Procurement Policy Note 01/17: Update to Transparency Principles · first published 16 February 2017
PPN 01/17 updates and replaces PPN 13/15, setting out what central government and its suppliers must do to be transparent about public contracts. The core shift is that disclosure is the default: contract values, performance metrics, governance arrangements and improvement plans should be published, not hidden. Commercial confidentiality can only be used to protect narrow things like pricing methodology or business plans — not the contract value itself or performance data. All central government contracts over £12,000 must be published on Contracts Finder. As a supplier, you will be required by contract to provide government with information it needs to respond to public and Freedom of Information Act (FOIA) requests, and you must be ready for audit access by the National Audit Office (NAO).
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs, the transparency default is broadly positive: Contracts Finder publication of all contracts over £12,000 means more visible opportunities and a level playing field on market intelligence. The risk is on the delivery side — if your performance metrics are published, underperformance is publicly visible, so SMEs must manage contracts actively from day one. The complaints route via the Crown Commercial Service (CCS) Mystery Shopper Service is a useful, low-cost tool if a buyer makes unreasonable information demands on you.
1. Read the transparency requirements section of every tender carefully — buyers must spell out exactly what data you will need to publish. Confirm you can produce and supply it before you bid.
All SMEs bidding for central government contracts — The document requires buyers to 'explain transparency requirements to potential suppliers as early as possible in the procurement process and set out clearly in tender documentation the types of information to be disclosed on contract award and thereafter.'
2. Set up a simple system from contract start to track and report performance metrics, governance arrangements and improvement plans — these are contractually required to be published.
All SMEs delivering central government contracts — Contracts must cover 'performance metrics … plans for management of underperformance … service improvement plans' as publishable information, so you need a process to generate this data reliably.
3. Make sure your subcontract agreements include a transparency and audit clause, because governance arrangements 'including those for supply chains where significant contract value rests with subcontractors' must be disclosed.
SMEs with subcontractors on central government work — The document explicitly names supply-chain governance as a disclosure category, meaning your subcontractors' data may need to flow up to the buyer.
4. Do not try to mark your contract value or performance data as commercially confidential — only pricing methodology, certain intellectual property and business plans can be withheld.
All SMEs supplying central government — 'The way the supplier has arrived at the price … could normally be withheld but this should not be grounds for withholding the contract value itself … This should not be grounds for withholding performance information.'
5. If you receive an information request from a buyer that feels disproportionate or like poor contract management, report it to the CCS Mystery Shopper Service rather than simply complying or refusing.
All SMEs supplying central government — The document explicitly directs non-strategic suppliers to 'raise any such request with the Crown Commercial Service's Mystery Shopper Service' — this is your low-cost escalation route.
6. Regularly search Contracts Finder, where all central government contracts over £12,000 must be published, to identify both direct opportunities and the incumbents you may be competing against.
SMEs looking for new opportunities — The document requires 'all central government contracts over £12,000 are published online on Contracts Finder', making this a mandated, comprehensive source of market intelligence.
Every rule below quotes the official document verbatim.
The note applies to all central government authorities and all their suppliers, including private, public, voluntary, community and mutual organisations. (All suppliers to central government authorities)
“all central government authorities … all suppliers to the above, whether from the public, private or voluntary and community sector, or new commercial models such as mutuals.”
All in-scope organisations must operate on a presumption in favour of disclosing information; commercial confidentiality is the exception, not the rule. (All central government suppliers and buyers)
“All in-scope organisations should operate on a presumption in favour of disclosing information … commercial confidentiality being the exception rather than the rule.”
Contract requirements must cover publication of: contract prices and incentivisation mechanisms, performance metrics, underperformance management plans, governance arrangements (including supply chains), resource plans, service improvement plans, and frequency of information release. (All central government contracts)
“contract prices and any incentivisation mechanisms in the contract … performance metrics … plans for management of underperformance … governance arrangements, including those for supply chains where significant contract value rests with subcontractors … resource plans … service improvement plans … frequency of information release.”
Pricing methodology, certain intellectual property details, and business plans may be withheld on commercial confidentiality grounds, but the contract value itself and performance information may not. (All central government contracts)
“The way the supplier has arrived at the price they are charging government in a contract could normally be withheld but this should not be grounds for withholding the contract value itself … This should not be grounds for withholding performance information.”
All central government contracts over £12,000 must be published online on Contracts Finder. (Central government contracts above £12,000)
“ensure that all central government contracts over £12,000 are published online on Contracts Finder.”
Data published must comply with Open Data Principles: accessible at no more than cost of reproduction, no restrictions by user identity or intent, in a digital machine-readable format under the Open Government Licence. (All in-scope procuring organisations)
“ensuring the data is accessible at no more than the cost of reproduction, without limitations based on user identity or intent, and in a digital, machine-readable format under the Open Government License.”
Suppliers must provide government with information to help it respond to public enquiries and FOIA requests relating to the contract, within a reasonable timeframe. (All central government suppliers)
“provide government with information that helps it respond to public enquiries regarding the contract(s) in question … respond to government queries that are relevant to the service in question within a reasonable time frame and with due consideration to the urgency of the question.”
The Comptroller and Auditor General (National Audit Office) retains access rights to government contracts regardless of audit arrangements agreed in the contract. (All central government contracts)
“This will not limit the rights of the National Audit Office to audit government contacts. The Comptroller and Auditor General will have access rights to government contracts.”
Non-strategic suppliers who believe an information request from government is unreasonable should raise it with the CCS Mystery Shopper Service; strategic suppliers should contact their Crown Representative. (All central government suppliers)
“suppliers that are not 'Strategic Suppliers' to government should raise any such request with the Crown Commercial Service's Mystery Shopper Service … Strategic Suppliers should refer the matter to their relevant Crown Representative.”
Transparency clauses have been incorporated into the government's Model Services Contract for major services contracts, and CCS is adopting them in model contracts for common goods and services. (Major services contracts and CCS common goods and services contracts)
“These have been incorporated into the government's Model Services Contract for major services contracts. Crown Commercial Service is also adopting the new transparency clause in their model contracts for common goods and services.”
The government has implemented the Open Contracting Data Standard (OCDS) by publishing Contracts Finder data in OCDS format. (Crown Commercial Service / Contracts Finder)
“The government has implemented the Open Contracting Data Standard (OCDS) in the Crown Commercial Service's operations by publishing Contracts Finder data in OCDS format.”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.