Turnstiles, Not Doors: How Procurement Frameworks Still Filter Out Britain's Smaller Consultancies

Every few years the machinery of public buying is rebuilt with a promise to widen the field. The Procurement Act 2023, which replaced the 2015 regulations in February 2025, arrived with exactly that billing: simpler, more transparent, more accessible to the small and the new. And yet a fifteen-person consultancy in Leeds or Bristol or Cardiff will tell you the same story it has told for a decade. The doors have been widened. The turnstiles have not.

The barriers that keep smaller advisory firms out of public work are rarely written into primary legislation. They are written into the frameworks: in the minimum requirements, the insurance schedules and the evaluation matrices that sit beneath the glossy social value pledges.

The Rhetoric and the Reality

Public bodies now speak fluently about social value, local economic benefit and supply chain diversity. Procurement teams publish SME action plans. Cabinet Office guidance urges contracting authorities to consider lotting, to accept consortia and to publish pipelines.

All of this is genuine, and some of it works. But there is a persistent gap between the ambition at the top of an organisation and the incentives of the framework manager in the middle. Framework managers are judged on delivery certainty, not on market plurality. When the choice is between a supplier with a decade of comparable references and one with an excellent proposal and modest turnover, the safer answer is rarely the braver one.

Three Filters That Do the Real Work

Turnover thresholds. Frameworks routinely require annual turnover of two to three times the contract value, or an absolute floor of £5 million or £10 million regardless of lot size. A firm turning over £1.4 million cannot bid for a £400,000 lot without a parent company guarantee, a partner or a misrepresentation.

Insurance. Professional indemnity at £5 million or £10 million, public liability at £5 million, employers' liability as required by statute. Each figure is defensible in isolation. Together they add thousands to annual premiums for work that may never generate a claim of that order.

Evidence. Three comparable references of similar scale, Cyber Essentials Plus, sector accreditations, documented policies on a dozen topics. This is a tax on administrative capacity, and administrative capacity is precisely what a small consultancy does not have spare.

None of these filters is unreasonable on its own terms. Cumulatively they form a wall, and the wall has a distinctive shape: it fits the firms that were already inside it.

The Opacity That Completes the Job

Then there is evaluation. A firm that invests forty hours in a bid and is told only that its submission was strong but not strong enough has learned nothing and will bid again, or not. Feedback that neither names the scored criteria nor explains the gap between the winning and losing submissions is not transparency; it is the appearance of it.

Standstill letters and debriefs exist precisely so that suppliers can understand outcomes. Too often they are drafted defensively, by which point the commercial lesson has already been lost.

What Smaller Firms Can Do This Quarter

Read the framework, not the advert. The contract notice is marketing. The tender pack contains the mandatory and discretionary exclusion grounds, the insurance schedule and the scoring model. Ninety minutes with the pack will save forty hours of bid writing.

Use the subcontract route deliberately. Many frameworks place supply chain obligations on primes. Approach the incumbent, name the lot you can serve, and ask what evidence would make you a credible named subcontractor. This is often the fastest route to a first public reference.

Bid in consortium, but paper it properly. Joint bids fail on governance long before they fail on price. Agree the lead bidder, the liability split and the exit terms before the first draft.

Engage before the market opens. Pre-market engagement exercises, prior information notices and published pipelines are invitations. Firms that respond shape specifications; firms that wait respond to them.

Press the debrief. Ask for the scores against each criterion and the moderation record. Most authorities will provide them on request, and the request itself signals a supplier that will not quietly disappear.

Build a reference library now. Three current, quantified case studies with client permission and measurable outcomes are worth more in a tender than any brochure.

Where a firm believes a procurement has breached the rules, the review provisions in the Procurement Act 2023 carry short limitation periods and specific procedural steps. Take specialist legal advice early; the clock is unforgiving.

What Professional Bodies Should Be Advocating

This is where a council of commerce earns its subscription. Individual firms lobbying a framework manager achieve little. A sector body making four specific, evidence-based asks achieves considerably more.

• Proportionate insurance. Limits scaled to contract value and risk, rather than fixed at figures designed for infrastructure programmes.
• Turnover expressed as a multiple, not an absolute. A firm bidding for a lot within its demonstrated capacity should not be barred by a number chosen for administrative convenience.
• Meaningful disclosure at debrief. Scores per criterion and a written explanation of the gap, as standard.
• Lotting by value and geography, with published spend analysis by supplier size band so that stated ambition can be tested against outcome.

The Test That Matters

Public procurement should be judged not by who is invited to bid, but by who wins. Until spend data is published by supplier size and the framework filters are set against the size of the work rather than the size of the organisation, the pledges will remain pledges. Britain's smaller consultancies are not asking for preference. They are asking for a specification they can actually meet.