By Thursday 29 October 2026 every public body buying under the Procurement Act 2023 must publish a payments compliance notice showing how quickly it paid suppliers from April to September, signed off by its finance director. Anyone can read it. These are the dates, the two on-time figures and what to check first.
Do you pay your suppliers late? By Thursday 29 October 2026, anyone will be able to look it up. Every public body that buys under the Procurement Act 2023 has to publish a payments compliance notice showing how long it took to pay its invoices between 1 April and 30 September, and how many it paid late. The notice is public and it is signed off by your finance director. A supplier can read it before deciding what to charge you (Procurement Act 2023, section 69; Procurement Regulations 2024, regulation 38).
Two things catch finance teams out. The deadline is the 29th, not the 30th. And the figure most authorities will want to quote, the share of invoices paid within 30 days, leaves out every invoice you have not paid yet, including the ones you are disputing. The notice carries a second figure that counts those as well, and it is never the better of the two.
Four questions to answer this week
- Between 1 April and 30 September 2026, did you pay an invoice, or did one fall due, under a contract awarded under the Act above the threshold? If so, you must publish.
- Can your finance system show the day each invoice reached the authority, and not only the day accounts payable registered it?
- How many invoices are sitting unpaid or in dispute, and what do they do to your on-time figure?
- Has the finance director who will sign it off seen the figures?
The dates you should know
Section 69 requires a payments compliance notice whenever, during a six-month reporting period, you made a payment under a public contract or a sum under one became payable. The periods end on 30 September and 31 March.
| Notice | Reporting period | Publish by |
|---|---|---|
| First notice | To 31 March 2026 | 29 April 2026 |
| Second notice | 1 April to 30 September 2026 | Thursday 29 October 2026 |
| First notice for procurements regulated by the Welsh Ministers, where the duty began on 1 April 2026 | 1 April to 30 September 2026 | Thursday 29 October 2026 |
| Next notice | 1 October 2026 to 31 March 2027 | Thursday 29 April 2027 |
| Separate duty: payments over £30,000 under section 70, July to September 2026 | Quarterly | “By end Oct 2026” |
Source: Procurement Act 2023, section 69(1) and (3); Cabinet Office, New legislative requirements under the Procurement Act 2023, updated 23 June 2026, which gives 31 March to 29 April 2026 as the window for the first notice, 1 April 2026 as the start date for procurements regulated by the Welsh Ministers and “by end Oct 2026” for section 70. The October 2026 and April 2027 dates are our arithmetic on the same basis, explained below.
Transferred Northern Ireland authorities, private utilities, schools and concession contracts are outside section 69.
Why 29 October and not 30 October?
Section 69(1) says the notice must be published “before the end of the period of 30 days beginning with the last day of a reporting period”. The last day, 30 September, is day one. Day 30 is Thursday 29 October.
The Cabinet Office counted the same way for the first round: its guide says the first notice had to be published “between 31 March 2026 and 29 April 2026”. Some published commentary gives 30 October. If your timetable says the 30th, bring it forward a day.
What is different from the figure you used to publish?
Under the Public Contracts Regulations 2015 you published payment performance once a year. The new notice is intended to “replace and strengthen” that duty (Cabinet Office, Guidance: Payments Compliance Notices, paragraph 7).
| Previous: Public Contracts Regulations 2015, regulation 113(7) | New: Procurement Act 2023, section 69 | |
|---|---|---|
| How often | Once a year | Every six months |
| Average days to pay | Not required | Required |
| Payment bands | Not required | % paid in days 1 to 30, in days 31 to 60, and on day 61 or later |
| Sign-off | Not required | Signed off by the director or similar officer responsible for finance, with name and job title |
| Interest owed for late payment | Published | Not required |
Source: Cabinet Office, Guidance: Payments Compliance Notices, updated 20 July 2026, paragraph 8; Procurement Regulations 2024, regulation 38(2).
Why does the notice show two different on-time figures?
Because they answer two different questions.
- Figure one: of the invoices you paid, how many did you pay within 30 days?
- Figure two: of all the invoices you should have paid, how many did you pay on time and without a dispute?
Figure one ignores anything still sitting unpaid. Figure two does not, so an authority with a pile of unpaid or disputed invoices looks fine on the first and poor on the second.
The Cabinet Office guidance shows it with ten invoices. This is its illustration, not data. An authority receives ten invoices. It pays four in 7 days, four in 27 days and one in 35 days. The tenth is disputed and unpaid. Figure one comes out at 89%. Figure two comes out at 80%.
| What the notice reports | Counted against | Result |
|---|---|---|
| Average days to pay | The 9 invoices paid | 19 days (171 days divided by 9) |
| Figure one: paid in days 1 to 30 | The 9 invoices paid | 89% (8 of 9) |
| Paid in days 31 to 60 | The 9 invoices paid | 11% (1 of 9) |
| Figure two: paid on time as section 68(2) requires | All 10 invoices | 80% (8 of 10) |
| Not paid in accordance with section 68(2) | All 10 invoices | 20% (2 of 10) |
Source: Cabinet Office, Guidance: Payments Compliance Notices, worked example; 171 days is four invoices at 7 days, four at 27 days and one at 35 days (28 plus 108 plus 35).
A disputed or invalid invoice never counts as paid on time in figure two, even if you paid it inside 30 days (paragraph 28). Expect a supplier comparing authorities to look at figure two.
Every percentage is a share of the number of invoices, not of their value (paragraph 26). A timesheet can be an invoice (paragraph 50). So a run of late agency timesheets for a few hundred pounds each will move your percentage further than one large invoice paid on time.
When does the clock start?
It starts earlier than most finance systems record. The invoice day is the day the authority receives the invoice. If the contract names an address or an electronic invoicing system, receipt means delivery there. If it does not, the guidance says the invoice is received on the day it arrives “within the contracting authority, even if this is not received by the person responsible for processing it” (paragraph 48).
Here is a made-up example. A supplier emails a £50,000 invoice to a service manager on 1 September. The manager forwards it to accounts payable on 12 September and it is paid on 8 October. Counted from the day accounts payable registered it, that is 26 days. Counted as the regulations require, from the day after it reached the authority, it is 37 days, and it belongs in the 31 to 60 band.
In the finance systems our consultants see most often, the date held against an invoice is the day accounts payable registered it. If yours works the same way, the percentages in your draft notice are better than the ones the regulations ask for, and your finance director is the one signing them off.
What does a poor figure cost you?
It costs money first. Where the contract sets no rate of its own, a supplier paid late can claim statutory interest at 8% over the Bank of England base rate, plus a fixed sum of £100 on a debt of £10,000 or more (GOV.UK, Late commercial payments). Bank Rate has been held at 3.75% at each decision since June 2026 (Bank of England, 17 September 2026), so the rate is 11.75%. On the £50,000 invoice above, paid 7 days after the 30 days ran out, that is £112.67 of interest (£50,000 at 11.75% is £5,875 a year; £5,875 times 7, divided by 365) plus £100: £212.67, paid from the service’s budget.
It also brings complaints. Payment remained the primary issue raised with the Cabinet Office’s Public Procurement Review Service in 2025/26. The service closed 28 late payment cases and upheld 25 of them, and unblocked £380,970.82 for suppliers (Procurement Compliance and Oversight, Progress Report 2025/2026, pages 4 and 7).
The Act sets no penalty for a missing notice (Trowers and Hamlins, 25 September 2026). The oversight route is the Procurement Compliance Service, which investigates breaches “regularly being made” by one authority and may publish its reports (Scope and Remit, file version 1.1).
What should you do before 29 October?
| If | Do this |
|---|---|
| Your timetable says 30 October | Publish by Thursday 29 October |
| Your system records the day accounts payable registered each invoice | Sample invoices against the emails and post they arrived in, and correct the invoice day before you calculate |
| You have not decided which payments to report | Choose between public contracts awarded under the Act only, or every invoice. The guidance permits adding below-threshold contracts and contracts awarded outside the Act (paragraphs 55 and 56). With a small population, a handful of invoices moves the percentage |
| Disputes are handled in service inboxes | List every invoice disputed in the period. Each counts as not compliant, and section 68(4) requires you to tell the supplier without undue delay |
| Your contracts do not say where invoices go | Name an invoice address or electronic invoicing system in every new contract, so the clock starts where finance can see it (paragraph 49) |
| The person signing it off has not seen the figures | Show them both on-time figures and the average, with a draft of any explanation. Regulation 38(6) lets you add other relevant information |
Source: our reading of section 69, regulation 38 and the guidance cited above.
Matching what you pay against what you hold on contract is the first step in our Procurement Act 2023 Compliance Reviews, and it produces the list of invoices this notice is calculated from.
What should suppliers take from this?
You can now look up how quickly a buyer pays before you price its tender. The notices are on Find a Tender, each signed off by a named finance director and laid out the same way. Section 68 implies a 30-day payment term into public contracts, and a contract term that tries to override it has no effect. Section 73 implies the same term into your sub-contracts, so the 30 days binds you as well.
Send each invoice exactly where the contract says, because that is where the clock starts. If a valid, undisputed invoice is still unpaid after 30 days, the Public Procurement Review Service takes late payment cases and upheld 25 of 28 last year. A buyer’s payment record belongs in the decision about where to bid, which is the work our consultants do in Strategic Public Sector Growth.
If you are publishing this month, decide this week which invoices you are reporting on and which date counts as received. Then show your finance director both on-time figures before the 29th.
Questions contracting authorities are asking
When is the payments compliance notice for April to September 2026 due?
By Thursday 29 October 2026. Section 69(1) of the Procurement Act 2023 requires publication before the end of the period of 30 days beginning with the last day of the reporting period, so 30 September is day one and 29 October is day 30. The Cabinet Office used the same count for the first notice, which had to be published between 31 March and 29 April 2026.
Which contracts and payments does the notice cover?
Payments made, and sums that became payable, under public contracts during the reporting period. Concession contracts and contracts awarded by transferred Northern Ireland authorities, private utilities and schools are excluded (section 69(6)). The Cabinet Office guidance says the Act does not require a notice for below-threshold contracts or for contracts awarded outside the Procurement Act 2023, but permits an authority to include them (paragraphs 55 and 56).
Where can I see how quickly a public body pays its suppliers?
On Find a Tender, the central digital platform, where each contracting authority publishes its payments compliance notice (notice type UK17) every six months. The notice gives the average number of days taken to pay, the percentage of payments made in days 1 to 30, in days 31 to 60 and on day 61 or later, and the percentage of invoices paid on time as section 68(2) requires, and it is signed off by the director or similar officer responsible for finance (Procurement Regulations 2024, regulation 38(2)).
Does a disputed invoice count against us?
Yes, in the section 68(2) figure. The Cabinet Office guidance treats only a valid, undisputed invoice paid within 30 days as paid in accordance with section 68(2). A disputed or invalid invoice is counted as not compliant whether or not it was paid within 30 days (paragraph 28). Section 68(4) also requires the authority to notify the supplier without undue delay when it disputes an invoice or considers it invalid.
What happens if the notice is late or is not published?
The Act sets no direct penalty (Trowers and Hamlins, Payments Compliance Notices: Update, 25 September 2026). The Procurement Compliance Service can investigate institutional breaches, meaning breaches regularly being made by one contracting authority, can make recommendations under section 109 and may publish its reports on GOV.UK (Scope and Remit of the Procurement Compliance Service, file version 1.1).
Sources: Procurement Act 2023, sections 68, 69, 70 and 73, as shown on legislation.gov.uk on 8 October 2026; Procurement Regulations 2024 (SI 2024/692), regulation 38, as amended by SI 2025/163; Cabinet Office, Guidance: Payments Compliance Notices, updated 20 July 2026; Cabinet Office, New legislative requirements under the Procurement Act 2023, updated 23 June 2026; Trowers and Hamlins, Payments Compliance Notices: Update, 25 September 2026; Procurement Compliance and Oversight (Cabinet Office), Public Procurement and Oversight Progress Report 2025/2026, covering 6 April 2025 to 5 April 2026; Cabinet Office, Scope and Remit of the Procurement Compliance Service, GOV.UK file version 1.1 dated 15 May 2026; GOV.UK, Late commercial payments: charging interest and debt recovery, read 8 October 2026; Bank of England, Bank Rate decisions of 18 June, 30 July and 17 September 2026.