Regulations and compliance
Public Contracts Regulations 2015(PCR 2015)
Written by Justin Cesman, CEO of Skim. Last reviewed:
- Definition
- The Public Contracts Regulations 2015 (PCR 2015) are the UK statutory instrument (SI 2015/102) that governed public procurement in England, Wales, and Northern Ireland from 26 February 2015. PCR 2015 still applies to procurements commenced before 24 February 2025, when the Procurement Act 2023 took over.
Key takeaways
- PCR 2015 (SI 2015/102) came into force on 26 February 2015 and transposed EU Directive 2014/24/EU into the law of England, Wales, and Northern Ireland; Scotland has its own separate regime.
- PCR 2015 is legacy-but-still-live: it continues to govern any procurement commenced before 24 February 2025, the day the Procurement Act 2023 took effect.
- A competitive procurement is treated as commenced under PCR 2015 when its contract notice was submitted for publication (or a below-threshold opportunity was published) before 24 February 2025.
- Frameworks and dynamic purchasing systems set up under PCR 2015 stay under PCR 2015 for their whole life, including call-offs awarded after 24 February 2025; legacy DPS must terminate by 23 February 2029 at the latest.
- PCR 2015 gives bidders enforceable rights: regulation 18 requires equal treatment, transparency, and proportionality, and regulations 97 to 104 set out the remedies for a breach.
How it works
The Public Contracts Regulations 2015 (PCR 2015), formally SI 2015/102, set the rules most UK public bodies had to follow when awarding contracts for works, supplies, and services from 26 February 2015. They transposed EU Directive 2014/24/EU into domestic law and, after Brexit, were retained as UK legislation. PCR 2015 applies to England, Wales, and Northern Ireland; Scotland runs its own separate procurement regime.
PCR 2015 defines the procedures a buyer may use, the advertising and time-limit requirements, how tenders are evaluated, and the remedies open to suppliers. Regulation 18 sets the core duties: treat all bidders equally, act transparently and proportionately, and do not artificially narrow competition. Above the financial procurement thresholds, full obligations apply; certain health, social, education, legal, and cultural services fall under a lighter set of rules known as the light touch regime, listed in Schedule 3. Where a buyer breaks the rules, regulations 97 to 104 give suppliers remedies that can include setting aside an award decision or damages — and a mandatory standstill period before contract signature gives an unsuccessful bidder the window to challenge.
PCR 2015 is now legacy legislation, but it is far from dead. The Procurement Act 2023 took effect on 24 February 2025 and governs procurements commenced on or after that date. Procurements commenced before it stay under PCR 2015 until they conclude. The transitional and saving rules (SI 2024/716, as amended by SI 2024/959) treat a competitive procurement as commenced when its contract notice was submitted for publication — or a below-threshold opportunity was published — before the boundary date; a direct award commences when the buyer first contacts a supplier intending to contract.
The practical consequence for bidders is that two regimes run in parallel for years. A framework agreement or dynamic purchasing system established under PCR 2015 continues to be governed by PCR 2015 for its entire life, so call-off contracts awarded under it after 24 February 2025 are still old-regime — though legacy dynamic purchasing systems must close by 23 February 2029 at the latest. legislation.gov.uk now titles PCR 2015 as revoked, which reflects its forward-looking repeal, not the loss of the saved rights attached to live legacy procurements.
PCR 2015 vs Procurement Act 2023
| Feature | PCR 2015 (legacy) | Procurement Act 2023 (current) |
|---|---|---|
| Governs procurements | Commenced before 24 Feb 2025 | Commenced on or after 24 Feb 2025 |
| Legal basis | EU Directive 2014/24/EU, retained UK law | Made-in-UK Act of Parliament |
| Award standard | Most economically advantageous tender (MEAT) | Most advantageous tender (MAT) |
| Competitive procedures | Open, restricted, competitive dialogue, competitive procedure with negotiation, others | Open procedure or a single competitive flexible procedure |
| Pre-market supplier filter | Selection questionnaire (SQ) | Procurement-specific questionnaire under conditions of participation |
| Continuous open route | Dynamic purchasing system (DPS) | Dynamic market |
| Standstill period | Minimum 10 calendar days | Minimum 8 working days |
Under the Procurement Act 2023
Reviewed
PCR 2015 is legacy-but-still-live. Which regime applies turns on a single date: the Procurement Act 2023 took effect on 24 February 2025 and governs procurements commenced on or after that day, while PCR 2015 continues to govern procurements commenced before it. The transitional and saving arrangements (SI 2024/716, as amended by SI 2024/959) treat a competitive procurement as commenced when its contract notice was submitted for publication before the boundary date, and a framework agreement or dynamic purchasing system set up under PCR 2015 stays under PCR 2015 for its whole life — so call-offs awarded after 24 February 2025 remain old-regime, with legacy dynamic purchasing systems required to close by 23 February 2029. legislation.gov.uk lists PCR 2015 as revoked, but that reflects its forward-looking repeal, not the rights saved for live legacy procurements.
Sources: Guidance: transitional and saving arrangements (GOV.UK) · The Public Contracts Regulations 2015, SI 2015/102 (legislation.gov.uk) · Procurement Act 2023 (Commencement No. 3 and Transitional and Saving Provisions) Regulations 2024 (legislation.gov.uk)
Why it matters for bidders
Knowing which regime applies is leverage. For any live procurement, the commencement date tells you whether PCR 2015 or the Procurement Act 2023 sets the rules — and therefore which advertising, evaluation, standstill, and remedies obligations a buyer is bound by. Get that wrong and you challenge under the wrong regulations, or miss a breach you could have acted on. The subtler point is duration: a framework agreement or dynamic purchasing system commenced under PCR 2015 keeps generating old-regime call-offs for years, so the legacy rules will shape real opportunities well past 2025. Reading published award and contract notices to spot which buyers are still operating legacy tools — and which procedure governs each one — is the kind of award-data discipline that teams who have won £3bn+ in UK and EU public contracts use to bid on the legal reality, not the assumption.
How Skim helps
Skim's Bid Analysis agent flags when a procurement process deviates from the regulatory requirements that actually apply to it — identifying whether PCR 2015 or the Procurement Act 2023 governs from the notice and timeline, so you can spot where clarification or challenge is appropriate and avoid procurements whose process raises red flags.
Frequently asked questions
- Are the Public Contracts Regulations 2015 still in force?
- PCR 2015 is legacy-but-still-live. legislation.gov.uk lists it as revoked because the Procurement Act 2023 replaced it for new procurements from 24 February 2025, but PCR 2015 continues to govern any procurement commenced before that date until it concludes, so it remains in active use for years.
- When did the Public Contracts Regulations 2015 come into force?
- PCR 2015, statutory instrument SI 2015/102, came into force on 26 February 2015. It transposed EU Directive 2014/24/EU into UK law and replaced the Public Contracts Regulations 2006. It applies to England, Wales, and Northern Ireland; Scotland has its own separate procurement regulations.
- Do PCR 2015 or the Procurement Act 2023 apply to my contract?
- It depends on when the procurement commenced. Procurements commenced before 24 February 2025 stay under PCR 2015; those commenced on or after that date follow the Procurement Act 2023. A competitive procurement is commenced when its contract notice was submitted for publication, so check that date against 24 February 2025.
- What happens to a framework set up under PCR 2015?
- A framework agreement or dynamic purchasing system established under PCR 2015 stays governed by PCR 2015 for its entire life. Call-off contracts awarded under it after 24 February 2025 remain old-regime. Legacy dynamic purchasing systems and qualification systems must terminate by 23 February 2029 at the latest.
- What remedies do PCR 2015 give bidders?
- Regulations 97 to 104 of PCR 2015 set out the remedies for a breach by a contracting authority. Before a contract is signed, a court can set aside an unlawful award decision; after signature, remedies can include damages or, in serious cases, a declaration of ineffectiveness. A mandatory standstill period gives bidders time to act.
- Which countries do the Public Contracts Regulations 2015 cover?
- PCR 2015 applies to public procurement in England, Wales, and Northern Ireland. Scotland is not covered; it operates its own procurement regime under separate Scottish regulations. PCR 2015 sits alongside the Utilities, Concession, and Defence and Security procurement regulations for those specialist sectors.
Sources
Related terms
Procurement Act 2023
The Procurement Act 2023 is the law governing most UK public procurement, in force since 24 February 2025. It replaces the Public Contracts Regulations 2015 and three other regimes with one set of rules, introducing the competitive flexible procedure, a central digital platform, and a published debarment list.
Procurement thresholds
Procurement thresholds are the financial values, set in Schedule 1 of the Procurement Act 2023 and revised every two years, that decide which rules a UK public contract follows. A contract estimated at or above the threshold (including VAT) triggers full regulated procurement; below it, lighter rules apply.
Light touch regime(LTR)
The light touch regime (LTR) is a simplified UK procurement regime for specified social, health, education, and similar services delivered to people. It applies a far higher threshold — £663,540 including VAT — and lets buyers design their own award process instead of following the standard procedures.
Negotiated procedure without prior publication
The negotiated procedure without prior publication is a procurement route under the Public Contracts Regulations 2015 that lets a buyer negotiate directly with one or more suppliers without advertising a contract notice. Permitted only in narrow cases such as extreme urgency, a single capable supplier, or no suitable tenders received.