A new Procurement Act 2023 reporting deadline is now approaching quickly, and it is one that local authorities should treat as a live operational priority rather than a late-April publishing exercise.
The first UK17 Payments Compliance Notice must be published between 31 March 2026 and 29 April 2026. For many councils, the challenge is not just the deadline itself. It is the fact that the first notice is expected to report on payment timings from 1 October 2025 to 31 March 2026, which means authorities need to look backwards, extract reliable payment data and produce a notice that can withstand internal and external scrutiny.
This matters because payment performance is no longer simply a finance process hidden in the background. Under the Procurement Act 2023, prompt payment is part of the wider transparency and contract governance framework. Councils that cannot evidence how quickly they pay suppliers may find that the issue quickly becomes one of commercial credibility, supplier confidence and internal assurance.
What is the Payments Compliance Notice?
The Payments Compliance Notice is the formal transparency notice used to report how promptly a contracting authority pays under public contracts. It is tied to the new payment regime under the Procurement Act 2023, which implies a 30 day payment term into public contracts and pushes authorities to demonstrate compliance through regular published reporting.
In practical terms, the notice is designed to show whether an authority is paying valid invoices within the required timeframe and how its wider payment profile looks across a six month reporting period. This moves payment performance into the public domain and makes it easier for suppliers, auditors and governance teams to compare an authority’s stated standards with its actual practice.
For local authorities, that is significant. Prompt payment affects supplier relationships, SME participation, market confidence and the authority’s reputation as a customer. It also connects directly to wider priorities around social value and inclusive local economies. A council that talks about supporting smaller providers but pays slowly will now find that gap much harder to hide.
Why this first deadline is particularly important
The first notice is awkward because it arrives early in the life of the new regime but still demands a meaningful body of historic data. Many councils will not yet have a ready-made report that captures exactly what is needed in exactly the right format.
There is also a common practical problem. Payment data often sits in finance systems, while contract information sits elsewhere, and the people who understand the legislative requirement may not be the people who can extract the payment evidence. That creates a risk of fragmented ownership, last minute uncertainty and a rushed notice that has not been properly checked.
The requirement for senior finance approval raises the stakes further. This is not a document that procurement can produce quietly on its own. The notice must be backed by the director or similar officer responsible for the authority’s finances. That means councils need a coordinated approach between procurement, finance, systems and governance colleagues now, not in the final days before publication.
What must be included
Authorities need to ensure the notice contains the required reporting information for the relevant period. That includes the reporting dates, the average number of days taken to make payments, and the percentages of payments made within the key time bands of up to 30 days, 31 to 60 days, and 61 days or more.
It also needs to capture the percentage of sums that became payable during the reporting period but were not paid within that same period. That is an important measure because it highlights not just how quickly payments were made, but whether liabilities were left outstanding at the close of the period.
The notice must also include approval from the senior finance officer, with their name and job title. For governance teams, that is an important point. It signals that payment reporting is meant to carry real professional accountability, not just administrative publication.
Where councils may come unstuck
The most obvious risk is data quality. If invoice receipt dates are not held consistently, or if the system records payment approval dates rather than actual supplier receipt dates, the calculations may not reflect the required methodology. Authorities should not assume that an existing creditors report will automatically produce a compliant answer.
A second risk is scope. The notice is about payments under public contracts. Authorities therefore need a sensible and documented method for deciding which payments fall within scope and which do not. Without that, teams may end up arguing over the population after the extraction has already been run.
A third risk is governance timing. Senior sign-off can become a bottleneck if the draft notice is only prepared near the end of April. Councils should assume that finance leadership will expect a clear explanation of the methodology, any data limitations and the reasons behind the reported figures.
Finally, there is a publication risk. Authorities need to be confident about how they will submit the notice and whether their existing systems or e-sender arrangements are ready. Assuming the route will simply be available and familiar is not a safe approach.
What local authorities should do now
The first step is to assign clear ownership. One officer should coordinate the exercise, but the work itself needs input from procurement, finance and system owners. If responsibility remains vague, the deadline will become much harder to manage.
The second step is to agree the methodology. Councils should document which contracts and payments are being included, how invoice dates are being identified, and how the required payment periods are being calculated. A short internal methodology note will save time and reduce challenge later.
The third step is to run an early data extract. Waiting until the publication window opens is unnecessary risk. An early test run allows authorities to spot missing fields, duplicate records, inconsistent dates or classification problems while there is still time to fix them.
The fourth step is to line up approval. Finance leadership should be briefed now, not surprised later. A draft notice, a summary of the figures and a concise explanation of the approach should be prepared in advance so the required approval can be secured smoothly.
The fifth step is to treat this as more than a one-off notice. The first publication should be used to establish a repeatable process for future six month reporting periods. Authorities that do that now will avoid turning every notice into a fresh scramble.
The wider lesson for councils
This deadline is one of the clearest early tests of whether a council has genuinely embedded the Procurement Act 2023 into day-to-day operations. It is easy to focus on tendering, award procedures and notices at the front end of procurement. The payments regime is a reminder that the Act also reaches deep into contract management, transparency and supplier treatment after award.
For local authorities, the real question is no longer whether prompt payment matters. It is whether the council can evidence its performance clearly, accurately and on time.
Councils that act now should still have time to get this right. Those that delay may discover that the first Payments Compliance Notice exposes wider weaknesses in contract data, system integration and internal accountability. In that sense, the deadline is not just a publishing obligation. It is a practical compliance test, and one that local authorities should already be preparing to meet.