The debarment list is real: how suppliers stay on the right side of it
The Procurement Act 2023 gave the UK something it never had before: a central, published debarment list. A supplier placed on it can be shut out of covered public procurements across the board — not just with one buyer. For the overwhelming majority of businesses this will never be a problem, but every bidder should understand how the regime works, because the exclusion grounds behind it apply to every bid you make.
Mandatory and discretionary grounds
Exclusion grounds come in two strengths. Mandatory grounds — serious matters such as fraud, bribery, tax offences or certain competition breaches — mean a buyer must exclude the supplier. Discretionary grounds — including professional misconduct and, notably, persistent or serious poor performance on earlier public contracts — mean a buyer may exclude. The debarment list is the sharp end: central government can investigate a supplier and, if a ground applies, place them on the published list.
It reaches further than your own company
Buyers look at connected persons and key subcontractors, not just the bidding entity. A problem in an associated company — or in a subcontractor you rely on for a bid — can raise an exclusion question for you. Know your supply chain before the buyer asks.
Self-cleaning: problems can be fixed
The regime is not meant to be a life sentence. If an issue occurred, a supplier can put forward self-cleaning evidence — remedial action, compensation paid, personnel or governance changes, compliance programmes — and the buyer must consider whether the circumstances are likely to recur. Documented, genuine remediation is the difference between a past issue and a present exclusion.
What to do
Keep the basics in order: tax affairs current, accounts filed, health-and-safety and data-protection records clean, subcontractors vetted. If something has gone wrong on a past contract, deal with it head-on and keep the paper trail — the rules reward suppliers who fixed the problem, and punish the ones who hid it.