PPN 02/24 Improving Transparency of AI use in Procurement · first published 25 March 2024
PPN 02/24 (Procurement Policy Note 02/24) gives central government buyers optional questions to ask suppliers about their use of Artificial Intelligence (AI) — both in writing bids and in delivering the contracted service. Using AI to write a tender is explicitly not banned; the policy recognises it can help smaller firms bid for more contracts. However, buyers may ask you to disclose AI use, check your responses for accuracy, and carry out additional due diligence (such as site visits or clarification questions) if they think AI-generated content introduces risk. The example disclosure questions in the policy are for information only and must not be scored in evaluation — so answering honestly cannot directly harm your bid score. The policy applies to central government departments, executive agencies, and Non-Departmental Public Bodies (NDPBs); other public bodies are encouraged but not required to follow it.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs, the explicit statement that AI bid-writing is not prohibited is a green light to use tools like Large Language Models (LLMs) to compete more efficiently — levelling the playing field against larger rivals with bigger bid teams. The risk is that AI-generated content that contains inaccuracies ("hallucinations") could trigger extra scrutiny, site visits, or clarification rounds that delay or undermine your bid; human review of any AI-drafted text is therefore essential. SMEs delivering services that embed AI (e.g. transcription, translation, analytics) should also be ready to describe that use proactively, as buyers will increasingly ask.
1. If you use AI tools (e.g. ChatGPT, Copilot) to draft any part of your tender, always have a human expert review and verify every fact, figure and reference before submission — and be ready to tick 'Yes' and provide details on any AI disclosure question.
All SMEs bidding for central government contracts — The PPN states LLMs may produce 'inaccurate or misleading statements' and that buyers may carry out additional due diligence — including site visits and clarifications — if AI use introduces risk. Verified, accurate responses reduce that scrutiny.
2. Do not use any confidential documents shared by the buyer during the procurement (e.g. specifications, draft contracts) as input or training data for AI tools.
All SMEs bidding for central government contracts — The PPN explicitly flags controls against 'using confidential Government tender documents to train AI or Large Language Models' — breaching this could constitute a serious compliance failure.
3. Prepare a clear, plain-English description of how AI is integrated into your service offering — ready to attach to any tender that includes an AI service-delivery disclosure question.
SMEs whose products or services embed AI (e.g. transcription, analytics, translation, automation) — The PPN introduces Example Disclosure Question 3 specifically asking whether AI is used in service delivery; buyers will increasingly include this, and a prepared answer avoids last-minute gaps.
4. Treat AI disclosure questions as a transparency opportunity, not a threat — answer honestly and use the free-text box to explain your quality-assurance process for AI-generated content.
All SMEs bidding for central government contracts — The PPN states disclosure questions 'should not be scored or taken into account in tender evaluation' and that buyers must not discriminate based on responses — so honest disclosure with a strong QA narrative costs you nothing on score and builds credibility.
5. If your bid involves any AI use and the contract touches national security, proactively ask the buyer at early market engagement whether additional information assurance requirements apply.
SMEs bidding on contracts with national security relevance — The PPN notes that 'in certain procurements where there are national security concerns in relation to use of AI by suppliers, there may be additional considerations and risk mitigations that are required' — getting ahead of this avoids late-stage surprises.
Every rule below quotes the official document verbatim.
The PPN applies to all central government departments, their executive agencies and Non-Departmental Public Bodies (NDPBs); other public sector bodies may adopt it voluntarily. (All in-scope central government organisations; wider public sector voluntary)
“The contents of this Procurement Policy Note (PPN) apply to all Central Government Departments, their Executive Agencies and Non-Departmental Public Bodies... Other public sector contracting authorities may wish to apply the approach set out in this PPN.”
Suppliers using AI to write bids is not prohibited during the commercial process. (All suppliers bidding for in-scope central government contracts)
“suppliers' use of AI is not prohibited during the commercial process but steps should be taken to understand the risks associated with the use of AI tools in this context”
Example AI disclosure questions must not be scored or taken into account in tender evaluation — they are for information only. (All in-scope central government procurements using the example disclosure questions)
“The Questions included in this annex should not be scored or taken into account in tender evaluation, and should be used for information only.”
Buyers may ask suppliers to disclose whether they used AI or machine learning tools (including LLMs) in any part of their tender submission, and to confirm responses have been checked for accuracy. (All in-scope central government procurements)
“Asking suppliers to disclose their use of AI in the creation of their tender (See Annex B for an example of text that can be added to procurement documentation).”
If a supplier uses AI to create tender responses, buyers may require additional due diligence — including site visits, clarification questions or supplier presentations — to verify capacity and capability. (All in-scope central government procurements where AI bid-writing is disclosed or suspected)
“If suppliers use AI tools to create tender responses, additional due diligence may be required to ensure suppliers have the appropriate capacity and capability to fulfil the requirements of the contract. Such due diligence should be proportionate to any additional specific risk posed by the use of AI, and could include site visits, clarification questions or supplier presentations.”
Suppliers must not use confidential government tender documents or information not already in the public domain as training data for AI systems or LLMs. (All suppliers bidding for in-scope central government contracts)
“Putting in place proportionate controls to ensure bidders do not use confidential contracting authority information, or information not already in the public domain as training data for AI systems e.g. using confidential Government tender documents to train AI or Large Language Models to create future tender responses.”
Buyers should also ask suppliers whether AI is embedded in the service they intend to deliver (not just used in bid-writing), using a separate disclosure question. (All in-scope central government procurements for services that may embed AI)
“Where AI is likely to be used in the delivery of a service, commercial teams may wish to require suppliers to declare this, and provide further details (see Example Disclosure Question 3).”
LLM-generated content may contain inaccurate or misleading statements ('hallucinations') because LLMs predict statistically plausible text rather than factually accurate text. (All suppliers using LLMs to draft tender responses)
“Content created with the support of Large Language Models (LLMs) may include inaccurate or misleading statements; where statements, facts or references appear plausible, but are in fact false.”
Buyers are warned not to discriminate against suppliers based on their use of AI or their responses to disclosure questions. (All in-scope central government buyers)
“It is important that contracting authorities do not discriminate against particular suppliers in the use of these questions or in the interpretation of supplier responses.”
Buyers should plan for a general increase in bid volumes and clarification questions as AI enables suppliers to streamline bid-writing, and may allow more procurement time accordingly. (All in-scope central government buyers)
“Planning for a general increase in activity as suppliers may use AI to streamline or automate their processes and improve their bid writing capability and capacity leading to an increase in clarification questions and tender responses.”
This briefing is enkii's interpretation of the official document — the official text always governs.
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