The Government Commercial Function's Framework Practice Guide of 10 September 2026 tells every public buyer how to choose a framework and when to call off without competition. On a £1 million call-off the levy is £10,000 at 1% and £60,000 at 6%, and the buyer pays it in the price. Five tests to run on every framework you pay for.
How many frameworks does your firm pay to sit on, and how many of them have produced a call-off in the last twelve months? Since 10 September 2026 the buyers on the other side have had an official checklist for deciding whether to use those frameworks at all. The Government Commercial Function’s Framework Practice Guide, with a foreword by the Government Chief Commercial Officer, sets a single standard for the whole framework lifecycle, from set-up to call-off, for central government, the NHS, local authorities and the rest of the public sector. One of its figures goes straight to your margin: the levy on a call-off averages less than 1% with some national providers and runs up to 5% or 6% with others. On a £1 million call-off that is £10,000 against £60,000 (1% and 6% of £1,000,000), and the guide says suppliers embed the levy in their prices, so the buyer pays it either way (Government Commercial Function, The Framework Practice Guide, 10 September 2026).
Five of its tests fall directly on suppliers. Before you read the detail, put your own frameworks against them.
Five questions to ask about every framework you pay for
- What levy do you pay on each call-off, and is it closer to the under 1% the guide reports on some national agreements or to the 5% or 6% it reports elsewhere?
- How many of the suppliers on the framework actually win work through it? The guide’s example of a limited market is a framework of 20 suppliers where one or two consistently win 90% of the call-offs.
- Who runs it: a central purchasing authority, or a private operator using a small contracting authority as host?
- Have you paid anything to join it or to use its software, regardless of work won?
- Do your renewals arrive as direct call-offs, and does the framework document actually contain the objective mechanism that permits them?
Those are the questions the guide puts to buyers. What follows is what it says about each, where the trap sits for incumbents, and which frameworks are worth paying for from here.
What is the Framework Practice Guide, and does it bind anyone?
It is guidance. It was developed across government commercial authorities, central government, local government and the NHS, and published on GOV.UK on 10 September 2026 (Government Commercial Function, The Framework Practice Guide). It is not a Procurement Policy Note and it does not change the Act. Anthony Collins, writing in Local Government Lawyer on 2 October 2026, makes the point that matters for suppliers: there is no legal prohibition on creating new or overlapping frameworks, and the Act treats a call-off with competition and a call-off without one as equal options, so the guide’s preferences are policy, not law. Buyers can depart from it. In our experience, most will not, because the guide gives a procurement team a defensible reason to say no to a framework a budget holder has asked for, and defensible reasons travel fast.
Which five tests does it put on your frameworks?
| Test | What the guide says | What it means for a supplier |
|---|---|---|
| The levy | Most providers charge a levy as a percentage of contract value; some national providers average less than 1%, others range up to 5% or 6%; rates cannot change during the framework; suppliers generally embed the levy in their prices | Buyers are told to compare levies, so a 6% framework now competes on price with a 1% one before any bid is scored; the worked figures are in the next table |
| Concentration | The guide’s example: a framework with 20 suppliers where one or two consistently win 90% of the call-offs operates “a structurally limited market” | Buyers are told to check who actually wins before using a framework; if you never win through it, it may be one buyers stop using, and if you always win, expect the pattern to be noticed |
| Private operators and host authorities | Frameworks run by private providers and hosted by a small contracting authority have often not been subject to oversight; a framework value far above the host’s annual turnover exposes the host to disproportionate liabilities; a buyer gets no institutional assurance from procedural errors on a non-CPA framework and should verify it was set up in strict compliance with the Act | Expect buyers to ask for the host’s name, its turnover and the framework’s compliance file before they call off |
| Hidden fees | Some frameworks charge suppliers to access the framework or its software regardless of work won; the guide calls this an artificial barrier that severely penalises SMEs | Under section 45(7) of the Act a framework may charge fees only to suppliers awarded call-offs, as a fixed percentage of the estimated contract value, stated in the tender notice; an access fee on a framework let under the Act is a compliance question, not a commercial one |
| Award without competition | Permitted only under the specific objective mechanisms set out in the framework documents; framework design must move from “noting” direct award as an option to “strict parameters”; competition is the default | Your renewals depend on what the framework document says, not on the relationship |
Source: Government Commercial Function, The Framework Practice Guide, 10 September 2026; Procurement Act 2023, section 45(7) as described in Cabinet Office, Procurement Act 2023 guidance: Frameworks, November 2024.
What does the levy difference cost, and who pays it?
The guide gives the range and leaves the arithmetic to you. Here it is, at the two ends of the range the guide reports, for three call-off sizes.
| Call-off value | Levy at 1% | Levy at 6% | Difference on the same contract |
|---|---|---|---|
| £250,000 | £2,500 | £15,000 | £12,500 |
| £1,000,000 | £10,000 | £60,000 | £50,000 |
| £5,000,000 | £50,000 | £300,000 | £250,000 |
Source: arithmetic on the levy range reported in The Framework Practice Guide, 10 September 2026 (levy multiplied by call-off value; the rates are illustrative points at each end of the guide’s range, not the rates of any named framework).
Who pays it depends on where you sit, and the answer is the same from both seats. The guide states that suppliers generally treat the levy as a cost of doing business and many embed it in the prices charged to the buyer, so a 6% framework costs the buyer up to £50,000 more on a £1 million call-off before a single bid is scored. Where the supplier cannot pass it on, because the price is fixed or the competition is tight, the £50,000 comes out of margin. The guide adds one more distinction that buyers are now told to weigh: levy income from public sector frameworks stays within the public sector, while a private operator’s levy leaves it.
Where is the trap for incumbents?
In the fifth row. Under section 45(3) and (4) of the Act a buyer can award a call-off without competition only where the framework sets out an objective mechanism for selecting the supplier and the core terms of the contract, including deliverables, charges and termination (Cabinet Office, Procurement Act 2023 guidance: Frameworks, November 2024). Many frameworks let under the previous regulations, and some let under the Act, mention direct award in a sentence and leave the mechanism to the buyer. The guide now tells buyers that this is misuse waiting to happen and that competition should be the default. If your public sector revenue renews through direct call-offs, read the framework document this week and find the mechanism. If it is a rota, a ranking or a published price-and-capability test, you know the rule you must win under. If it is a sentence, every renewal from here is a mini-competition, and the time to write the bid is before the call comes, not after.
The second trap is quieter. Frameworks awarded under the Public Contracts Regulations 2015 remain live and every call-off under them follows the old rules, so the Act’s protections on fees and direct award do not reach them (The Framework Practice Guide, Part Two, Section 2). Dynamic purchasing systems end on 23 February 2029, but there is no single expiry date for legacy frameworks. A legacy framework with an access fee and a loose direct award clause can run for years yet. The guide simply tells buyers to look harder at it.
Which frameworks are worth paying for from here?
The guide changes what a buyer accepts without asking. The table compares the two positions, using the guide’s own descriptions.
| Previous position: frameworks under the Public Contracts Regulations 2015 | New position: the Act and the guide | |
|---|---|---|
| Duplication | Similar frameworks created side by side | Buyers are told to consult the Summarised Search in Find a Tender, the register of frameworks and dynamic markets, before creating or choosing one |
| Levies | Vary from under 1% to 5% or 6% depending on the provider | Must be stated in the tender notice, fixed for the life of the framework, and compared by the buyer before choosing |
| Supplier access fees | Charged by some frameworks regardless of work won | Fees only on awarded call-offs, as a fixed percentage of estimated value (section 45(7)) |
| Direct award | Noted as an option in the framework documents | Only through the objective mechanism in the framework documents; competition the default |
| Term | Four years under regulation 33 of the 2015 Regulations, with legacy frameworks still running | Four years (eight for defence and utilities); open frameworks up to eight years, reopened at least once in the first three years and again within five (sections 47 and 49) |
| Private operator, small host | Used as a convenient and proactive route to market | Buyer must verify compliance and weigh the host’s exposure before calling off |
Source: The Framework Practice Guide, 10 September 2026; Cabinet Office, Procurement Act 2023 guidance: Frameworks, November 2024; Public Contracts Regulations 2015, regulation 33.
Three practical consequences follow. First, a place on a central purchasing authority framework, from the Government Commercial Agency, NHS bodies or the established consortia, now carries an assurance premium with buyers that a privately operated framework does not. Second, open frameworks are where new entrants get in: the Act requires them to reopen, so a framework you missed is a framework you can join at the next window, and the one you are on is a framework your competitors can join. Third, the autumn calendar is already set.
| Agreement | Reference | Tenders open | Expected live |
|---|---|---|---|
| Consultancy and Professional Services | RM6399 | 15 September 2026, tenders due 3pm 9 November 2026 | Decision expected 1 June 2027 |
| Global Travel, Accommodation and Venue Management Services | RM6408 | 14 October 2026 | 3 May 2027 |
| Managed Debt Collection Services | RM6402 | 15 October 2026 | To be confirmed |
Source: Government Commercial Agency, upcoming agreements page, accessed 2 October 2026; RM6399 tender notice 2026/S 000-087183, 15 September 2026.
Decide which frameworks you will still be paying for in 2027 by running the five questions above against each one, and put the levy, the concentration figure and the host’s name on one page for your board. Our consultants run framework onboarding on a fixed fee for the frameworks that pass, and build the call-off pipeline behind them as part of a Strategic Public Sector Growth plan.
What should contracting authorities take from the guide?
Four things, each of which leaves a record. Consult the Summarised Search before creating a framework, and record that you did. Before calling off from any framework that is not run by a central purchasing authority, confirm which regulations govern it and that it was set up in compliance with them. Award without competition only where the framework document gives you the objective mechanism, and keep the record that shows which mechanism you used. And read your own levy and fee arrangements against section 45(7). None of this is new law. All of it is now the written standard your decisions will be measured against, and a Procurement Act 2023 Compliance Review checks call-offs against exactly these points.
Frameworks used to be judged by one thing: whether you were on them. From 10 September 2026 buyers have five written tests for judging the framework itself, and a supplier’s question changes with them, from which frameworks can we get on to which frameworks will buyers still be using in 2027.
Questions suppliers are asking
What is the Framework Practice Guide?
Guidance published on GOV.UK by the Government Commercial Function on 10 September 2026, with a foreword by the Government Chief Commercial Officer. It sets a single standard for how public bodies set up, choose, use and manage frameworks under the Procurement Act 2023, and it was developed with central government, local government and NHS procurement bodies (Government Commercial Function, The Framework Practice Guide, 10 September 2026).
Is the guide mandatory?
No. It is guidance, not a Procurement Policy Note and not law. Anthony Collins notes in Local Government Lawyer (2 October 2026) that the Act does not prohibit new or overlapping frameworks and treats call-offs with and without competition as equal options, so the guide's preferences are government policy that buyers can depart from with reasons.
Can a framework charge suppliers a fee to join?
Not under the Act. Section 45(7) allows fees only on suppliers awarded a call-off contract, as a fixed percentage of the contract's estimated value, and the fee must be set out in the tender notice (Cabinet Office, Procurement Act 2023 guidance: Frameworks, November 2024). Frameworks awarded under the Public Contracts Regulations 2015 continue under the old rules, which is where the access fees the guide criticises still sit.
Can a buyer still award a call-off without competition?
Yes, where the framework sets out an objective mechanism for selecting the supplier and the core terms of the contract (section 45(3) and (4)). The guide tells buyers to default to competition and to use direct award only through that mechanism, and tells framework providers to design strict parameters for it (The Framework Practice Guide, 10 September 2026).
How long can a framework last, and when do dynamic purchasing systems end?
Four years under section 47, or eight for defence and utilities. An open framework under section 49 can run for up to eight years and must reopen to new suppliers at least once in the first three years and again within five. Dynamic purchasing systems end on 23 February 2029; legacy frameworks have no single expiry date (The Framework Practice Guide, 10 September 2026; Cabinet Office guidance: Frameworks, November 2024).
Sources: Government Commercial Function, The Framework Practice Guide, GOV.UK, 10 September 2026; Local Government Lawyer, The role of the Framework Practice Guide, Sophie McFie-Hyland, Anthony Collins, 2 October 2026; Cabinet Office, Procurement Act 2023 guidance: Frameworks, November 2024; Procurement Act 2023, sections 45, 46, 47 and 49 and Schedule 3; Public Contracts Regulations 2015, regulation 33; Government Commercial Agency, upcoming agreements page, accessed 2 October 2026; Find a Tender, Government Commercial Agency, Consultancy and Professional Services (RM6399), tender notice 2026/S 000-087183, 15 September 2026.