Someone on UK Business Forums asked the question that stops more small firms bidding than any amount of paperwork: do I have to show a public sector buyer my accounts, and what will they do with them once they have them?
Short answer: yes, and less than you fear. The longer answer is worth your time, because the rule everyone repeats about turnover is true in some places and not in others, and almost nobody tells you which is which.
Where your accounts go now
For procurements under the Procurement Act 2023, supplier information is registered once on the Central Digital Platform and reused across bids on Find a Tender, rather than being retyped into every portal. The registration covers the ordinary identifying material, company number, VAT number, connected persons, whether you are an SME, plus your economic and financial standing information for your two most recent financial years. If your accounts had to be audited, that means the audited accounts. If they did not, which covers most small companies, the regulations ask for accounts or other equivalent information, so far as it can reasonably be given. If you have only one year of trading behind you, it is that year alone (checked 20 August 2026).
They are not put on a public register. Supplier information is shared with the contracting authorities you choose to share it with. What varies, wildly, is the test each individual buyer then applies to it.
The “twice your turnover” rule: it depends which regime you are in
Bid consultancies repeat, usually without a source, that a buyer cannot demand annual turnover of more than twice the contract value. It has the feel of law because in several places it still is.
Regulation 58(9) of the Public Contracts Regulations 2015 capped the minimum yearly turnover a buyer could require at twice the estimated contract value, except in duly justified cases, where the authority had to state its main reasons (checked 20 August 2026). That cap has not gone away everywhere:
- In Scotland it is live law today for devolved Scottish buyers, in regulation 59
of the Public Contracts (Scotland) Regulations 2015. The Procurement Act 2023 does not reach them: section 2(5)(a) makes a devolved Scottish authority an excluded authority. The only exception is section 115A, which pulls them back in when they buy through a cross-border or reserved arrangement (checked 20 August 2026).
- In England, Wales and Northern Ireland, PCR 2015 is saved where the procurement
had already reached a defined point before 24 February 2025, most commonly a contract notice submitted for publication, and for call-offs from frameworks concluded and dynamic purchasing systems established before that date. Given how long frameworks run, that covers a lot of what is on the market right now, though the saved dynamic purchasing systems die at the end of 23 February 2029 (checked 20 August 2026).
The Procurement Act 2023 carries no numeric equivalent. We searched the full text of the Act and of the Procurement Regulations 2024 on legislation.gov.uk on 20 August 2026 for “twice”, “not exceed twice” and “minimum yearly turnover”. There are none. Its provision on conditions of participation is section 22, and what that requires is proportionality rather than a ceiling: a buyer may set conditions only where it is satisfied they are a proportionate means of ensuring that suppliers have the legal and financial capacity to perform the contract, or the technical ability to perform it (section 22(1)). A separate subsection, section 22(5), tells the buyer what proportionate means: when it judges proportionality it must have regard to the nature, complexity and cost of the contract (checked 20 August 2026).
So the first question is not “is this allowed”, it is “which regime is this notice under”. On a new Procurement Act procurement in England, the argument against an outsized turnover requirement is that it is not proportionate to the nature, complexity and cost of this contract. That is a real argument, and a better one on a small contract than a large one, but it is an argument rather than a ruler. On a Scottish devolved tender, or an old-framework call-off, you can still point at a regulation.
What buyers are actually setting
Whatever the ceiling is, the tests are all over the place. Real examples from Find a Tender:
- Cornwall Council’s Enterprise Service Management contract, at an estimated
£180,000 a year against £935,000 over its five-year core period, required minimum annual turnover of £360,000, which is two times the annual value and 38.5% of that core budget (notice 2025/S 000-057925, 18 September 2025, checked 20 August 2026). The notice’s headline total of £1,910,000 assumes both extension options are taken. It also applied a liquidity test, with a minimum acid test ratio of 1.0.
- West Midlands Combined Authority’s supply chain transition contract, with a
total potential value of £11,900,000, required minimum turnover of £23,800,000 in each of the last two accounting periods, unless mitigations could be agreed with WMCA Finance during the clarification period (notice 2025/S 000-008098, 5 March 2025, checked 20 August 2026).
- The Natural History Museum, on a Procurement Act procurement, asked for “an
annual turnover of three times the annual contract value or more” (notice 2025/S 000-017274, 28 April 2025, checked 20 August 2026).
- Tate’s membership communication services tender skipped turnover and applied a
liquidity test instead: current assets less stock, divided by current liabilities, averaged over the latest two years of accounts, with a minimum of 0.8 (notice 2026/S 000-006322, 23 January 2026, checked 20 August 2026).
Notice what those have in common. None is a judgement about whether your business is any good. They are arithmetic applied to filed figures. That is the thing to understand about financial standing: it is a gate, not a competition. You do not score points for a strong balance sheet. You are either through or you are out.
The West Midlands figure took two goes, which is instructive. The original notice of 21 February 2025 asked for turnover “50% greater than the total potential contract value” while still printing £23,800,000, which is twice £11.9m, not half as much again. A corrigendum two weeks later replaced the wording with “at least twice the amount”. A buyer publishing an internally contradictory turnover rule, then correcting it, is the best argument there is for reading the financial requirement properly before you decide anything.
Notice also how little the “twice turnover” shorthand tells you. Cornwall asked for turnover worth 38.5% of its five-year core budget. West Midlands asked for exactly twice the contract value, which was the statutory ceiling rather than a breach of it: its original notice went out three days before the Act commenced, so it is a saved PCR 2015 procurement and regulation 58(9) did bind it. The Natural History Museum, on a Procurement Act procurement where no such ceiling exists, asked for three times. Tate did not ask about turnover at all.
Credit scores are set by the buyer, not by the government
Some buyers skip the ratios and buy a score instead. The Scottish Parliamentary Corporate Body’s recycling and waste management services tender required a Creditsafe risk score of 40 or higher, with a parent company guarantee required from bidders below that threshold who have a qualifying parent. A bidder below 40 with no parent had to submit evidence of a stable and improved financial standing with its tender, or risk rejection (notice 2025/S 000-014241, 10 April 2025, checked 20 August 2026).
There is no national minimum credit score for public sector bidding. We looked for one on 20 August 2026, in the Cabinet Office guidance note on assessing and monitoring the economic and financial standing of suppliers and across published notices on Find a Tender and Public Contracts Scotland, and found none. What that guidance says instead is worth quoting back at a buyer who is using a score as a gate: authorities “should generally not use the lack of a credit rating, a minimum credit rating or its accompaniment by a negative outlook on the bidder’s rating as a reason to eliminate a bidder alone”, and credit scores “should be used to corroborate other analysis or to assist identifying potential risk for investigation”.
What the notices themselves show is buyer-set numbers: 30 at East Ayrshire Council, “more than 30” at the Natural History Museum, 40 at the Scottish Parliament. That is why one authority fails you at 39 and another never asks. If your score is marginal, look at it before you bid rather than after you lose, because the agencies will tell you what is dragging it down and some of it is fixable paperwork rather than trading performance.
Two things a buyer is not supposed to ask you for
Section 22(3) carries two restrictions written with smaller suppliers in mind, and almost nobody tells bidders about them. A condition on legal and financial capacity may not require audited annual accounts, except from suppliers who are or were required to have their accounts audited under Part 16 of the Companies Act 2006 or an overseas equivalent, and it may not require insurance relating to performance of the contract to be in place before the award of the contract (checked 20 August 2026).
Both sit in the Procurement Act, so both apply to covered procurements under that Act. They do not reach below-threshold contracts, procurements still running under the saved 2015 regulations, or devolved Scottish buyers.
Where the insurance restriction does apply, it is worth money. If you have been declining to bid because you cannot justify carrying £5m of cover for work you have not won, the requirement is normally that the cover is in place on award rather than on submission, so quoting for cover you will take out if successful is legitimate. The Cabinet Office guidance says the point of the restriction is to stop businesses “being expected to incur unnecessary costs for insurance when they have no guarantee of winning the business”, and that a buyer may instead ask for evidence you will hold the cover on commencement, including “a letter from an insurance company confirming that they would offer the insurance”. That sentence tells you exactly what to send. Read the pack anyway, because the buyer still sets the levels. Tate’s tender, for example, still specified its required limits, at £1m each for public liability, employers’ liability, professional indemnity and product liability.
What to do if you do not meet the test
Failing a financial threshold is not automatically the end of the bid, and on a Procurement Act procurement the routes through it are written into the Act itself. Section 22(8) treats you as satisfying a condition to the extent that an associated supplier satisfies it, and section 22(9) says who counts as associated: firms bidding together, a firm you will subcontract to, or a firm guaranteeing your performance. So a consortium bid and a parent company guarantee both work by statute rather than by custom, and a performance bond is sometimes accepted as an alternative form of assurance.
A fourth option is not a route through the test but around it: subcontract to a prime who already clears the threshold. You are not the bidder, so the condition is not yours to meet. It is slower, and it builds the contract history that makes the next bid easier.
What does not work is ignoring the requirement and hoping. A financial gate is assessed mechanically, and a tender that fails it has to be disregarded before award however good the quality answers are. Some buyers check it first and some check it last, but the outcome is the same.
“We only file filleted accounts”
This is the version of the worry we hear most from micro businesses, and today it is less of a problem than it feels. Small companies and micro-entities can still file abridged or filleted accounts at Companies House, leaving the profit and loss account off the public register, and buyers deal with that constantly (checked 20 August 2026). In our experience, where a buyer needs more than the public filing shows it asks for management accounts, a statement of turnover or a bank reference rather than refusing you.
Do check the current position before you rely on it. From April 2028 the Economic Crime and Corporate Transparency Act 2023 removes the abridged option and requires small companies and micro-entities to file a profit and loss account, though with an option to opt out of publishing it. That date has already moved once, from April 2027, in an announcement on 9 June 2026 (checked 20 August 2026). Read Companies House’s own current guidance rather than an article, including this one, that may have been overtaken.
Our view
Every authority does this differently and so does every procurement, but the commonalities are worth knowing. Nearly all of them look back at your two most recently filed years to see how the business has performed rather than how it says it is doing. A good many buy in a third-party view of you instead of reading the accounts themselves, which is how a credit score you have never looked at ends up deciding a bid you spent three weeks on.
The financial section is the part of a tender where small firms lose without ever finding out why, because failure there is silent and mechanical. It is also the easiest part to prepare in advance, and the only part where the work can genuinely be done before a notice appears: know your two most recent filed figures, know your acid test ratio, know your credit score, and know which of the three routes above you would use if a threshold came in above you.
Then read the financial requirement in the pack first, before the specification, and check which regime the notice is under while you are there. If you cannot clear it, that is a no-bid decision made on day one instead of day twenty, and it is the cheapest decision in bidding.
If you want a second pair of eyes on whether a requirement is one you can clear or one you should walk away from, that is what a bid review is for, and we cover this ground in bid training for teams who want to make the call themselves.