Procurement in a Nutshell – Pipeline Notice

The Procurement Act 2023 (the Act) came into force on 24th February 2025.

The Act, in particular, revoked the following:

• Public Contracts Regulations 2015 (PCR)
• Concession Contracts Regulations 2016
• Utilities Contracts Regulations 2016

Background

A Pipeline Notice is a publication outlining each individual procurement that will make up a contracting authority’s procurement pipeline over the next reporting period, providing the market with information about current and future public contract opportunities.

It is mandatory to publish a Pipeline Notice for any contracting authority that considers it will pay more than £100 million under relevant contracts in the coming financial year.

Each Pipeline Notice must be published within 56 days of the first day of the relevant financial year (Section 93(4)), which means that for this financial year, the notices will need to be published by 26th May 2025.

For further information on the legislative requirements relating to Pipeline Notices please see our previous Nutshell linked here.

A single Pipeline Notice or multiple?

As mentioned in our previous Nutshell, the guidance published in December 2024 stated that a Pipeline Notice was a single notice providing details of all relevant contracts that an authority intends to award during the reporting period, although digitally, details will need to be entered in relation to each individual procurement. It was therefore assumed that there would be one Pipeline Notice, covering multiple procurements.

However, the Government then published the UK1 Form which was designed so that an individual Pipeline Notice was required for each procurement, resulting in the guidance contradicting the commercial reality and misleading contracting authorities.

Since our previous Nutshell discussing this issue, the Government has revised the guidance on Pipeline Notices. The revised guidance now states (at paragraph 14) that in practice, a Pipeline Notice will need to be published for each individual procurement making up a contracting authorities pipeline.

What does this mean?

While the revised guidance clarifies the requirements relating to Pipeline Notices, and aligns with the structure of the UK1 Form, the administrative burden placed on contracting authorities cannot be understated.

Contracting authorities, who are anticipated to pay more than £100 million under relevant contracts in the coming financial year, must ensure that, by the 26th May 2025, an individual Pipeline Notice is published for each upcoming procurement. As such, authorities will need to manage their internal processes effectively to ensure the timely and correct publication of these notices.

This demands a more thorough procurement management process, requiring contracting authorities to prepare and mobilise their commercial teams efficiently.

For further information please contact Melanie Pears or Tim Care in our Public Sector Team.