A framework agreement is a standing arrangement between a buyer and one or more suppliers that pre-agrees the terms, pricing, and conditions for future contracts. It does not itself commit either side to spend money. Rather, it creates a ready-made route to place orders quickly, without running a full procurement process each time. ApexCounsel helps businesses across the UK understand and negotiate these arrangements from the supplier side.
Key Takeaways
- Framework agreements set pre-agreed terms; they do not guarantee any orders for suppliers.
- The Procurement Act 2023 (in force 24 February 2025) introduced open frameworks lasting up to 8 years.
- SMEs make up 75.4% of CCS suppliers but receive only 10.8% of spend, a gap worth understanding before joining a framework.
- Both public and private sector buyers use frameworks; only public frameworks are tightly regulated.
- A call-off contract is the binding agreement; the framework itself is the gateway to reach it.
What Is a Framework Agreement Under UK Law?
Under the Public Contracts Regulations 2015, Regulation 33, a framework agreement is defined as “an agreement between one or more contracting authorities and one or more economic operators, the purpose of which is to establish the terms governing contracts to be awarded during a given period.” The UK public sector channelled £33 billion through commercial agreements in 2024/25 (CCS Annual Report, Gov.uk, 2025), which gives a sense of how central this mechanism has become.
In plain English, a framework is a pre-qualification and pre-pricing exercise. A buyer (often a public authority) runs a competitive process once, approves a shortlist of suppliers, and then places individual orders from that list over time without needing to advertise fresh each time.
The framework itself is not the contract. It sets the rules of the game. The binding contract only comes into existence when a specific “call-off” order is placed. This distinction matters enormously for suppliers assessing the value of winning a framework place.
The Public Contracts Regulations 2015, Regulation 33 defines a framework agreement as “an agreement between one or more contracting authorities and one or more economic operators, the purpose of which is to establish the terms governing contracts to be awarded during a given period.” Being admitted to a framework creates no obligation on the contracting authority to place any orders.
How Did the Procurement Act 2023 Change Framework Agreements?
The Procurement Act 2023, Section 45 came into force on 24 February 2025 and replaced the PCR 2015 for all new frameworks set up from that date. It introduced the most significant reforms to UK procurement law in a decade. Transparency requirements tightened: call-off award notices are now mandatory, whereas before publication was optional.
The single biggest structural change is the introduction of open frameworks. Under the old PCR 2015 regime, once a framework closed its supplier list, no new entrants could join for its entire duration. Open frameworks under the 2023 Act can run for up to 8 years, provided the buyer reopens them to new suppliers at least twice during that period. This gives newer or smaller suppliers more realistic opportunities to enter frameworks they previously missed.
The table below summarises the key differences between the two regimes.
| Rule | PCR 2015 | Procurement Act 2023 |
|---|---|---|
| Standard max duration | 4 years | 4 years (closed framework) |
| Open frameworks | Not available | Up to 8 years; must reopen at least twice |
| New suppliers mid-term | Not permitted | Permitted via open frameworks |
| Call-off award notice | Optional | Mandatory |
| Mini-competition | Required where terms not fully predetermined | Continues; conditions can apply at call-off stage |
| Transitional rule | Applies to frameworks set up before 24 Feb 2025 | Applies to all new frameworks from 24 Feb 2025 |
What Is a Call-Off Contract and Why Does It Matter?
A call-off contract is the individual, binding purchase agreement placed by a buyer within the framework. It is the point at which real commercial obligations arise. In 2025, 1,856 distinct frameworks were used by the public sector to award contracts (Tussell 2026 Public Sector Frameworks Report), which means the call-off stage is where billions of pounds in work is actually committed each year.
Call-offs can be awarded in two ways. First, direct award: if the framework terms, including price and specification, are sufficiently detailed, the buyer can place an order directly with the most suitable supplier without a further competition. Second, mini-competition: the buyer invites all capable framework suppliers to submit a fresh proposal for the specific job, evaluates them, and awards to the highest scorer.
There is a critical legal boundary here. Call-offs that are “substantially different” from the terms already agreed in the framework constitute a legal breach. Suppliers and buyers alike need to check that any deviations are minor and justifiable, or risk the call-off being challenged.
From a supplier’s perspective, it is also worth noting that call-off award notices must now be published under the Procurement Act 2023. This transparency creates a useful intelligence source: you can see who is winning work from frameworks you sit on, and benchmark your win rate accordingly.
If you are considering drafting framework terms or a call-off contract template, the ApexCounsel Document Creator provides a practical starting point.
Are Framework Agreements Worth It for SMEs?
The statistics paint a stark picture. SMEs represent 75.4% of all Crown Commercial Service suppliers (9,905 of 13,142) but account for only 10.8% of spend, just £3.9 billion of £36.2 billion (CCS SME Action Plan, Gov.uk, June 2025). That gap between supplier share and spend share is the defining challenge facing SMEs on public frameworks.
The chart below visualises this imbalance directly.
Crown Commercial Service data shows SMEs are 75.4% of suppliers but receive only 10.8% of spend.
SME Supplier Share vs Spend Share — CCS 2024/25
100%
75%
50%
25%
0%
75.4%
Supplier Share
10.8%
Spend Share
Source: CCS SME Action Plan, Gov.uk, June 2025
The Cabinet Office has set a target of directing 30% of procurement expenditure to SMEs by the end of 2027/28 (Cabinet Office SME Action Plan 2025-2028, Gov.uk). Progress is being made: UK public sector SME spend reached £45.2 billion in 2025, representing 21% of all direct procurement and a six-year high (British Chambers of Commerce, May 2026). But the gap between headcount on frameworks and actual spend remains a serious practical issue.
[SOLICITOR INSIGHT] The single most important warning for SME founders considering a framework bid is this: being accepted onto a framework creates no legal obligation on the buyer to spend a penny with you. This “no volume guarantee” principle is well-established but rarely explained plainly. Founders sometimes spend significant resources winning a framework place, then receive no call-offs at all. Before committing to a framework bid, model the realistic win rate by reviewing publicly available call-off award notices for that framework.
When Should a Business Use a Framework Agreement?
Frameworks make commercial sense when a buyer expects to purchase similar goods or services repeatedly over several years. NHS frameworks, for example, delivered over £424 million in savings in 2025 by aggregating demand and negotiating once rather than repeatedly (Thornton & Lowe / NHS via Tussell 2026). The efficiency case is strong for high-volume, routine procurement.
For suppliers, the calculus is different. A framework place is most valuable when:
- The buyer regularly places call-offs rather than simply maintaining the list.
- Your pricing on the framework is competitive enough to win mini-competitions as well as direct awards.
- The framework covers a category where you have genuine capacity to deliver at scale.
- The bid cost is proportionate to the realistic contract value you could win over the framework’s life.
- You have reviewed published call-off notices for the framework to verify that spend is genuinely flowing.
[ORIGINAL ANALYSIS] Reviewing Tussell data alongside CCS SME figures, a pattern emerges: the frameworks with the highest SME spend concentration tend to be category-specific ones, such as technology, consultancy, and professional services, rather than large goods supply frameworks where larger incumbents dominate. SMEs evaluating which frameworks to pursue should focus on category fit as much as framework prestige.
Do Framework Agreements Apply to Private Sector Businesses?
Private sector framework agreements are widely used but largely unregulated. There is no statutory maximum duration, no mandatory publication of call-off awards, and no requirement to run mini-competitions. Businesses are free to structure the arrangement as they see fit, subject only to ordinary contract law principles and competition law constraints.
Common private sector uses include:
- Preferred supplier lists for professional services such as legal, HR, and accountancy.
- Construction and facilities management arrangements for property portfolios.
- Technology vendor frameworks used by banks, insurers, and large retailers.
- Consortium purchasing arrangements by trade associations on behalf of members.
[CAMBRIDGE PERSPECTIVE] In our experience advising businesses across the Cambridge technology corridor, private sector frameworks are increasingly common as fast-scaling companies seek to professionalise their supply chains without running a full tender every time they need specialist input. The key legal risk in these arrangements is not regulatory non-compliance but ambiguity: poorly drafted frameworks can make it unclear whether a call-off constitutes a new binding contract or a variation of the framework itself.
If you are drafting or reviewing a private sector framework, clarity on four points is essential: the scope of goods or services covered, how prices are set or adjusted over the framework’s life, the call-off process and what triggers a binding commitment, and the termination rights on both sides.
In 2025, 72% of large public contracts were procured through frameworks, up from 43% in 2018/19 (Tussell 2026 / Thornton & Lowe). Over 50% of Strategic Suppliers’ contracts in 2024/25 were awarded via framework agreements. The framework route is no longer a niche option: it is the default procurement channel for major UK public contracts.
What Is the Government Commercial Agency and Why Does It Matter?
The Crown Commercial Service (CCS) managed £33 billion in commercial agreements in 2024/25 and delivered £5.3 billion in commercial savings, up from £2 billion in 2020/21 (CCS Annual Report, Gov.uk, 2025). From April 2026, CCS began transitioning to the Government Commercial Agency (GCA), which consolidates commercial functions across central government. If you are researching how to access public sector frameworks, you may encounter both names: they refer to the same organisation in transition.
For buyers and suppliers navigating the new landscape, the GCA’s How to Buy guidance is the authoritative reference point for understanding which frameworks are available and how to access them. You can also explore ApexCounsel’s commercial law services for tailored advice on framework strategy and compliance.
Frequently Asked Questions
What is a framework agreement in UK law?
A framework agreement is a pre-agreed arrangement between a buyer and one or more suppliers that sets the terms, pricing structure, and conditions under which future contracts can be placed. The statutory definition under the Public Contracts Regulations 2015 (Regulation 33) describes it as an agreement “to establish the terms governing contracts to be awarded during a given period.” The framework itself is not a binding purchase commitment. Orders only become binding when a call-off contract is placed within the framework’s terms.
How long can a framework agreement last?
For public sector frameworks set up under the PCR 2015, the standard maximum duration is 4 years. The Procurement Act 2023 (in force from 24 February 2025) retains the 4-year limit for closed frameworks but introduces open frameworks, which can run for up to 8 years provided the buyer reopens them to new suppliers at least twice. Private sector framework agreements have no statutory duration limit; the parties can agree any term they choose.
What is a call-off contract?
A call-off contract is the individual, legally binding purchase agreement placed by a buyer within an existing framework. It is the point at which real financial obligations arise. Call-offs can be placed by direct award (where the framework terms are specific enough to identify the right supplier immediately) or by mini-competition (where framework suppliers are invited to submit tailored proposals). Under the Procurement Act 2023, buyers must now publish a call-off award notice for each contract placed, creating a public record of all framework spend.
Can small businesses use framework agreements?
Yes, and many do. SMEs represent 75.4% of all CCS suppliers. However, they account for only 10.8% of CCS spend, a significant imbalance the Cabinet Office is working to address through its 30% SME spend target by 2027/28. Small businesses considering a framework bid should check published call-off award data first to assess whether spend is genuinely flowing through that framework. They should also factor in the “no volume guarantee” principle: a framework place does not guarantee any orders.
What is the difference between a framework agreement and a contract?
A framework agreement establishes the rules and pre-agreed terms for future purchases. It does not itself commit either party to spend or supply anything. A contract (in this context, a call-off contract) is the binding agreement that creates actual legal obligations: to deliver specific goods or services, by a specific date, for a specific price. Think of the framework as the approved supplier list with pre-negotiated terms, and the call-off as the actual order placed from it.
What changed with the Procurement Act 2023?
The Procurement Act 2023, which came into force on 24 February 2025, made three significant changes to framework agreements. First, it introduced open frameworks: buyers can now admit new suppliers mid-term, which was not possible under PCR 2015. Second, call-off award notices are now mandatory rather than optional, improving transparency. Third, the standard closed framework duration remains at 4 years, but open frameworks can extend to 8 years. All frameworks set up from 24 February 2025 fall under the new rules; earlier frameworks remain under PCR 2015 for their duration.
Do framework agreements apply to private sector businesses?
Yes, but with far less regulation. Private sector businesses use framework agreements freely, whether for preferred supplier lists, professional services panels, or procurement consortia. There are no statutory rules on duration, transparency, or mini-competition requirements. The arrangement is governed purely by ordinary contract law. The key practical risks are ambiguity in drafting (particularly around what triggers a binding call-off) and competition law considerations if the framework restricts suppliers’ ability to deal with others. A solicitor can review the terms before you sign.
If you are working through a framework agreement as a buyer, supplier, or public authority, ApexCounsel’s commercial solicitors can advise on structure, compliance, and risk. You can also explore our full range of commercial law services.
