that changed shape after award.
These are the patterns a review finds first, and the ones a reviewer from outside would find first too.
- Uncontracted spend.Suppliers being paid, sometimes for years, with no recorded contract behind the payments.
- Cumulative spend going through as smaller individual payments.A requirement that should sit under one procured contract, bought in pieces, each below the threshold that would have triggered a process.
- Disproportionate administration for small payments.Hundreds of low-value orders raised, approved, receipted and paid separately, costing more to process than they are worth.
- Extensions and variations that moved the contract.Past its approved value, past its original term, and at a certain point past what the modification rules allow without a new procurement or a change notice.
- Direct awards to incumbents.Rolled over without a transparency notice or a recorded justification, the pattern most likely to draw a referral from a supplier who expected a competition.
- Auto-renewals.Rolling on without the required notices, often unnoticed because the register shows an end date that passed.
- Contract registers that are incomplete or out of date.The first thing a reviewer opens, because it is the map to everything else.
- Payments that cannot be tied to a contract.Now visible to anyone, since payments over £30,000 under public contracts are published.
How it works
Five steps. Minimal input from your team.
The review runs on exports of data you already hold. We make the data request straightforward and do the reconciliation ourselves.
Data request
Spend ledger, purchase orders, contract register and supplier list, in whatever form your systems export them.
Reconciliation
Every spend line matched to a recorded contract or flagged, with cumulative spend by supplier and by requirement brought together.
Review
Flagged spend tested against the Act, the regime the contract was let under and your own financial regulations and contract procedure rules, with each exception classified.
Findings
Your compliance position, exposures ranked by value and risk, efficiency savings quantified, presented to your executive leadership team.
Roadmap
Prioritised actions, owners and dates for compliant, efficient spending and contracting, ready for your board or committee.
Why now
Oversight is live, and it publishes.
- Referrals from anyone.The Procurement Compliance Service can open an investigation on a referral from any source, including suppliers.
- Documents on notice.It can require documents and assistance under section 108, with a minimum of 30 days to respond, and issue recommendations under section 109 that you must have regard to.
- Published findings.Its reports, and your progress reports, may be published on GOV.UK.
- Visible spend.Payments over £30,000 under public contracts are published under section 70, so uncontracted spend can be seen by anyone who looks, before you have looked yourself.
Sources: GOV.UK guidance on procurement compliance and oversight, updated August 2026; Cabinet Office, Procurement Compliance Service scope and remit; Procurement Act 2023, sections 70, 108 and 109.
The pathway
From a compliance position to compliant, efficient contracting.
The review gives you a position: the share of spend under a recorded, compliant contract, and behind it every exception classified as uncontracted, non-compliant, exempt from the Act, below threshold, or a legacy contract still regulated under the previous rules. Each is valued and ranked, so the leadership conversation moves from whether there is a problem to which problems to fix first.
The roadmap turns that position into a programme: requirements consolidated and procured properly, duplicate suppliers rationalised, auto-renewals renegotiated or re-competed, price drift corrected, small-payment administration removed, and the controls that keep the position holding. The savings are quantified as a business case, which is what turns a compliance exercise into a budget conversation. Where you want support delivering it, our transformation, advisory and training services pick up where the review ends.
Procurement transformation and advisoryWho it is for
Any organisation the Act reaches.
Local authorities, housing associations, NHS bodies, universities and colleges, police and fire services, and any charity or company that is publicly funded or controlled. Not sure the Act applies to you? We check that first, against the statutory test, and record the reasoning.
Why Nexus
We know where reviewers look.
We implement the Act inside contracting authorities and we help suppliers win under it. The review is built by people who run procurement, present to boards and know what a supplier's adviser looks for in an award, a modification or a direct award.
Questions we are asked
About the review.
What data do you need, and in what format?
Exports of your spend ledger, purchase orders, contract register and supplier list, in whatever form your finance and procurement systems produce. We work with what you have. Gaps in the data are themselves a finding.
Does it cover contracts let under the old regulations?
Yes. The payment and reporting duties refer to public contracts, so legacy contracts still in force are caught, and they are often where the extensions, variations and auto-renewals sit. Every spend line is reconciled whichever regime the contract was let under.
We are in Wales, Scotland or Northern Ireland. Does the review account for that?
Yes. Welsh authorities publish through Sell2Wales and have their own exemptions on publishing contract documents; Northern Ireland authorities work under the Act with their own arrangements; Scotland has its own procurement legislation. The review tests you against the position that applies to you.
How are the findings presented?
A findings pack with the compliance position, the classified exceptions and the savings case, presented in person or online to your executive leadership team. The roadmap is written for your board or committee and can go in as it stands.
What happens after the review?
That is your call. Some authorities run the roadmap themselves. Others ask us to lead the programme, take an interim role, or train budget holders and officers on the controls. The review stands on its own either way.
How is the review priced?
Fixed fee, set by the scale of the spend and the number of entities, confirmed after a short scoping call.