The Central Debarment Register: What It Means for Suppliers (2026)
The Procurement Act 2023 introduced a central debarment register — a publicly accessible list of suppliers excluded from participating in UK public procurement. This is a genuinely new feature of the UK procurement landscape, with no direct equivalent under the previous Public Contracts Regulations 2015. For suppliers, it creates a risk that did not formally exist before February 2025: a single exclusion decision can now apply across all public procurement, not just a single contract or buyer.
This guide covers how the central debarment register works, what triggers an exclusion, how long exclusions last, and what suppliers can do to protect their position.
What the Central Debarment Register Is
The central debarment register is a list maintained by the Cabinet Office of suppliers who have been excluded from participating in public procurement contracts in the UK. Once a supplier is listed, any contracting authority running a procurement under the Procurement Act 2023 can — and in some cases must — exclude that supplier from their competition without conducting their own separate assessment.
This centralisation is the fundamental change from the previous regime. Under the Public Contracts Regulations 2015, exclusion grounds were assessed independently by each contracting authority for each procurement. A finding by one buyer that a supplier met a mandatory exclusion ground did not automatically affect the supplier’s eligibility with other buyers. The central debarment register changes this — a single listing now has procurement-wide effect across the whole of UK public procurement.
Mandatory and Discretionary Exclusion Grounds
The Procurement Act 2023 retains the distinction between mandatory and discretionary exclusion grounds, carrying forward the broad categories that existed under the PCR 2015 — but with some additions and clarifications.
Mandatory exclusion grounds
Suppliers must be excluded from any procurement where mandatory exclusion grounds apply. These cover criminal convictions of the supplier or connected persons for offences including bribery, corruption, fraud, money laundering, terrorist financing, modern slavery and human trafficking, and certain tax and social security offences. A supplier subject to a binding legal decision on these grounds has no discretion in the matter — exclusion is automatic.
The Procurement Act 2023 expanded the list of mandatory exclusion grounds compared to the PCR 2015. Notably, it added specific grounds relating to the supplier being subject to financial sanctions — reflecting the increased use of sanctions as a policy tool since 2022 — and grounds relating to a wider range of environmental and labour law violations.
Discretionary exclusion grounds
Discretionary exclusion grounds are circumstances where a contracting authority may exclude a supplier but is not required to. These cover a broader range of conduct — including poor past performance on public contracts, significant or persistent deficiencies in a previous contract, misrepresentation in a previous procurement process, and evidence of anti-competitive behaviour. Under the Procurement Act 2023, a supplier’s listing on the central debarment register for a discretionary ground can still trigger exclusion by other buyers — but those buyers must make their own assessment of whether exclusion is proportionate in the context of their specific procurement.
How a Supplier Gets Listed
A supplier can be listed on the central debarment register through two routes.
The first is a debarment decision by a minister — a formal decision by a Cabinet Office minister, following an investigation, that a supplier meets the grounds for exclusion and should be listed. This process involves notice to the supplier, an opportunity to make representations, and a formal decision that is subject to challenge. A ministerial debarment decision can result in exclusion for a defined period of up to five years for most grounds.
The second is automatic listing following a relevant criminal conviction or binding legal decision — where the mandatory exclusion grounds are met by virtue of a court judgment or equivalent, the supplier can be listed without a separate ministerial investigation.
Contracting authorities also retain the power to apply exclusion grounds independently in their own procurements — without the supplier necessarily being on the central register. The register does not limit buyer discretion; it extends the effect of existing decisions to the whole market.
Self-Certification and the Register — What Changes for Suppliers
Most suppliers encounter exclusion grounds through the self-certification process in a Selection Questionnaire — declaring whether any mandatory or discretionary exclusion grounds apply to their organisation or connected persons. This self-certification obligation has not changed under the Procurement Act 2023.
What has changed is the verification layer that sits behind it. Contracting authorities can now check the central debarment register directly — giving them an immediate, reliable indication of whether a supplier has already been assessed as meeting exclusion grounds by another authority or through a ministerial process. This makes inaccurate self-certification significantly more detectable than it was under the previous regime.
The practical implication for suppliers is straightforward: self-certification declarations must be accurate. An inaccurate declaration — particularly a false denial of a mandatory exclusion ground — is itself a ground for exclusion under the misrepresentation provisions of the Act. Our guide to tender compliance covers self-certification requirements in detail.
Connected Persons — A Wider Net Than Many Suppliers Realise
One of the most significant aspects of the debarment provisions — and one of the least understood — is the concept of “connected persons.” Exclusion grounds do not apply only to the supplier’s own conduct. They can also apply based on the conduct of connected persons — directors, shadow directors, persons with significant control, and in some circumstances key subcontractors and members of a consortium.
This means a supplier can potentially face exclusion based on a conviction or finding against an individual director, even where the corporate entity itself has no relevant conviction. Suppliers should understand who their connected persons are, and what exclusion ground implications any relevant convictions or findings relating to those individuals might have, before self-certifying in any procurement.
How Long Does Debarment Last?
For most discretionary grounds, the maximum debarment period following a ministerial decision is five years. For mandatory exclusion grounds arising from criminal convictions, the period is generally linked to the sentence imposed. The Act includes provisions for suppliers to apply for early removal from the register — by demonstrating that they have taken sufficient remedial action to address the conduct that gave rise to the exclusion.
Remedial action — sometimes called “self-cleaning” — is an important route for suppliers who have addressed historic issues. A supplier that has taken genuine, demonstrable steps to correct the conduct underlying an exclusion ground, compensate any harm caused, and implement measures to prevent recurrence can submit evidence of this remediation to the Cabinet Office. Successful remediation can result in removal from the register or a finding that the exclusion ground no longer applies in a specific procurement context.
What Suppliers Should Do Now
For most suppliers, the central debarment register is a background risk that does not require immediate action — it becomes relevant only if exclusion grounds apply. But the register’s existence does change the risk profile of self-certification inaccuracies and makes it worth taking three practical steps.
First, review your self-certification declarations for accuracy — particularly around connected persons. If any director or person with significant control has a relevant conviction or finding that you have not previously disclosed, take advice on whether this constitutes a mandatory or discretionary exclusion ground and what your disclosure obligations are.
Second, establish a process for monitoring whether any connected person’s circumstances change in ways that affect exclusion ground declarations. A director appointed after a previous self-certification may have a relevant conviction that needs to be assessed before the next procurement.
Third, if you believe you may already be subject to a debarment investigation or decision, seek specialist procurement law advice immediately — the timeline for making representations in a ministerial debarment process is defined and limited.
Frequently Asked Questions About the Central Debarment Register
Can I check whether my organisation is on the central debarment register?
Yes — the register is publicly accessible, meaning any supplier can check their own status and any buyer can check a supplier’s status. Checking the register before submitting a self-certification declaration is good practice, particularly where there is any uncertainty about whether a past event might have resulted in a listing.
Does listing on the register mean automatic exclusion from every procurement?
For mandatory exclusion grounds, yes — contracting authorities must exclude a listed supplier. For discretionary grounds, contracting authorities must consider the listing but retain the ability to assess proportionality in the context of their specific procurement. In practice, discretionary listings will result in exclusion in most cases — buyers are unlikely to take the reputational and governance risk of proceeding with a listed supplier without very strong justification.
What is “self-cleaning” and does it work?
Self-cleaning is the formal process of demonstrating that a supplier has taken sufficient remedial action to address the conduct underlying an exclusion ground — compensating harm, cooperating with investigations, implementing preventive measures, and demonstrating genuine organisational change. Under the Procurement Act 2023, self-cleaning can result in a finding that an exclusion ground no longer applies, or in early removal from the register. It requires genuine, documented remediation — not a statement of intent. Specialist procurement law advice is essential for any supplier pursuing this route.
Does the debarment register apply to subcontractors?
Contracting authorities can check the register in relation to proposed subcontractors as well as prime contractors, particularly where the subcontractor will be delivering a significant part of the contract. Key subcontractors may also be connected persons for the purposes of the prime contractor’s own exclusion ground assessment. This makes it important for prime contractors to check their supply chain as well as their own position when self-certifying.
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About the author: Written by Joshua Smith, a seasoned bid-writing expert with experience across the UK, Middle East and US, helping organisations secure the contracts they deserve through high-quality, competitive tender responses.