The UK debarment list is still empty. Your subcontractors still count.

The Procurement Act 2023 came into force on 24 February 2025. It introduced a central debarment list of suppliers that contracting authorities in England, Wales and Northern Ireland must take into account. At the time of writing, 9 October 2026, the list has no entries.

That is not a reason to relax. The Act’s exclusion rules reach beyond the bidder to the companies it relies on.

Excluded and excludable

A supplier is excluded if a mandatory ground applies to it, such as a conviction for certain fraud, bribery or organised crime offences, and the circumstances are continuing or likely to recur. An authority must exclude it. A supplier is excludable on a discretionary ground, such as a serious breach of a previous contract, poor performance, or a threat to national security. An authority may exclude it.

The grounds generally look back five years.

Why your supply chain is in scope

• Associated persons. If you rely on another company to meet the conditions of participation, and that company is excluded or excludable, you can be too. The authority must give you the chance to replace it.
• Subcontractors. In a competitive tendering procedure, the authority must ask whether you intend to subcontract, and must check each intended subcontractor against the debarment list. An excluded subcontractor makes you excluded. You must be given the chance to find an alternative.

For a prime contractor, a weak subcontractor is now a bid risk, not only a delivery risk.

Who runs the list now

The Procurement Review Unit closed on 1 April 2026. Debarment is now handled by the Debarment Review Service in the Government Commercial Agency. National security cases sit with the Cabinet Office’s National Security Unit for Procurement.

The only investigations announced so far concern seven organisations linked to the Grenfell Tower fire, opened in February 2025. They were paused in July 2025 at the request of the prosecuting authorities.

Performance now follows a supplier

Most contracts worth more than £5 million must carry at least three published KPIs, assessed at least once a year. Serious breaches and uncorrected poor performance are published, and can later be grounds for exclusion. A poor record on one public contract can now be read by the next buyer.

What to check before the next bid

• Every company you rely on to meet the conditions of participation, and every intended subcontractor.
• Their exposure to each exclusion ground, including ownership, past contract terminations and national security concerns.
• Your own published record on contracts over £5 million.
• A replacement for any subcontractor that could make you excludable, identified before the bid rather than after.