Public procurement is moving into a new phase. The Procurement Act 2023 has changed more than the rules for running a compliant tender process, and the developing Commercial Payments Bill points in the same direction: organisations spending public money will increasingly be judged on how contracts are managed, how suppliers are paid and how supply-chain risk is controlled after award.
For housing associations and public bodies, that shift matters. Development, retrofit, maintenance and repairs rely on supply chains that need to work in practice, not just on paper. A compliant award is only the start.
The Procurement Act reaches beyond award
The Procurement Act includes obligations relating to contract performance, modifications, termination, payments and transparency. Procurement, operational, finance, commercial and legal teams need to consider the entire contract lifecycle, not simply the tender process.
Why payment now matters beyond finance
Section 68 of the Act implies payment terms into most public contracts. In broad terms, sums due must be paid within 30 days of receipt of an invoice or, if later, when payment falls due in accordance with the invoice, subject to the statutory provisions on disputed or invalid invoices.
Section 73 carries equivalent protections into public sub-contracts, helping to ensure that prompt payment does not stop at the first tier of the supply chain.
For housing associations, delivery often depends on networks of contractors, subcontractors, consultants and specialist SMEs. Payment delays can quickly become an operational as well as a financial problem.
The transparency position needs particular care in Wales. Section 69 payments compliance notices took effect for procurement regulated by the Welsh Ministers on 1 April 2026, following commencement elsewhere in January. Section 70, concerning information about individual payments above the statutory threshold, has not yet commenced . Organisations must identify which requirements apply to their procurement, rather than assume a uniform UK position.
Reliable data and clear accountability matter beyond statutory reporting: they show whether payment processes actually work. That means tracking invoice disputes and approval bottlenecks, as well as payment dates. Contract reviews should also test whether main contractors can evidence payment to subcontractors, rather than relying only on a promise in the tender.
The Commercial Payments Bill raises the stakes
The Bill completed its House of Lords third reading on 20 October 2026 and has moved to the Commons. The practical task is to prepare for the proposals that emerged from the Lords, while recognising that they are not yet law.
Those proposals include maximum commercial payment periods, mandatory statutory interest that cannot be contracted out of, stronger payment-dispute remedies and expanded Small Business Commissioner powers. The general ceiling would be 60 days for private purchasers and 30 days for public authorities, which retains the 30 day period under the Procurement Act.
The Bill would also amend the Procurement Act directly through Schedule 1, Part 3. One amendment would replace section 69’s reference to compliance with the 30-day term with the broader concept of “payment performance”. That wording does not itself create an additional payment deadline. For ordinary public contracts, a separate amendment would remove section 68’s alternative later invoice-due-date starting point, making receipt the basis of the 30-day period.
It nevertheless offers a useful management lens. Procurement leaders should ask where delays arise, whether invoice validation is proportionate, what happens further down the supply chain and what payment data reveals about contract management. Paying the main contractor promptly is not enough if money then stalls before reaching the businesses delivering the work.