Welsh Ministers have approved regulations to update Schedule 9 of the Procurement Act 2023, adding Iraq and Kazakhstan to the list of treaty‑state suppliers for procurements regulated in Wales. The instrument was made on 17 December and takes effect on 31 December 2025, following Senedd approval. For suppliers, this is a compliance tweak with real market reach.

What changes on the ground is straightforward: contracting authorities in Wales must not discriminate against treaty‑state suppliers in covered procurements, and those suppliers gain the same rights and remedies as UK suppliers. Welsh Government guidance is clear that this widens the competitive pool and is designed to improve value for money.

Coverage hinges on when the procurement chapters of the two treaties apply. The UK–Iraq Partnership and Cooperation Agreement (CP 1356) takes effect in line with Article 115, while the UK–Kazakhstan Strategic Partnership and Cooperation Agreement (CP 1365) applies its government procurement chapter (Chapter 8 of Title III) under Article 136. Wales is positioning the domestic law so that access switches on automatically once those treaty provisions are live.

There is a sensible cut‑off for live competitions. Procurements already under way before the relevant treaty chapter applies will continue on their current footing where a tender notice, transparency notice or below‑threshold notice has been published, or where a below‑threshold award has begun with direct supplier contact. That avoids rerunning processes mid‑stream and reduces legal risk for buyers and bidders alike.

For contracting authorities, two steps matter this month. First, refresh template documentation and evaluation briefs to reflect treaty‑state access where the market access schedules cover your entity and requirement. Second, train commercial teams on ‘like‑for‑like’ treatment: the Procurement Act requires the same treatment for treaty‑state and UK suppliers in materially similar circumstances, and that includes accepting equivalent forms of evidence at selection stage.

Suppliers from Iraq or Kazakhstan eyeing Welsh tenders should prepare to evidence establishment and control consistent with treaty definitions, line up English‑language documents, and be ready for standard checks on sanctions, beneficial ownership and security. Equal treatment is not a waiver of due diligence-selection criteria and security requirements still bite on a proportionate basis under the Act.

Welsh and UK firms gain on the export side too. Because these are reciprocal arrangements, the shift should make it easier for engineering, consultancy and digital services SMEs in Wales to compete for central and sub‑central opportunities in Iraq and Kazakhstan where the treaties open those markets. Ministers flagged that reciprocity when seeking Senedd approval.

Not everything is in scope. Treaty schedules typically carve out sensitive services such as elements of healthcare, R&D and broadcasting content. Before launching or bidding, check whether your entity, the contract type and the service codes are actually listed in the relevant market access schedule. This avoids disputes over coverage after evaluation.

A quick practical example helps. If a council in Wales publishes a covered above‑threshold consultancy tender after the procurement chapter takes effect, an Iraqi or Kazakhstani supplier claiming treaty‑state status must be treated on an equal footing with UK bidders-same time limits, same technical clarifications, and the same remedy routes if something goes wrong. If the notice went out before the chapter applied, the legacy footing stands for that competition.

At UK level, a parallel statutory instrument updating the ‘specified international agreements’ list comes into force on 30 December 2025. Wales follows a day later for devolved procurements, keeping the procurement regime coherent across the UK while respecting devolved competence. Buyers operating cross‑border should align timelines and documentation accordingly.

What to watch next is timing. The commercial effect in Wales begins when the procurement chapters in the Iraq and Kazakhstan treaties apply, not simply on the date the Welsh regulations commence. Keep an eye on FCDO treaty updates and notice wording in new tenders; authorities should signpost when an opportunity is covered by treaty access in their documentation.

For most SMEs, the takeaway is clear: treat this as new market access with familiar rules. Read the market access schedules, prepare equivalent documentation, and assume equal treatment on covered tenders in Wales once the chapters are in force. That is a compliance lift worth doing now, with potential upside on both sides of the supply chain.