Welsh Ministers have made the Procurement Act 2023 (Threshold Amounts) (Amendment) (Wales) Regulations 2025. Made on 9 December 2025, laid before the Senedd on 11 December, and commencing at 12.05 a.m. on 1 January 2026, the instrument restructures how Schedule 1 to the Procurement Act 2023 sets out threshold figures for devolved procurements and confirms alignment with the World Trade Organization Government Procurement Agreement (GPA).
Regulation 3 amends paragraph 1 of Schedule 1. The wording before the table is adjusted so that each contract type refers directly to the threshold shown in a single column. The ‘any other contract’ column is removed, the heading of the remaining column is shortened, and sub‑paragraph (1B)-which had defined when a contract is “regulated by the Welsh Ministers” for the purpose of the table-is omitted. The effect is a cleaner presentation of Welsh‑applicable thresholds within the Act’s Schedule.
These edits sit alongside the UK‑wide update in S.I. 2025/1200, which refreshed the sterling values for 2026 and introduced dual columns while expressly excluding contracts regulated by the Welsh Ministers. Wales is now applying the same GPA‑aligned figures for devolved authorities while removing the duplicative column structure for Welsh procurements to keep the Schedule clear for users.
From 1 January 2026 the operative values, inclusive of VAT, are the GPA‑aligned sterling thresholds confirmed for this cycle: £5,193,000 for works (including defence works), £415,440 for utilities contracts that are not works or light touch, £663,540 for light touch contracts, £884,720 for light touch contracts in the utilities regime, £5,372,609 for concession contracts, £135,018 for central government goods and services, and £207,720 for sub‑central goods and services. These are the Cabinet Office’s published figures for the period beginning 1 January 2026 and are the values Welsh authorities should apply.
Regulation 4 sets transitional provisions. Procurements commenced before 1 January 2026 are unaffected. A procurement is treated as commenced if, before that date, the authority has published a tender notice under section 21, a transparency notice under section 44, a below‑threshold tender notice under section 87, or has contacted a supplier to start awarding a below‑threshold contract. This preserves continuity for live procedures.
Scope remains determined by the primary legislation. ‘Contracting authority’ has the meaning in section 2(1) of the Procurement Act 2023 and ‘below‑threshold contract’ in section 5(5). Removing the inserted sub‑paragraph does not change which procurements in Wales are devolved; it simply avoids duplication in Schedule 1 while leaving jurisdictional tests with the Act.
Timing is sequenced against the UK instrument. S.I. 2025/1200 takes effect at 12.00 a.m. on 1 January 2026 for England and reserved authorities, while the Welsh instrument begins at 12.05 a.m. The five‑minute interval ensures the UK text changes land first, after which the Wales‑specific presentation change is applied for devolved procurements.
For procurement teams, the immediate tasks are operational: update templates and pipeline valuations to the 2026 figures from 1 January, ensure estimated values include VAT as required by section 123, and continue under the pre‑existing thresholds for any procurement already commenced before the start date. Welsh Government guidance on thresholds and light touch services remains the reference point for practice details.
The Explanatory Note records that a Regulatory Impact Assessment has been prepared and can be obtained from the Commercial and Procurement Directorate, Welsh Government, Cathays Park, Cardiff. In parallel, Cabinet Office PPN 023: 2026 Threshold Amounts and existing GOV.WALES guidance provide the cross‑UK and Welsh context on how the updated figures should be applied in day‑to‑day procurement.