PA23 compliance risks are rising: 4 warning signs from the latest PPRS data and 16 actions to take now
The Procurement Act 2023 has now been live for a year, but the latest Cabinet Office Public Procurement Review Service (PPRS) data shows that compliance gaps persist.
While overall complaint volumes remain modest, the proportion of upheld complaints is rising, transparency issues are becoming more visible, and late payment continues to undermine supplier confidence, especially for SMEs.
It is not clear from the data whether the complaints relate to above or below‑threshold procurements, where the latter have formal remedies in law. However, the PPRS cases still act as a critical barometer of good practice, consistency, and organisational maturity and as such, the themes should be taken seriously.
Here’s what the data signals and what housing associations need to do next.
- Upheld complaints are climbing – and that matters more than volume
Complaint volumes had steadily fallen from their 2018 peak through to 2022, likely due to COVID‑19 disruption and emergency procedures. Since 2023, volumes have risen modestly as organisations prepared for the Procurement Act 2023, but volume alone is no longer a reliable proxy for procurement health.
What matters far more is that the proportion of complaints upheld by PPRS has increased sharply, from 41% in 2023 to 56% in 2025.
This tells us two things:
- Suppliers now challenge with stronger evidence, clearer understanding of their rights, and greater confidence.
- Regulators are applying stricter scrutiny, and are less tolerant of weak documentation, inconsistent processes, or unclear evaluation.
Despite complaint numbers remaining below their pre‑2019 levels, the share of upheld cases has more than tripled since 2020 – an unmistakable signal of rising expectations and tightening standards.
What does this mean for housing associations?
This is a warning sign, not a statistical quirk.
- “No complaints” is no longer a safety blanket.
Silence from the market often reflects insufficient transparency, not perfect compliance. - When suppliers do challenge, they are increasingly correct.
Upheld rates above 50% indicate systemic gaps in evaluation discipline, documentation, or feedback quality.
4 tips what procurement teams should do now
- Pressure‑test procurement processes
Ensure you have full auditability and clear evidence of how decisions were made. - Strengthen evaluation discipline
Moderation, justification, and consistency matter more than ever. - Invest in better feedback
Vague, generic, or minimal feedback is a fast track to escalation. - Treat PPRS cases as sector‑wide learning
Even if your organisation hasn’t yet faced challenge, the risks highlighted apply universally.
Bottom line:
Reliance on historic templates, informal practice or undocumented decision‑making is now a genuine organisational liability. Those who strengthen governance early avoid becoming part of the next upheld statistic.
- Transparency is the new battleground
One of the clearest shifts in the data is the rise in transparency‑related complaints. While still fewer than process or payment issues, transparency failures are becoming a leading early indicator of poor readiness.
This is by design: the Procurement Act 2023 is structured to expose weak practice, not reduce complaints. More notices, more data, and better supplier visibility mean inconsistencies are easier to spot, and harder to hide. Many recent PPRS cases point not to intentional non‑compliance, but to insufficient organisational readiness, unclear documentation, or misalignment between teams.
What does this mean for housing associations?
Transparency is now a front‑line risk, not an administrative task.
- Perception of fairness matters as much as actual fairness.
A fully compliant procurement can still generate challenge if documentation is unclear or inconsistent. - Informal practice is no longer safe.
Suppliers can now “join the dots” across notices, feedback, clarifications, and award rationale. - Minor gaps escalate quickly.
Missing logs, unclear evaluation notes, or inconsistent messaging often trigger formal complaints.
4 tips what procurement teams should do now
- Treat transparency as a process, not a publication event
Documentation must be built in real time, not retrofitted. - Map responsibilities for notices and data
Particularly important where procurement is devolved or spread across departments. - Assume suppliers will scrutinise everything
If you can’t clearly explain a decision, expect questions. - Build capability, not just templates
People need to understand why transparency matters, not just what to publish.
Bottom line:
Transparency is becoming the defining indicator of procurement maturity. Getting it right builds trust; getting it wrong invites challenge.
- Late payment: a persistent and reputational risk
Despite years of policy pressure, late payment remains one of the most consistent themes in PPRS complaints, cutting across councils, NHS trusts, and arms‑length bodies.
Unlike evaluation disputes, late payment is:
- easy to evidence,
- hard to defend, and
- highly visible.
This makes late payment complaints more likely to be upheld and more damaging to your organisational reputation.
With the Procurement Act’s increased focus on payment reporting (even though formal requirements apply to above‑threshold public contracts), many associations will opt for broader supply chain reporting in the name of consistency.
This means poor payment performance will become more visible, and more scrutinised than ever before.
What does this mean for housing associations?
Late payment is no longer just a finance issue. It is a:
- supplier confidence issue,
- market access issue for SMEs, and
- public reputation issue.
Suppliers interpret late payment as a proxy for organisational culture and reliability. Poor payment behaviour discourages future bids and damages trust – even if your procurement processes are otherwise strong.
4 tips what procurement teams should do now
- Integrate finance, procurement and contract management
Most payment failures occur post‑award; ownership must be explicit. - Embed payment KPIs into contract management
Monitor them like any other critical metric. - Decide what you will report and stick to it
Consistency is more important than breadth. - Treat late payment as preventable
Early engagement avoids escalation, interest charges, and reputational fallout.
Bottom line:
Late payment is where procurement policy meets operational reality. If the two don’t align, supplier confidence erodes and so does governance credibility.
- Repeat offenders = a governance red flag
A small number of contracting authorities appear repeatedly in PPRS data across multiple years. Activity levels alone don’t explain this, the pattern usually points to systemic issues, such as:
- unclear governance
- weak assurance
- inconsistent application of rules
- under‑resourced procurement teams
Under the Procurement Act, such patterns matter more than ever. Regulators, boards and suppliers pay attention to behaviour over time, not isolated incidents.
What does this mean for housing associations?
If similar issues recur across procurements, even small ones, this is not a procurement problem. It is a governance signal.
Boards will increasingly be judged on whether they:
- understand procurement risk,
- receive meaningful reporting, and
- invest in capability and oversight.
4 tips what procurement teams should do now
- Look for patterns, not patches
Track themes across procurements, not just individual fixes. - Strengthen second‑line assurance
Independent checks should be standard for major or high‑risk procurements. - Elevate procurement within governance structures
Risk reporting, not just savings or spend, must reach executive level. - Invest in capability and culture
Repeated issues almost always indicate overstretched teams or outdated processes.
Bottom line:
Repeat complaints are rarely bad luck. They indicate deeper organisational vulnerabilities that become more visible under the Procurement Act’s transparency regime.
Conclusion: Procurement maturity is now a strategic imperative
The latest PPRS data paints a clear picture: expectations are rising, scrutiny is intensifying, and suppliers are more informed than ever. Across upheld complaints, transparency failures, late payment issues and repeat patterns, the message is consistent:
Procurement compliance is no longer about avoiding challenge, it is about demonstrating maturity, fairness and accountability.
Housing associations that act early to strengthen governance, capability, documentation and supplier engagement will:
- reduce complaint risk,
- improve supplier relationships,
- enhance governance confidence, and
- position themselves strongly under the Procurement Act’s new regime.
Those who wait will find that the market, and regulators, are already judging.
Ready to assess your organisation’s compliance maturity?
Download our Procurement Compliance Checklist to identify gaps and strengthen your approach under the Procurement Act 2023.
