Significant Payment Notices – Duty under Section 70 of the Procurement Act 2023 (Effective 1 April 2026)
Overview
From 1 April 2026, contracting authorities in England will be required to comply with a new transparency duty under section 70 of the Procurement Act 2023, obliging them to publish quarterly notices of any payment over £30,000 made under a public contract.
These obligations are confirmed in the Procurement Act 2023 (Commencement No. 4) Regulations 2025, which bring section 70 into force on that date.
This requirement sits alongside other payment related duties introduced by section 69 (Payment Compliance Notices) and forms part of an expanding transparency framework intended to shine a light on public spending and supplier performance.
The level of detail required in Significant Payment Notices has not yet been specified in the Procurement Regulations, but further amendments and government guidance are expected before April 2026.
What Section 70 requires
Under section 70, contracting authorities must:
- Issue a Significant Payment Notice for any payment over £30,000 made under a public contract
- Publish these notices on a quarterly basis
- Ensure that each notice is published within the timelines prescribed in forthcoming regulations
The regulations highlight section 70’s commencement and reinforce the need for authorities to prepare internal systems ahead of the April 2026 go‑live date.
Because the Regulations have not yet set out the required content, it remains unclear what level of granularity (e.g. invoice details, contract identifiers, payment justification) will be mandated.
Why this matters
The publication of high‑value payments is likely to bring significant external scrutiny. Authorities may face:
- Reputational questions if large payments appear unusual for the stage or value of the contract
- Audit or media interest where payments depart from typical patterns
- Political attention, particularly for capital‑intensive or high‑profile projects
Suppliers may also find that their commercial arrangements attract undesired visibility, potentially affecting negotiations or public perceptions.
Recommended steps for contracting authorities
Ahead of April 2026, authorities should:
- Review financial processes to ensure all payments over £30,000 can be reliably identified and extracted
- Prepare internal reporting workflows, including senior or director‑level review before publication
- Begin drafting internal templates, ready to adapt once the statutory format is confirmed
- Consider reputational risk, especially where large milestone or mobilisation payments are standard for certain contract types
- Ensure alignment with related transparency duties under sections 69 and 71
The phased commencement framework set out in the Procurement Act 2023 (Commencement No. 4) Regulations 2025 emphasises that these transparency duties should be embedded into procurement and contract‑management practice now, not left until the deadline approaches.
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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
Our team advises both contracting authorities and suppliers on preparing for the transparency obligations under the Procurement Act 2023. We can help with:
- Designing compliant reporting processes
- Updating financial and contract‑management frameworks
- Drafting compliant notice templates
- Advising on reputational and commercial implications
- Training procurement and finance teams
If you require tailored advice on the impact of section 70 or how these obligations interact with sections 69 and 71, please contact us.
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