The government built a national blacklist to keep risky suppliers away from public money. Nineteen months after it opened for business, nobody has ever been on it.
Estimated reading time: 6 minutes
In short. The Procurement Act 2023 created a centralised debarment list so that a supplier found to pose a risk to public funds anywhere in the UK can be barred from every public contract, not just the one it was caught on. Section 62 of the Act gave ministers that power from 24 February 2025. The current, officially approved debarment list, published from the live gov.uk Debarment Review Service page, still shows no supplier on it. Every contracting authority in the country is required to check that empty list before every covered procurement decision. Two documented mistakes: four stars.
Public procurement in the United Kingdom runs to roughly £385 billion a year, and until February 2025 a supplier caught defrauding one council could still legally bid for a contract from the council next door, because exclusion decisions were made procurement by procurement with no shared memory between them [1]. The Procurement Act 2023 was built to fix that with a single national list. Section 62 lets a minister, after an investigation, enter a supplier's name on a "list kept by a Minister of the Crown for the purposes of this section," recording the exclusion ground and whether it is mandatory or discretionary [2]. That power has existed since 24 February 2025 [2] [3]. The list it produces is the Act's own test of whether the power is being used.
The claims, tested
| The claim | What the Act and the department's own documents say | Verdict |
|---|---|---|
| The reformed exclusions framework would be "more focused on suppliers who pose an unacceptable risk to effective competition for contracts, reliable delivery, and protection of the public, the environment, public funds, national security interests or the rights of employees" [1] | The Debarment Review Service (DRS), which now runs the regime, states its "purpose is to protect public procurement from suppliers that pose risk, by carrying out an investigatory process for considering suppliers for entry on a centralised debarment list" [4] | A mechanism exists on paper and has existed for nineteen months |
| The debarment list gives contracting authorities "a central source of information" to support consistent exclusion decisions across the public sector [4] | The current debarment list, "APPROVED (CURRENT)," effective 17 November 2025 and due for review 17 November 2026, contains a header row and no supplier entries: "the debarment regime became effective on 24th February 2025... until a ministerial decision is made to add a supplier following an investigation, the list will remain blank" [5] | The central source of information has never had anything in it |
| The list is a working control, not a formality: contracting authorities "must check the debarment list" before allowing a supplier to bid, at interim stages of a procurement, and before awarding any public contract [6] | Because the list has never had an entry, every one of those mandatory checks, across every public body in the country, since February 2025, has checked a document with nothing on it [5] [6] | A statutory duty that has never once changed an outcome |
| Contracting authorities that exclude a supplier of their own accord "must" still notify the DRS under section 59 of the Act, feeding the central system even when the minister never acts [6] [7] | Individual contracting authorities can, and by their own guidance are told they must, exclude a supplier from a specific procurement using their own risk assessment, regardless of whether that supplier ever reaches the national list [6] | CLEARED: the underlying exclusion power at the point of a single procurement is real and does not depend on the list |
The mistakes, counted
A national blacklist with nobody on it (1). Section 62 of the Act does not describe an aspiration; it is a live power a minister has been able to use since 24 February 2025, following an investigation that finds a supplier "excluded or excludable" [2]. The document that power was supposed to produce is the debarment list itself, and the version in force today, dated 17 November 2025 and marked current until its next review in November 2026, carries the same sentence it presumably carried on day one: the list "will remain blank" until a minister decides otherwise [5]. Nineteen months after the power was granted, no minister ever has. The Procurement Review Unit that used to run the process no longer exists as a separate body, its debarment function folded into the Government Commercial Agency from 1 April 2026 [8], so the machinery has changed hands without ever producing an output for the machinery to hand over.
Every public body in the country is required to check nothing (2). This is not a mechanism suppliers and contracting authorities can quietly ignore. Cabinet Office guidance is explicit that a contracting authority "must check the debarment list" before allowing a supplier to bid, at any interim stage of a multi-stage procurement, and again before awarding the contract [6]. Multiply that by every covered procurement run by every council, NHS trust, police force, government department and other public body in the United Kingdom since February 2025, and the debarment list has been consulted an enormous number of times without a single one of those checks ever being capable of returning a match. A compliance duty that structurally cannot fail is not a safeguard; it is paperwork wearing a safeguard's clothes, and nothing on gov.uk explains why nineteen months of the regime's operation have produced no debarments, no published referral count, and no public account of how many investigations, if any, have been opened and closed without result.
Credit where due
The debarment list is not the only exclusion tool the Act created, and it would be unfair to read this piece as saying the reform has done nothing. Section 59 requires a contracting authority that has excluded, replaced or removed a supplier from a live procurement to notify the DRS regardless of the outcome, and the department's own guidance confirms that a contracting authority "may only exclude" a supplier who is not on the central list "if they are satisfied, based on their own assessment," that the exclusion grounds apply [6] [7]. That power sits with every contracting authority, works case by case, and does not depend on a minister ever adding anyone to the national list. The Act also builds real due process around the list itself: before an entry is made, the affected supplier must be given eight working days' notice and an explanation of its right to seek interim relief, which is a genuine, non-trivial procedural protection rather than a rubber stamp [2]. The centralising ambition has not yet delivered a single centralised outcome. The decentralised, case-by-case exclusion power the Act sits on top of appears to be functioning as designed.
Verdict
Four stars, from two documented mistakes. A reader told that the UK now has a national blacklist for suppliers who put public money at risk could reasonably picture something with names on it. Nineteen months after the power to create that list was switched on, it has none, and the compliance duty built on top of it, checking that list before every public award in the country, has been checking an empty page the entire time. None of this means fraud and poor performance in public contracts have stopped; it means the one national mechanism built to record and share that risk across the public sector has not recorded a single case of it. The case-by-case exclusion power beneath the list is real and appears to work. The list itself is a promise the Act has kept in form and not yet once in substance.
Sources
- GOV.UK / Cabinet Office, "Transforming Public Procurement: government response to consultation", 6 December 2021. https://www.gov.uk/government/consultations/green-paper-transforming-public-procurement/outcome/transforming-public-procurement-government-response-to-consultation
- Procurement Act 2023, section 62 (Debarment list), legislation.gov.uk
- The Procurement Act 2023 (Commencement No. 3 and Transitional and Saving Provisions) Regulations 2024 (S.I. 2024/716), legislation.gov.uk
- GOV.UK / Government Commercial Agency, "Debarment Review Service (DRS)". https://www.gov.uk/guidance/debarment-review-service-drs
- Debarment List, Government Commercial Agency, effective 17 November 2025
- Debarment Review Service - Scope and Remit, Government Commercial Agency
- Procurement Act 2023, section 59 (Notification of exclusion of supplier), legislation.gov.uk
- GOV.UK / Cabinet Office, "[Withdrawn] Procurement Review Unit", withdrawn 1 April 2026. https://www.gov.uk/guidance/procurement-review-unit