PPN 025 (PA 2023)

PPN 025: Protecting the UK’s national security through public procurement

In: Define > Sourcing strategy

Overview

This PPN applies only to central government departments, their executive agencies and non-departmental public bodies. Such bodies are referred to as “in-scope organisations”.

Private utilities should strongly consider applying this PPN and accompanying guidance in relevant procurements in energy infrastructure, and engage with the Sector Lead on their proposed approach to relevant procurements.

Other organisations that are contracting authorities under the Procurement Act 2023 can consider their own pipelines in the context of the guidance. Where procurements are high value, complex or related to national interests, they are also encouraged to engage the Sector Leads.

The government’s National Security Strategy 2025 is clear that we are entering a new era of radical uncertainty and that a major cultural shift is needed for the UK to respond effectively. To ensure public procurement plays its part, the government is taking action to recalibrate its approach so that the UK’s huge purchasing power is more effectively deployed to protect our national security.

In this PPN, the government has commissioned action in four critical sectors and identified organisations to act as Sector Leads for each:

  • shipbuilding - National Shipbuilding Office, Ministry of Defence
  • steel - Department for Business and Trade
  • artificial intelligence - Department for Science, Innovation and Technology
  • energy infrastructure - Department of Energy Security and Net Zero

Objective at this commercial stage

Deploy the national security exemption in the Procurement Act 2023 where appropriate and justified in a relevant procurement.

Key considerations at this commercial stage

In-scope organisations should:

  • identify national security risks and impacts and build an evidence base
  • confirm whether the procurement is a ‘covered procurement’ in accordance with Schedule 1 threshold or potentially subject to exemptions under the Procurement Act 2023
  • develop the commercial strategy for the specific procurement based on options analysis and national security risks identified
  • determine if use of national security exemption is supported by secure evidence and a robust justification
  • assess the risk profile
  • determine if the procurement is covered by any trade agreements and, if so, whether use of national security exemption falls within identified exceptions to those trade agreements, supported by secure evidence and a robust justification
  • consider legal advice and approach to launching any procurement

Additional support and guidance