The Cabinet Office abolished most of its spend controls on 1 April 2026 and rewrote its commercial guidance to say so the same day. It never touched the sibling guidance for technology spending, which still calls central sign-off mandatory above 100,000 pounds.
Estimated reading time: 6 minutes
In short. HM Treasury's Office for Value for Money reform ended most Cabinet Office spend controls from 1 April 2026, raising departments' own delegated authority into the tens or hundreds of millions of pounds. The Cabinet Office rewrote its "Commercial spend controls" guidance that same day, replacing its entire operative text with a one-line notice. Three live pages covering the sibling process, digital and technology spending, including the Technology Code of Practice, the standard used for "all of your technology projects or programmes", were never touched. One of them still states it is "mandatory to assure all non-BAU spend above 100,000 pounds for digital and 1 million pounds for technology through your assurance boards." Three documented mistakes: four stars.
Cabinet Office spend controls have required departments to seek central sign-off before spending on commercial contracts, technology, property and several other categories since well before this decade. On 1 April 2026, most of that stopped. HM Treasury's Office for Value for Money set out the change in a November 2025 report, and the Cabinet Office rewrote its own guidance for commercial spending on the day the reform took effect. The parallel guidance for digital and technology spending, the other half of a process every GOV.UK page describes as a single pair, "commercial and digital and technology", was not rewritten. Some of it has not been touched since before the reform was even announced.
A same-day rewrite, and a page left alone
"Commercial spend controls (version 5)" is one of the two central spend-control policies departments have followed since 2021 [5]. Its own update log records what happened on 1 April 2026: "Updated the details section with a message regarding Cabinet Office spend controls" [5]. The page's entire operative content, thresholds, approval steps, definitions, was replaced with one sentence: "Most Cabinet Office spend controls ceased as a requirement from 1 April 2026 as part of changes to the spending control and accountability framework. The advertising, marketing and communications control remains in place" [5]. The same sentence, verbatim, now opens the Cabinet Office's summary collection page, itself last updated 8 September 2026 [6], and the general "Spend controls framework" guidance, last updated 1 April 2026 [7].
"Digital and technology spend controls (version 5)" is the sibling policy, the one departments are told governs their technology spending. It has not received that sentence, or any equivalent, and its detail has not been touched since 18 February 2025 [2], five weeks before HM Treasury even published the reform report that abolished most of what the page describes as mandatory. The page still states in full: "It is mandatory to assure all non-BAU spend above 100,000 pounds for digital and 1 million pounds for technology through your assurance boards" [2].
A newer edition exists, "Digital and technology spend control (version 6)", last updated 10 October 2025, but it tells departments not to use it: "Use version 5 of the digital and technology spend controls policy until GDS has told you to use this version" [3]. Almost a year after that instruction was last edited, and five months after the reform it never mentions, version 5 remains the live, binding text.
A third page compounds it. "Set up a commercial or digital and technology spend controls pipeline", also last updated 18 February 2025, instructs organisations: "Your organisation must create and maintain pipelines showing future activity to follow the current versions of the commercial and digital and technology spend controls processes" [4]. It links straight through to the unrevised version 5 policy as the "current" one, with no caveat that the commercial half of that same sentence has since been rewritten to say most of the process it describes no longer applies.
The standard every technology project is told to follow
The Technology Code of Practice is not a niche policy. It is the cross-government standard GOV.UK describes as something "you should use... for all of your technology projects or programmes" [1]. Its own spend-controls section is direct: "You must consider all points of the TCoP as part of the Cabinet Office spend control process. If your project or programme needs spend control approval you should contact the GDS Assurance team... for guidance with the approvals process" [1]. The page was last updated 7 July 2025 [1], nearly nine months before the process it names as mandatory mostly stopped being one.
What the reform actually changed
HM Treasury's own report explains why the thresholds on the unrevised pages are now out of step with how departments are meant to operate. Departments' main delegated authority limits, the point below which they do not need Treasury sign-off at all, ran from 15 million pounds at HM Treasury itself up to 1,000 million pounds of capital spending at the Ministry of Defence even under the old system [8] (p.30), and most departments' limits were raised further for 2026-27 [8] (p.8). Against limits in that range, the still-live requirement to route digital spend above 100,000 pounds through a central assurance board is not a rounding error, it is roughly the scale of oversight the reform was designed to remove. The report gives its own example of what that removal looks like in practice: "where HMRC faced up to 40 approval points to deliver its digital and customer programmes... it would now only face two" [8] (p.16).
The claims, tested
| The document's own words | What the record actually shows | Verdict |
|---|---|---|
| Technology Code of Practice: "You must consider all points of the TCoP as part of the Cabinet Office spend control process", last updated 7 July 2025 [1] | The Cabinet Office's own summary page says "Most Cabinet Office spend controls ceased as a requirement from 1 April 2026", updated 8 September 2026 [6] | A standard used for "all" technology projects still names a mandatory process that mostly stopped being mandatory five months earlier, with no caveat |
| Digital and technology spend controls (version 5): "It is mandatory to assure all non-BAU spend above 100,000 pounds for digital and 1 million pounds for technology through your assurance boards", last updated 18 February 2025 [2] | Departments' own delegated authority limits run from 15 million to 1,000 million pounds [8] (p.30); the sibling Commercial spend controls page had its entire operative text replaced with a ceased notice on 1 April 2026, the day the reform took effect [5] | The live policy's mandatory thresholds are orders of magnitude below what the reform now delegates to departments; the equivalent commercial policy was rewritten the same day the change happened, this one was not |
| "Set up a commercial or digital and technology spend controls pipeline": organisations "must create and maintain pipelines... to follow the current versions of the commercial and digital and technology spend controls processes", last updated 18 February 2025 [4] | The "current version" it links to for the commercial half of that sentence has been reduced to a ceased notice; the "current version" it links to for the digital and technology half has not been touched [5] [2] | One sentence, two linked policies, treated as equally current when only one of them still is |
The mistakes, counted
The Technology Code of Practice still names a mostly-abolished process as mandatory (1). TCoP tells every department to "consider all points of the TCoP as part of the Cabinet Office spend control process" and to contact the GDS Assurance team for approvals [1]. It was last updated 7 July 2025, and carries no reference anywhere to the 1 April 2026 reform that ended most of the process it names.
The live Digital and Technology Spend Controls policy still states thresholds the reform has overtaken (2). Version 5, the edition departments are explicitly told to keep using [3], states plainly that assurance-board sign-off is "mandatory" above 100,000 pounds for digital and 1 million pounds for technology spend [2]. Departments' own delegated authority limits, the level below which HM Treasury itself no longer requires sign-off, run from 15 million to 1,000 million pounds [8] (p.30). The page has not been edited since five weeks before the reform report that changed this was even published.
The pipeline-setup guidance treats both halves of the reform as equally current when only one was rewritten (3). "Set up a commercial or digital and technology spend controls pipeline" instructs organisations to follow "the current versions" of both the commercial and the digital and technology processes in the same sentence [4]. The commercial version it links to was rewritten to a ceased notice on 1 April 2026 [5]. The digital and technology version it links to has been unchanged since February 2025 [2].
Credit where due
Where the Cabinet Office did the work, it did it properly. The Commercial spend controls page was not quietly patched; its entire operative section was replaced with a plain statement of what changed and when, dated to the exact day the reform took effect [5]. The same notice was added to the general spend-controls framework page the same day [7], and the summary collection page carries it too, most recently confirmed current as of 8 September 2026 [6]. The reform itself, on HM Treasury's own account, is not a deregulatory gesture without a mechanism: delegated authority limits are specific, published, per-department figures rather than a discretionary judgement call [8] (p.30), and the department's own worked example, HMRC's digital approval points falling from up to 40 to two, is a concrete, checkable claim about what the change is meant to achieve [8] (p.16). The problem is not the reform. It is that the update stopped at the commercial half of a process every one of these pages describes as a single, paired thing.
Verdict
Four stars, from three documented mistakes. HM Treasury's spend-controls reform is a real, specific, mostly well-evidenced change, and the Cabinet Office proved it knows how to communicate it by rewriting the Commercial spend controls page the same day the change took effect. Five months on, the Technology Code of Practice, the live Digital and Technology Spend Controls policy, and the guidance telling organisations to build pipelines for both, still describe the sibling process as if 1 April 2026 never happened. A department reading only the digital and technology guidance today would have no way of knowing, from that guidance, that the mandatory threshold it quotes no longer matches how the rest of government now operates.
Sources
- The Technology Code of Practice, GOV.UK guidance, Government Digital Service, published 14 July 2021, last updated 7 July 2025
- Digital and technology spend controls (version 5), GOV.UK guidance, Cabinet Office, last updated 18 February 2025
- Digital and technology spend control (version 6), GOV.UK publication, Cabinet Office, published 23 February 2024, last updated 10 October 2025
- Set up a commercial or digital and technology spend controls pipeline, GOV.UK guidance, Cabinet Office, published 30 April 2018, last updated 18 February 2025
- Commercial spend controls (version 5), GOV.UK guidance, Cabinet Office, published 26 October 2021, last updated 20 May 2026
- Cabinet Office Controls, GOV.UK collection, Cabinet Office, last updated 8 September 2026
- Spend controls framework, GOV.UK guidance, Cabinet Office, last updated 1 April 2026
- Reforming the spending control and accountability framework, Office for Value for Money / HM Treasury, published 26 November 2025