united kingdom procurement act 2023 frameworks riba competitions arb cross-border bidding

Architecture tenders in the United Kingdom: how they work and how a European firm bids

TenderDesk · 28 Oct 2026 · 21 min read

The UK rewrote its procurement law in 2025. This guide explains how architects are appointed by UK public clients today: procedures, thresholds, frameworks, RIBA competitions, the title rules for foreign architects, and the practical steps a European practice takes to bid.

The United Kingdom left the EU procurement system at the end of 2020 and replaced it with its own law, the Procurement Act 2023, in force since 24 February 2025. For an architecture or engineering practice from the continent the result is a market that feels familiar in its logic (notices, selection, award, standstill) but different in nearly every detail: one central platform instead of TED, two procedures instead of five, thresholds quoted including VAT, frameworks that carry most of the design work, and a protected title that decides whether your firm may even call itself an architect. This guide walks through all of it, from where a tender appears to what you need in place before you submit.

It covers England, Wales and Northern Ireland under the Act, says where Scotland differs, and ends with the practical checklist for a firm bidding from outside the UK. Thresholds and procedures are those in force in October 2026; both change on fixed cycles, and the sources at the end let you check the current figures.

Key points

The Procurement Act 2023 applies to procurements started on or after 24 February 2025 in England, Wales and Northern Ireland. Older procurements, and call-offs from older frameworks, still run under the Public Contracts Regulations 2015. Devolved Scottish authorities keep their own law.
There are two competitive procedures: the open procedure and the competitive flexible procedure. Architecture appointments and design competitions run under the second, which the authority designs itself.
Thresholds from 1 January 2026, including VAT: £135,018 for central government services, £207,720 for other public bodies, £5,193,000 for works. Smaller contracts above £12,000 (central) or £30,000 (others) must still be advertised.
Everything is published on one platform, Find a Tender, which also holds your supplier registration. A firm cannot be awarded a contract without being registered there and having shared its information with the buyer.
Most architecture work is bought through frameworks (Government Commercial Agency, Pagabo, Scape, Fusion21, LHC, NHS SBS) and dynamic markets; getting onto them is a separate campaign from winning projects.
RIBA runs the UK's design competitions in four formats; public clients must open the selection stage to all suitably qualified entrants, including firms abroad.
Using the title "architect" in the UK requires registration with the Architects Registration Board. EU qualifications listed in the frozen 2020 annex are still recognised, by application, with no nationality requirement.
A European firm can bid without a UK company, a UK office or a UK bank account. EU firms are treaty-state suppliers under the UK–EU Trade and Cooperation Agreement and must be treated like UK suppliers.
Contracts over £5 million a year with central government need a published Carbon Reduction Plan; central government also scores social value at a minimum of 10 percent.
After award there is a standstill of eight working days and every assessed bidder receives an assessment summary with its scores and the winner's.

What changed in 2025 and what did not

Until 2020 the UK applied the EU directives through the Public Contracts Regulations 2015 and published above-threshold notices in TED. From 1 January 2021 notices moved to a national service, Find a Tender, and from 24 February 2025 the Procurement Act 2023 replaced the regulations for new procurements in England, Wales and Northern Ireland.

The transition matters in practice because many design frameworks were set up under the old regulations and keep running under them until they expire. A procurement is "commenced" under the old rules if its contract notice was submitted before the Act's start, and it stays under those rules for the life of the resulting contract, extensions included; for a framework, until the last call-off ends. So a call-off from a 2023 framework in 2026 is still a 2015-regulation procedure, with its restricted procedure, its selection questionnaire and its ten-day standstill. A new tender notice published in 2026 is an Act procedure. The notice itself tells you which regime applies; the Act's notices carry "UK" numbers (UK1 pipeline, UK4 tender, UK6 award, UK7 contract details).

Two institutional changes in April 2026 affect the names you will read. The Crown Commercial Service became the Government Commercial Agency, and the Procurement Review Unit was dissolved: supplier complaints about a specific procurement still go to the Public Procurement Review Service in the Cabinet Office, while the Debarment Review Service moved to the new agency.

The two procedures

The Act keeps the open procedure, a single stage in which any supplier may submit a tender, and folds every other EU procedure into the competitive flexible procedure. Under the flexible procedure the authority designs the process it considers appropriate: it can run several stages, limit the number of participants after a selection stage, negotiate, hold dialogue, ask for presentations, site visits or design proposals, and refine the award criteria between stages, provided the tender notice said it might. Guidance suggests inviting at least five suppliers to a straightforward process and at least three where there is extensive dialogue.

Architecture appointments almost always use the flexible procedure, and so do design competitions: the Cabinet Office's own training names "design competitions or contests for town and country planning, architecture, engineering" as a textbook use of it, with intermediate assessments narrowing the field. There is no separate design-contest procedure in the Act; the competition is simply a flexible procedure whose stages include anonymous or named design proposals.

A real example shows the shape. In 2025 the Bank of England appointed an architect for the refurbishment of its Threadneedle Street building through a three-stage flexible procedure: initial tenders with conditions of participation, negotiation with five shortlisted firms, then best and final offers. The published weightings were price 30 percent, project approach and team 28 percent, design ethos 24 percent and design delivery 18 percent. Twenty-four firms tendered, five were assessed in the final stage, the award notice opened an eight-working-day standstill, and the contract details notice later showed a fee of £6.28 million and three key performance indicators tied to RIBA stages. From pipeline notice to signature took eight months.

Direct awards without competition are allowed only on listed grounds (a single capable supplier, extreme and unavoidable urgency, additional works where a change of supplier would cause disproportionate technical difficulty, and a few others), and a transparency notice must be published before the award is made.

Thresholds and small contracts

The UK revises its thresholds every two years in line with the WTO Government Procurement Agreement. For procurements started between 1 January 2026 and 31 December 2027 the figures are £135,018 for goods and services bought by central government, £207,720 for goods and services bought by other public bodies (councils, universities, NHS trusts, housing associations), £5,193,000 for works and the same for concessions, and £663,540 for light-touch services. All UK thresholds include VAT, which is the first trap for a continental firm used to net figures: a £180,000 design fee plus 20 percent VAT is a £216,000 contract and sits above the sub-central threshold.

Architecture is not a light-touch service. The light-touch list covers health, social, education, hospitality, legal and similar services; design services follow the full regime, with its minimum tendering periods and its mandatory standstill.

Below the thresholds the Act still requires publicity. A "notifiable below-threshold contract" is one worth more than £12,000 including VAT for central government (NHS trusts count as central government here) or more than £30,000 for everyone else. The authority must publish a below-threshold tender notice on Find a Tender before advertising anywhere else, unless it seeks quotes only from a closed group it has pre-selected, and must publish a contract details notice afterwards even for a single-quote award. It may not run a separate suitability stage for these small contracts; your legal, financial and technical standing can be assessed only as part of the award. For a small practice this is where many first UK commissions are: feasibility studies, condition surveys, small extensions and masterplanning briefs for parish and town councils.

Where tenders are published

Find a Tender is the central digital platform. Every notice under the Act appears there, from pipeline notices to contract details, including below-threshold notices, and searching and setting alerts is free. The data is also published in the Open Contracting Data Standard through a public API, which is how TenderDesk reads it four times a day.

The platform is also where you register as a supplier. Registration runs through GOV.UK One Login; you register the organisation (a Companies House number is not required, and a non-UK address is accepted), complete six sections (basic information, connected persons, qualifications, trade assurances, exclusions, financial information), and generate a share code that you hand to each buyer. The buyer must confirm before the tendering period ends that you are registered and have shared your information; without that, your tender cannot be assessed. Registration is free, needs your last two years of accounts and the names, dates of birth and nationalities of the people who own or control the firm, and takes an afternoon. Do it before you find the first tender you want, because a new share code is needed every time the information changes.

Contracts Finder, the older service for small contracts in England, is still online but has been superseded: below-threshold notices now go to Find a Tender. The devolved nations keep their own portals. Public Contracts Scotland carries every regulated Scottish procurement (goods and services over £50,000 excluding VAT, works over £2 million) and a Quick Quote tool for smaller invited quotes. Sell2Wales feeds the central platform and republishes after it. eTendersNI does the same for Northern Ireland departments, agencies and councils. A Welsh or Northern Irish supplier profile must be linked to the central platform identifier to keep tendering.

Design competitions that are not public procurements, typically for universities, trusts, charities and private developers, appear on the RIBA Competitions listing and nowhere else. TenderDesk reads that listing every morning alongside Find a Tender.

How architects are actually appointed

Frameworks

Most UK public design work is bought through frameworks: multi-year agreements with a list of pre-selected consultants, from which an authority calls off a project by mini-competition or, where the framework sets an objective mechanism, by direct award. Under the Act a framework lasts at most four years unless the notice justifies longer; an "open framework" must reopen to new suppliers at least once in its first three years and every five years thereafter, and may run for eight. Supplier fees are limited to a fixed percentage of call-off value; access fees are gone. There is no mandatory standstill or assessment summary on a call-off, so a lost mini-competition tells you less than a lost open tender.

The frameworks that matter for architects in 2026 are the Government Commercial Agency's Construction Professional Services 2 (RM6356, April 2026 to April 2030, Lot 2 Architectural Services with 27 suppliers, open to every UK public body), Pagabo's Professional Services framework (23 lots, 116 providers, to April 2028), Scape's Professional Services and Development framework (about £3 billion, three delivery partners, from January 2027), Fusion21's Construction Consultancy Services framework (Lot 4 Architecture with a £3 million turnover floor, Lot 15 Building Safety Act Principal Designer), LHC's Consultancy Services and multidisciplinary frameworks, and the NHS Shared Business Services construction consultancy framework whose Lot 7 is Architectural Services and whose invitation to tender is due in early 2027.

Getting onto a framework is a tender in its own right, usually two-stage, with turnover floors, insurance levels, case studies and method statements. It is a campaign to plan a year ahead, not something to do when a project appears. The reward is access to several years of call-offs that never reach the open market.

Dynamic markets

Dynamic markets replace the old dynamic purchasing systems. They must stay open to new members at any time, have no cap on membership, and award only through the flexible procedure. For a foreign firm they are the easier door: you can join when you are ready rather than waiting for a framework to reopen.

RIBA competitions

The Royal Institute of British Architects runs the UK's design competitions on behalf of clients, in four formats. An Open Design competition is anonymous, usually two-stage, with prize money or equal honoraria for the second stage. An Open Ideas competition carries no commitment to commission. An Invited Design competition selects a shortlist on track record and asks the shortlisted teams for proposals. A Competitive Interview appoints the team before detailed design, on the strength of approach and chemistry, with a small payment to the shortlisted firms.

RIBA's guidance states that public bodies must open the selection stage to all suitably qualified entrants, that each brief says whether entry is UK, European or worldwide, that the evaluation panel must include at least one architect, that fee proposals should carry no more than 30 percent of the marks, and that unsuccessful entrants may request feedback. Selection questionnaires can set turnover and professional indemnity minimums, and when the client is a public body the minimum timescales of the Act apply on top.

Prequalification and standard forms

For works, the public sector has moved from PAS 91 to the Common Assessment Standard, run by recognised assessment bodies such as Constructionline, Achilles, CHAS and others; version 6 arrives in November 2026 and includes a building-safety section. For pure design services most clients still write their own procurement-specific questionnaire, but a Constructionline Gold or Platinum registration is a cheap signal that saves questions.

The RIBA Plan of Work 2020 is the vocabulary of every brief: Stage 0 strategic definition, 1 preparation and briefing, 2 concept design, 3 spatial coordination, 4 technical design, 5 manufacturing and construction, 6 handover, 7 use. Fees, deliverables and key performance indicators are expressed in these stages, and a team is expected to be appointed before Stage 2. The usual appointment forms are the RIBA Standard Professional Services Contract (2020, amended 2024 for the Building Safety Act) and the NEC4 Professional Service Contract, which the Construction Playbook favours for central government.

The Building Safety Act 2022 added a duty that now appears in appointments: on any project with more than one contractor the client must appoint in writing a principal designer under the building regulations, competent to plan, manage, monitor and coordinate the design so that the building complies. Frameworks have dedicated principal-designer lots, and an architect bidding as lead designer should expect to be asked to demonstrate that competence or to name who holds it.

Central government departments, agencies and public bodies must give social value a minimum of 10 percent of the total score, drawn from the Social Value Model menu (jobs, skills, wellbeing, environment, equal opportunity). Other authorities may follow suit and many councils do, often at 10 to 20 percent. For contracts worth more than £5 million a year including VAT, central government requires a Carbon Reduction Plan as a condition of participation: board-approved, published on the supplier's website, committing to net zero by 2050, covering Scope 1 and 2 emissions and the Scope 3 categories for purchased goods, waste, travel and commuting, updated annually. A continental firm that already reports under the Corporate Sustainability Reporting Directive has the data; it needs to be presented in the UK template.

Eligibility: what a foreign firm needs

The title "architect"

Using the word "architect" in business in the UK without being on the Architects Register is a criminal offence under the Architects Act 1997. A company may use "architects" in its name only if a registered architect controls and manages all of its architectural work and the Architects Registration Board has given permission, which Companies House checks. This is the single most important rule for a European practice: you can bid, win and deliver without a UK registration, but you cannot describe yourself as an architect while doing it.

Since Brexit, EU qualifications are no longer automatically recognised, but the board still recognises, by individual application, the qualifications listed in the EU directive's annex as it stood at the end of 2020. The applicant must have met any home-country access requirement (the Italian state examination, the French HMONP, and so on), there is no nationality requirement, and the documents are the degree, diploma supplement, access certificate and a statement from the home competent authority less than twelve months old. Qualifications awarded after 2020 and not on that frozen list are not covered and go through the prescribed examination route. Mutual recognition agreements exist with the United States, Australia, New Zealand and Canada, and a UK–EU agreement has been recommended jointly by the board and the Architects' Council of Europe but is not yet in force. The board reports that about one registrant in ten is based outside the UK.

The practical arrangement most European firms adopt is that one or two partners register individually with the board, which allows the firm to use the title and to sign as architect, while the UK project team is supported by a local executive architect for the statutory stages.

Bidding as a non-UK firm

The Act defines treaty-state suppliers: firms entitled to the benefit of an international agreement listed in its Schedule 9, which includes the WTO Government Procurement Agreement and the UK–EU Trade and Cooperation Agreement. A treaty-state supplier must not be treated less favourably than a UK supplier and has the same remedies. An EU, Swiss, Norwegian, Japanese or Canadian practice therefore bids on equal terms. Suppliers from countries without such an agreement may be disregarded, and a 2026 court decision confirmed that they cannot bring proceedings under the Act.

No UK company is needed. An overseas company must register with Companies House only if it establishes a place of business in the UK; bidding and delivering a project from abroad is not that. The central platform accepts a non-UK address and issues an identifier to organisations without a Companies House number. A UK bank account is not required; fees are quoted and paid in sterling, so agree who carries the exchange risk. Insurance is checked by level and by the wording of the policy rather than by the insurer's country: public clients typically ask for professional indemnity of £5 million to £10 million per claim, and will not negotiate down, so ask your insurer for a UK-territory endorsement and a certificate in English before you bid.

VAT follows the land. Drawing up plans for a building on a specific site is a land-related service taxed where the land is, so design fees for a UK building are subject to UK VAT. When the client is VAT-registered, as nearly every public body is, the client accounts for it under the reverse charge and you invoice without VAT and without registering. When a client is not VAT-registered, a non-established supplier has no registration threshold and must register from the first pound. Check this with your accountant per contract; the Act's VAT-inclusive thresholds and the 20 percent rate mean the sums are material.

Submissions are in English, including the drawings. A "UK experience required" condition of participation is not unusual in briefs, but conditions must be a proportionate means of testing capacity or ability, and the Act's equal-treatment objective together with the treaty-state rules give an EU firm grounds to ask for "comparable experience" instead, before the deadline and in writing. Comparable climate, comparable regulatory complexity and comparable building type carry the argument; a UK-registered partner or an executive architect in the team settles it.

Timelines and the rules after you submit

The minimum tendering period is 25 days when submission is electronic and all documents are available with the notice, 30 days if some documents follow, and 10 days where the authority published a qualifying planned procurement notice 40 days to a year earlier or in a state of urgency. The participation stage of a flexible procedure normally allows at least 25 days. In practice an architecture tender gives five to six weeks for the first stage and a further four to eight for the second.

After the final assessment every bidder assessed at the last stage receives, at the same time and before the award notice, an assessment summary: the award criteria with their weightings, the bidder's own scores and reasons, and the same for the most advantageous tender, redacted only where commercially sensitive. The contract award notice then starts a standstill of eight working days, counted from the day of publication as day one, so the contract can be signed from working day nine; a legal challenge issued and notified during standstill suspends the award automatically. Framework call-offs, dynamic-market awards and light-touch contracts have no mandatory standstill.

The Act awards to the most advantageous tender, a change of label from the EU's most economically advantageous tender that the government describes as a clarification. Criteria must relate to the subject matter and be clear, measurable and proportionate; weightings must be in the tender notice; abnormally low tenders must be questioned. Contracts above £5 million need at least three published key performance indicators assessed at least yearly, with the results published. Invoices that are valid and undisputed must be paid within 30 days, and that term flows down to subconsultants.

Complaints about a particular procurement go first to the authority during standstill, then to the Public Procurement Review Service, whose recommendations are not binding, and ultimately to the court. Debarment, the UK equivalent of exclusion from all public contracts for up to five years, is run by the Debarment Review Service; the published list was empty when this guide was written.

Scotland, in short

Devolved Scottish authorities (the Scottish Government, councils, NHS Scotland, Scottish universities) are outside the Act and keep the Public Contracts (Scotland) Regulations 2015, which still look like the EU directives: open and restricted procedures, the ESPD, Public Contracts Scotland as the portal and PCS-Tender as the submission system. Scottish thresholds from 1 January 2026 match the UK figures and include VAT. Below the EU-derived thresholds, the Procurement Reform (Scotland) Act 2014 regulates contracts above £50,000 for services and £2 million for works, with community-benefit requirements; a consultation on raising those figures closed in early 2026 without a decision yet. Since December 2025 a Scottish authority buying through a UK framework or dynamic market follows the UK rules for that purchase.

A six-week preparation plan for a European practice

Week one: register the firm on Find a Tender, complete the six sections and generate a share code; set alerts for CPV 71200000 and 71300000 and for the councils, universities and NHS trusts in the regions you can serve. Week two: decide who in the partnership registers with the Architects Registration Board and start the EU-qualification application; ask your insurer for a UK endorsement and an English certificate at £5 million and at £10 million. Week three: rewrite three case studies in the RIBA Plan of Work vocabulary, in English, with sterling construction values, and prepare a social-value statement using the Social Value Model themes. Week four: identify one framework or dynamic market relevant to your sector and read its last award notice to learn the turnover and insurance floors. Week five: find a UK executive architect or principal designer willing to team on a first bid and agree the split of stages. Week six: bid for one below-threshold study with a council to earn a UK reference.

Checklist

Supplier registration on Find a Tender complete, share code generated, accounts for two years uploaded
Partners' Architects Registration Board applications filed, or a registered executive architect named for the team
Professional indemnity certificate in English, UK territory, at the level the brief asks (usually £5m to £10m)
Case studies in RIBA Plan of Work stages, sterling values, English drawings
Social-value statement against the Social Value Model themes; Carbon Reduction Plan if any contract may exceed £5m a year
Building Safety Act principal-designer competence demonstrated or subcontracted
VAT treatment per contract agreed with your accountant (reverse charge vs registration)
Framework and dynamic-market calendar for the next twelve months
Clarification questions on any "UK experience" condition sent before the deadline
Standstill dates and assessment-summary rights noted for every bid

Frequently asked questions

Can a French, German or Portuguese practice bid for UK public architecture work without a UK company?

Yes. EU firms are treaty-state suppliers under the UK–EU Trade and Cooperation Agreement and must be treated like UK suppliers. No UK company, office or bank account is required; the central platform accepts a non-UK address. You cannot use the title "architect" in the UK without Architects Registration Board registration, so a partner usually registers individually or a registered executive architect joins the team.

Are UK thresholds net or gross of VAT?

Gross. Every UK threshold, including the £12,000 and £30,000 small-contract limits and the £5 million Carbon Reduction Plan line, includes VAT. A €150,000 net design fee is about £130,000 net and £156,000 with VAT, which is above the central government threshold of £135,018.

Where do UK architecture tenders appear now that the UK is not in TED?

On Find a Tender, the central digital platform, for everything from pipeline notices to small below-threshold contracts in England, Wales and Northern Ireland; on Public Contracts Scotland for Scotland; on Sell2Wales and eTendersNI as mirrors; and on the RIBA Competitions listing for competitions run for private and charitable clients. TenderDesk aggregates all of them.

Is there a design-contest procedure in the Procurement Act 2023?

Not as a separate procedure. Design competitions run as competitive flexible procedures whose stages include design proposals, and the Cabinet Office names them as a textbook use of that procedure. RIBA Competitions manages most of them on the client's behalf.

How long is the standstill and what do I receive if I lose?

Eight working days from the day the contract award notice is published, counting that day as day one. Before the notice, every bidder assessed at the final stage receives an assessment summary with its own scores and reasons and the winner's scores. Framework call-offs have no standstill and no summary.

Do I need to be on a framework to win work in the UK?

No, but most public design work is called off from frameworks and dynamic markets, so a firm that only answers open tender notices sees a fraction of the market. Dynamic markets stay open to new members at any time and are the easier first step for a foreign firm.