From 1 January 2026, contracting authorities will be required to publish six‑monthly Payment Compliance Notices demonstrating how they have met the statutory duty to pay invoices within 30 days, as set out in section 69 of the Procurement Act 2023. These new transparency obligations form part of the phased implementation of the Act under the Procurement Act 2023 (Commencement No. 4) Regulations 2025.
The first reporting period will cover 1 January 2026 to 31 March 2026, with notices required to be published within 30 days of the period ending — meaning by April 2026. For Welsh‑regulated procurements, the duty begins slightly later, on 1 April 2026.
What contracting authorities must publish
Each Payment Compliance Notice must include the information prescribed under the Procurement Regulations 2024, including:
- The authority’s details and the reporting period covered
- The average number of days taken to pay invoices
- The percentage of invoices paid within:
- 0–30 days
- 31–60 days
- 61+ days
- The percentage of invoices that remained unpaid during the period
- A director‑level confirmation verifying the accuracy of the notice
Authorities should ensure that systems and governance processes are in place to publish these notices on the central platform within statutory deadlines.
Why this matters
These new notices are intended to increase transparency and accountability around payment practices, particularly where supply chains rely heavily on SMEs. Authorities that delay payments risk reputational damage and may also be exposed to compliance risk.
How contracting authorities can prepare
There are several practical steps that authorities should consider now to ensure readiness:
- Update internal templates to reflect the new reporting content
- Ensure finance systems can extract accurate payment data for each reporting window
- Establish internal approval workflows, including director‑level sign‑off
- Train procurement and finance teams on the new statutory obligations
- Review existing contracts to understand which arrangements require payment reporting
- Prepare for publication on the Central Digital Platform as required under the Act
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The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
How we can support
We regularly advise contracting authorities on implementing the Procurement Act 2023 and can assist with:
- Reviewing internal payment processes
- Drafting compliant Payment Compliance Notices
- Updating contract templates and policies
- Delivering training workshops for procurement and finance teams
If you would like support in preparing for the first reporting cycle, please get in touch.
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