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Procurement Act 2023 thresholds updated 1 Jan 2026

Whitehall has confirmed fresh procurement thresholds under the Procurement Act 2023. The Procurement Act 2023 (Threshold Amounts) (Amendment) Regulations 2025 were made on 18 November 2025, laid before Parliament on 21 November 2025, and take effect from 1 January 2026, according to legislation.gov.uk. The instrument was made with the consent of Northern Ireland’s Department of Finance and signed by Chris Ward, Parliamentary Secretary, Cabinet Office. For suppliers and finance teams, this quietly shifts the value points that determine when more formal procedures bite.

Two numbers stand out for day‑to‑day works at the smaller end. Section 85(3) is corrected so the triggers for procedures on regulated below‑threshold works contracts move to £135,018 and £207,720, down from £138,760 and £213,477. The Cabinet Office notes this fixes an oversight in S.I. 2025/163, which updated Schedule 1 but left section 85(3) out of step; the figures now align with the corresponding entries in Schedule 1 as originally intended.

Beyond that tidy‑up, most of Schedule 1’s thresholds are refreshed. Government says the revisions keep the UK in step with the WTO’s Agreement on Government Procurement. GPA‑linked rows are updated and non‑GPA rows adjusted for consistency. The practical takeaway is simple: borderline procurements may now fall into either the fully regulated regime or a more formal below‑threshold process, depending on contract type and authority.

There is also a structural change to the threshold table. A distinct column now sets out thresholds for contracts regulated by the Welsh Ministers, with another column covering all other cases. The Regulations clarify that a contract is treated as regulated by the Welsh Ministers where it is awarded by a devolved Welsh authority or run under a devolved Welsh procurement arrangement. Welsh thresholds will be updated via a separate Welsh statutory instrument.

Transition rules matter for live pipelines. Procurements commenced before 1 January 2026 continue under the old numbers. In practice, that includes cases where a tender notice, a transparency notice or a below‑threshold tender notice has already been published, or where an authority has invited tenders or contacted a supplier to start awarding a below‑threshold contract. The cut‑off is clear; document your file in case of audit.

For SMEs and bid teams, assume a slight uptick in formal opportunities surfacing early in 2026 as authorities recalibrate values and republish notices. If your typical works packages cluster around £130k–£140k or £205k–£215k, revisit costings and risk allowances now. A project costed to sit safely below last year’s trigger could step over the line in January, bringing extra steps on advertising, timings and record‑keeping.

Finance directors should re‑baseline procurement assumptions in Q4 and Q1. Update approval matrices and budget notes that reference legacy thresholds, especially for minor capital works and estates refurbishments. Where frameworks are not impacted, spot procurements might be; align internal guidance on below‑threshold tender notices and transparency notices so teams use the correct figures from day one.

Devolved differences will require care for suppliers trading across England, Scotland, Wales and Northern Ireland. Until the Welsh statutory instrument lands, treat Wales‑regulated contracts as a separate track and watch authority notices closely. Mixed or joint procurements should flag which regime applies to avoid disputes over advertising and standstill expectations.

No full impact assessment accompanies the change, with the Cabinet Office expecting no significant effect on the private or voluntary sectors. That looks reasonable for most buyers, but edge cases will notice the difference. Small adjustments, yes-but with real compliance consequences if documents, notices and thresholds are misapplied on or after 1 January 2026.

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