For public sector organisations, procurement compliance has always been a balancing act between cost, efficiency and accountability. However, the rules have changed with the arrival of the Building Safety Act (BSA) 2022 and the introduction of PPN 03/24.
Today, procurement in public sector projects, particularly construction, demands stricter pre-qualification, contractor verification and full traceability of safety and compliance records. Failure to comply can expose organisations to legal, financial and reputational risks.
This guide breaks down what these new requirements mean for public sector procurement, how they interact with the BSA, and the practical steps you can take to remain compliant.
For tailored support on aligning your procurement processes with new legislation, download the Veriforce CHAS Building Safety Act Compliance Guide.
Why Public Sector Procurement Is Under Pressure
The Public Procurement Act 2023 already reshaped how public bodies source suppliers, consolidating previous frameworks and creating a more transparent and efficient system. In addition, the Building Safety Act 2022 places new duties on clients, including public sector bodies, to verify competence and compliance throughout the supply chain.
PPN 03/24 ties these two worlds together by advising the use of the Common Assessment Standard (CAS) for supplier pre-qualification on construction projects over £5.337 million.
One of the most significant shifts under the BSA is the introduction of personal accountability. Senior officers and duty holders within public sector bodies can now be held directly responsible for compliance failures.
For procurement leaders, this means compliance cannot be delegated or assumed; it must be evidenced, audited and demonstrable.
Related Reading: What Are The Key Updates To The Building Safety Act?
What Is PPN 03/24?
Procurement Policy Note (PPN) 03/24 was published in 2024 by the Cabinet Office. It instructs central government departments, executive agencies, and other public sector organisations to adopt the Common Assessment Standards as part of their supplier selection processes for higher-value construction projects.
Key Requirements Of PPN 03/24:
- Use of CAS and the Standard Selection Questionnaire for pre-qualifying suppliers.
- Alignment of procurement processes with Building Safety Act duties.
- A consistent, industry-wide approach to assessing contractor competence.
This removes the scope for bespoke, inconsistent pre-qualification questionnaires and replaces them with a standardised, auditable framework.
Related Reading: Sourcing Suppliers: Advantages Of Pre-qualification Tendering
Public Sector Procurement And The Building Safety Act
The Building Safety Act applies to all clients commissioning construction projects, including public sector bodies. Its scope is broad, covering new builds and refurbishments, maintenance and demolitions.
What It Means For Procurement In Public Sector Organisations
Public sector procurement teams must now adapt to the stricter compliance environment shaped by the Building Safety Act. Beyond awarding contracts, they are directly responsible for ensuring that safety, competence, and accountability are embedded throughout every stage of a project.
1. Duty Holder Responsibilities
Public sector clients commissioning work are considered ‘duty holders’ under the BSA, with direct responsibilities for safety compliance.
2. Contractor Competence Verification
Every contractor involved must be able to demonstrate SKET (Skills, Knowledge, Experience and Training) to meet the Act’s competence requirements.
3. Golden Thread Of Information
Accurate, traceable, and digital safety records must be maintained throughout the project’s lifecycle. Procurement teams must ensure contractors can meet these data requirements.
4. Accountability For Higher-Risk Buildings (HRBs)
Projects involving HRBs (buildings over 18m in height, 7+ storeys, and with at least 2 residential units) carry particularly strict oversight duties.
These responsibilities mean that public sector procurement must evolve from a cost-comparison exercise into a robust compliance management function.
Learn More About The Common Assessment Standard
The Common Assessment Standard is the highest recognised compliance accreditation in construction, facilities, housing, social care and education.
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Why The Common Assessment Standard Is Central
The Common Assessment Standard was developed by Build UK and CECA to create a single, consistent framework for contractor pre-qualification. Under PPN 03/24, it becomes strongly recommended for public sector projects.
Benefits For Public Sector Procurement:
- Standardisation: All suppliers are assessed against the same criteria.
- Efficiency: Reduces duplication and administrative overhead.
- Transparency: Provides clear, auditable evidence of contractor competence.
- Safety Alignment: Incorporates mandatory Building Safety Act requirements.
For public sector businesses, the CAS is now the foundation of compliant procurement.
5 Common Pitfalls Public Sector Procurement Teams Face
Even with PPN 03/24 and CAS in place, there are still many challenges that public sector procurement teams face:
1. Overlooking Contractor Competence Beyond Paperwork
Treating CAS certification as the final word on competence is tempting, but compliance doesn’t end at pre-qualification. Contractors must be continuously monitored to ensure they retain the Skills, Knowledge, Experience and Training (SKET) necessary for safe delivery. Ongoing audits, site inspections, and refresher checks are essential to avoid blind spots.
2. Failing To Maintain The Golden Thread
The Golden Thread requires a clear, accurate, and digital record of safety-critical information throughout a project’s lifecycle. Procurement teams that focus only on documentation at the contract award stage risk creating gaps later on. Without strong data capture, handover, and verification processes, organisations may struggle to demonstrate compliance during inspections or investigations.
3. Underestimating Accountability Risks
The Building Safety Act introduces personal liability for duty holders, meaning non-compliance can result in unlimited fines or even imprisonment. Procurement leaders who treat compliance as a box-ticking exercise may overlook the seriousness of these risks. Every procurement decision now carries both corporate and personal implications.
4. Not Updating Procurement Workflows
Many public sector bodies still rely on outdated pre-qualification processes developed before the introduction of CAS and PPN 03/24. These legacy workflows often duplicate checks, omit new compliance requirements, or lack proper integration with the Golden Thread. Without updating procurement systems, organisations risk inefficiency and non-compliance.
5. Insufficient Supply Chain Oversight
Compliance is not limited to Tier 1 contractors; subcontractors and specialists working deeper in the supply chain must also meet BSA and CAS standards. Procurement teams that stop at verifying their direct suppliers may overlook significant risks further down the chain. Extending oversight and accountability throughout all supply chain tiers is essential for full compliance.
Related Reading: How To Know If Your Supply Chain Is Sustainable
How Veriforce CHAS Supports Public Sector Procurement
Veriforce CHAS was the first recognised assessment body to deliver the Common Assessment Standard, and today remains one of the UK’s largest and most trusted providers.
Why Public Sector Clients Choose Veriforce CHAS
- Proven Compliance Expertise: 30+ years in contractor assessment and supply chain assurance.
- Trusted by 2,500+ Clients, including major public sector organisations.
- 32,000+ Verified Contractors: a ready-made pool of compliant suppliers.
- One Secure Portal: simplifies contractor monitoring and reporting.
- Annual Certification: ensures ongoing compliance, not just point-in-time checks.
With Veriforce CHAS, procurement leaders can move from uncertainty to confidence, knowing their supply chains are legally compliant and operationally reliable.
For public sector organisations, compliance under the Building Safety Act and PPN 03/24 is non-negotiable. Procurement teams must embrace the Common Assessment Standard, maintain the Golden Thread, and verify competence across the supply chain.
However, with so many moving parts, achieving compliance can feel overwhelming. That’s where Veriforce CHAS provides clarity, structure, and assurance, helping public sector bodies stay on the right side of the law while building safer, stronger supply chains.
Download the Veriforce CHAS Compliance Guide to learn more about aligning your procurement processes with new legislation.
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Updated 7th November 2025
