The April to September 2026 reporting period closes on 30 September. Contracting authorities should prepare two related but distinct payment disclosures: the six-monthly **UK17 Payments Compliance Notice** under section 69 of the Procurement Act 2023 and, where applicable, quarterly information about individual payments under section 70. Treating them as one return risks using the wrong contract population, reporting period or approval process.
The practical task is to establish scope, reconcile source data and retain a clear sign-off record before the October publication window closes. This article focuses on procurements regulated by the UK regime; devolved and exempt arrangements need their own check.
Which October payment disclosures are due?
A UK17 notice reports how promptly an authority paid invoices under public contracts during a six-month reporting period. The second period runs from **1 April to 30 September 2026**. The Cabinet Office's implementation guidance says the notice must be published within 30 days of the period ending. The Payments Compliance Notices guidance explains the measures and required finance approval.
Section 70 is a different publication. It concerns payments **over £30,000 including VAT** made under relevant public contracts and is reported quarterly. For the July to September quarter, publication is due by the end of October 2026. Its scope is narrower: the Cabinet Office says it applies to public contracts procured under the Act where the procurement commenced on or after **1 April 2026**, subject to the statutory exceptions. An older contract should not be pulled into that dataset merely because a payment was made this quarter.
Check 1: define the contract population
Start with a list of contracts and record the legislation and commencement date applicable to each procurement. Identify public contracts, any relevant statutory exceptions and the contracts that feed each return. Finance data alone may not establish whether a payment falls within section 70; procurement and contract records must supply that context.
Create two controlled extracts rather than one spreadsheet repurposed for both duties. Record the source system, extraction date, query logic and person responsible. This makes later corrections explainable.
Check 2: reconcile invoices and payment dates
For UK17, test the average payment time and the proportions paid within days 1–30, days 31–60 and on or after day 61. Check invoices that became payable but remained unpaid at period end. The notice also needs information about compliance with the statutory payment term and must be approved by the finance director or equivalent. The official guidance explains how disputed or invalid invoices are treated; do not silently remove them without a documented basis.
Reconcile a sample of records back to invoices, receipt dates, bank settlement data and contract identifiers. Investigate negative intervals, duplicate invoices, credit notes, payments crossing the period boundary and values recorded without VAT. A payment date generated by an internal batch process may differ from the date funds reach the supplier.
Check 3: review the section 70 return separately
Filter for payments above the statutory value threshold, then verify that each underlying procurement started under the Act on or after 1 April 2026 and is not excepted. Confirm the reporting quarter, supplier identifier, contract reference and amount before upload. A missing or inconsistent contract identifier can make a technically complete return difficult to interpret.
The aim is a traceable public record, not simply a file that passes portal validation. The first section 70 publication raised data-quality questions; our earlier review of that reporting cycle sets out the operational lessons.
Check 4: approve what the data actually says
Give procurement, finance and contract management a shared exception list. Ask a named reviewer to resolve material differences between ledger data and contract records. Keep the calculation method, sample checks, corrections and approval decision together. A senior sign-off should be based on an intelligible summary of the results and unresolved issues, not an unseen spreadsheet.
What should authorities do this week?
Close the reporting population as at 30 September, identify owners for both returns, run a sample reconciliation and agree an approval timetable before the October deadlines. Where the data exposes slow payment, use the result to improve invoice handling and supplier communication. Accurate publication is the compliance task; a credible improvement plan is the commercial task.
**Primary sources:** Cabinet Office implementation guide and Payments Compliance Notices guidance.
This article is general procurement guidance, not legal advice. Check the Act, regulations and guidance applicable to the authority and contract before publication.