Compliance

Procurement Act 2023 for schools and academy trusts: what changed

What the Procurement Act 2023 means for schools and academy trusts: when it applies, the 2026 thresholds, how to tender and what to do now.

Published 29 October 2026By Assetproc

The Procurement Act 2023 has applied to schools and academy trusts in England since 24 February 2025. It replaced the Public Contracts Regulations 2015 for new procurements. If you are buying goods or services above the thresholds, you must now follow the Act’s rules, publish notices on the government’s central digital platform and award to the most advantageous tender.

This guide explains what the Procurement Act 2023 means for schools and trusts in practice, which contracts it covers and what to check before your next tender. It is written for business managers, finance leads and trust executives, not procurement lawyers.

Does the Procurement Act 2023 apply to your school or trust?

Yes, if you are running a procurement. The Department for Education (DfE) states that schools and trusts undertaking procurements are contracting authorities. That puts you in scope in the same way as councils and other public bodies.

Which rules apply to a particular purchase depends on its value and on the contract type. DfE’s guidance on buying procedures and procurement law for schools sets out five routes:

  1. Buy from a framework agreement, selecting the supplier directly where the framework allows it.
  2. Buy low-value goods from catalogues.
  3. For low or medium-value purchases, research suppliers and get at least three quotes.
  4. For high-value purchases below the public procurement threshold, advertise and run a buying process.
  5. For high-value purchases, run a process that complies with the Procurement Act 2023.

DfE describes low value as under £10,000, medium as £10,000 to £40,000 and high as over £40,000. It also tells schools to check their own procurement rules, so your trust’s financial regulations may set different bands. Always follow whichever is stricter.

The thresholds that apply in 2026

Thresholds are revised every two years. The current figures took effect on 1 January 2026 and apply to procurements that start on or after that date. A procurement started earlier is not affected.

According to Procurement Policy Note 023, the main thresholds are:

Contract type Threshold (including VAT)
Goods or services for a sub-central authority, including schools and academy trusts £207,720
Goods or services for a central government authority £135,018
Works contracts £5,193,000
Light touch contracts £663,540

Schools and academy trusts are sub-central authorities. Catering, cleaning, ICT and print are services contracts, so for most school and trust tenders the figure that matters is £207,720 including VAT over the life of the contract. The lower central government figure applies to government departments and similar bodies, not to schools.

Below the threshold, the Act still has requirements for “regulated below-threshold contracts”. If a contract is close to a threshold, take advice on how its value is calculated before you decide on a route.

What a compliant tender looks like

The Act’s central rule is that a contract following a competitive tendering procedure goes to the supplier with the most advantageous tender (section 19). That is a tender which meets your requirements and best satisfies your award criteria, scored using the methodology and weightings you set in advance. Price is part of the picture, not the whole of it.

In practice a compliant process involves:

  • Planning. Define the need, estimate the whole-life value and choose a route. Decide the award criteria and their weighting before you go to market.
  • Notices. Publish the tender and later notices on the central digital platform, which is the enhanced Find a Tender service. Suppliers use one account for it and for the Supplier Information Service. The notice types include pipeline notices, planned procurement notices, contract award notices and contract details notices.
  • Evaluation. Score every bid against the published criteria, record the reasons, and keep a clear audit trail.
  • Award. Tell bidders the outcome and give them the information they need to understand it.
  • Contract management. Keep the contract documents and details notice up to date, and manage performance after award.

DfE offers training on the Act, including registering on the central digital platform. Registering before you need it saves time when a tender is live.

Frameworks and the Academy Trust Handbook

A framework is often the quickest compliant route, and we compare the main providers in our guide to procurement frameworks from CCS, ESPO and YPO. A framework does not remove your duties. You must still follow its call-off rules, record why you chose a supplier and check that the framework suits your requirement.

Academy trusts must also follow the Academy Trust Handbook 2026, in force from 1 October 2026. It requires trusts to have a competitive procurement procedure in their financial framework, to follow the Procurement Act 2023 rules and thresholds, and to use the Find a Tender service (paragraph 2.25). Trusts must consider DfE buying opportunities when purchasing goods and services, and record how they reached their decision (paragraph 2.27).

Some categories have firmer rules:

  • Supply staff: use the Government Commercial Agency’s Supply Teachers and Education Recruitment agreement, or an alternative that costs no more (paragraph 2.28).
  • Energy: use DfE’s Energy for Schools service or a DfE-approved deal when contracts renew, unless you find an alternative of equivalent value for money (paragraph 2.29).
  • Management information systems: award MIS contracts under DfE’s MIS framework once it launches, planned for September 2027 (paragraph 2.30).

Where schools and trusts go wrong

These are common mistakes in school and trust procurement:

  • Rolling a contract on by default. A contract that auto-renews or is extended repeatedly may need to be re-tendered. Our article on hidden procurement costs in schools and trusts covers what to look for.
  • Thin evaluation records. If a challenged bidder asks why they lost, you need scoring notes that explain it.
  • Separate contracts across a trust. Several schools buying the same service separately may mean the combined value counts towards the threshold. Take advice on this.
  • Late planning. TUPE, mobilisation and notice periods all take time. A compliant tender takes months, not weeks.
  • No one owns the contract after award. Savings on paper disappear without active contract management.

A practical checklist before your next tender

  1. List every contract with its end date, value and notice period.
  2. Work out the total value over the full term, including extensions, and compare it with the threshold.
  3. Check your own financial regulations and the Academy Trust Handbook.
  4. Register on the central digital platform.
  5. Choose the route: framework call-off, or your own competitive process.
  6. Write the specification and award criteria before you approach suppliers.
  7. Keep a written record of every decision.

What compliant procurement can deliver

Compliance is not just a cost. Pickwick Academy Trust replaced five cleaning contractors with one trust-wide contract across seven schools, using a two-stage restricted procedure with weighted scoring. The result was £47,280 saved every year. You can read the full Pickwick Academy Trust cleaning case study, and see how we approach this on our cleaning tender service page.

How Assetproc can help

Assetproc is an independent procurement consultancy for schools, multi-academy trusts and the public sector. We map your contracts, work out which route applies, write specifications and award criteria, run the tender and support contract management after award. If you are not sure whether a contract needs a full process, our contract reviews are a good place to start.

To talk through a contract or an upcoming tender, get in touch with Assetproc.

This article is general information, not legal advice. Check the current legislation and DfE guidance before you start a procurement.

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