By late May 2026, the Procurement Act 2023 is no longer new. The regime has been in force since February 2025, and councils have now had more than a year to adjust their procurement processes. That makes this a useful point to assess not only whether authorities understand the rules, but whether those rules have genuinely been embedded into everyday practice.
The picture is mixed. Many councils have made real progress, but recurring implementation issues are still appearing across procurement activity. These are not just isolated drafting errors or one-off operational slips. They point to wider weaknesses in governance, process alignment and commercial control.
Why this matters now
The first year or so of a new regime is usually where behavioural patterns become visible. Early assumptions harden into routine practice, good or bad.
For councils, that means May 2026 is a sensible point to stop describing issues as transition problems and start treating them as business-as-usual governance matters. If the same weaknesses are still appearing now, they are likely to recur unless authorities take active steps to address them.
Common issue 1: weak documentation
One of the clearest recurring problems is poor documentation.
Evaluation outcomes may be sensible, moderation may have been reasonable and the final decision may be defensible in substance. But if the council cannot show how it reached that decision through a strong record, it has a problem.
Under the Act, transparency and traceability matter more. Weak notes, thin approval records or fragmented files can undermine an otherwise lawful procurement.
Common issue 2: poor sequencing at award stage
Some councils are still applying old habits to new award-stage requirements.
Assessment summaries, contract award notices, standstill and contract entry now need to happen in the right sequence and with much clearer discipline. Where those steps are still treated as loosely connected tasks, authorities risk confusion, unnecessary supplier queries and avoidable legal exposure.
This is often less a legal knowledge problem than a process ownership problem.
Common issue 3: bidder communication that is too vague
A further issue is the quality of supplier communication, especially at award stage.
Assessment summaries are sometimes still too generic, too cautious or too disconnected from the actual evaluation record. That creates frustration for bidders and increases the chance of follow-up questions or challenge.
Where councils are struggling in this area, the problem usually begins earlier. If moderation reasoning is not captured well, the authority will find it much harder to explain the outcome later.
Common issue 4: fragmented data and record alignment
The Procurement Act places more emphasis on structured information and a visible procurement lifecycle.
That means councils need procurement records, contract records and, increasingly, related operational data to align more cleanly than before. In some authorities, those systems still sit too far apart. That may have been manageable under older practices, but it becomes harder under a regime built around transparency and traceability.
Common issue 5: over-reliance on templates
Templates are useful, but they do not replace understanding.
A number of councils are still relying too heavily on inherited documents or lightly revised forms that do not fully reflect the logic of the new regime. That can create subtle but important weaknesses in notices, approvals and bidder communications.
The stronger authorities are usually the ones that combine good templates with clearer ownership, stronger training and more disciplined review.
What councils should do now
This is a good point for authorities to run a practical implementation review.
That does not need to be a major project. Councils can start by selecting a small number of recent procurements and testing whether the documentation, sequencing, governance and communications would stand up well to scrutiny.
If weaknesses appear, the authority should treat that as a prompt to improve templates, clarify roles, refresh guidance and strengthen internal quality control.
Councils looking to strengthen their Procurement Act implementation, governance and commercial processes can explore relevant support through the Prestige Commercial Consulting main website.
Where targeted support may help
Where the same issues are appearing repeatedly, or where the authority is managing higher-risk procurements, additional support may accelerate improvement. Councils that want to discuss implementation challenges, governance arrangements or process redesign can use the Prestige Commercial Consulting contact page.
The takeaway
The Procurement Act 2023 is no longer in its opening weeks. By May 2026, councils should be treating recurring implementation issues as governance and capability matters, not temporary bedding-in problems.
Authorities that use this point to tighten documentation, sequencing and internal control will be in a much stronger position for the rest of the year.