Purpose: A practical early screen for the complexity factors highlighted in the Approval Processes guidance, with actions for procurement and project leaders.
A practical early screen for the complexity factors highlighted in the Approval Processes guidance, with actions for procurement and project leaders. This matters because public procurement decisions are rarely isolated events. A choice made during planning can affect competition, affordability, service quality, supplier behaviour and the ability to manage the contract later. The strongest approach is therefore to use the source guidance as part of an end-to-end commercial process, with clear ownership and evidence rather than as a document that is completed after the key decisions have already been taken.
Quick summary
- The guidance identifies first-generation outsourcing as a factor that may make a project complex.
- Planned transformation of services is another indicator.
- A limited market, or a situation where government is the only buyer, can increase complexity.
- Services or assets that are not well understood internally are also highlighted.
- Projects with a well-understood scope and an established market are less likely to be classed as complex.
What the guidance means in practice
The source material gives several anchors for that process. The guidance identifies first-generation outsourcing as a factor that may make a project complex. Planned transformation of services is another indicator. A limited market, or a situation where government is the only buyer, can increase complexity. These are not interchangeable statements: some describe statutory or policy requirements and others describe recommended commercial practice. Teams should identify which category each requirement falls into, apply it to the organisation and procurement in scope, and keep a record of the judgement. Where guidance from 2021 or 2023 predates the Procurement Act 2023, its commercial principles can remain useful, but current legislation, regulations and current statutory guidance take precedence on legal process.
The practical value becomes clearer when the remaining guidance is read alongside the project lifecycle. Services or assets that are not well understood internally are also highlighted. Projects with a well-understood scope and an established market are less likely to be classed as complex. Commercial pipelines are used to flag potential complex projects for early commercial involvement and assurance. In day-to-day terms, this means the buyer should be able to answer three questions at any approval point: what outcome are we trying to achieve, what evidence supports the proposed commercial approach, and what will need to be managed after the decision is made? If those answers are weak, more analysis is normally more useful than adding another layer of narrative to an approval paper.
A practical process to follow
A proportionate process can be built into existing governance. The steps below are deliberately practical. They are not a substitute for the detailed source guidance, legal advice or local standing orders, but they provide a useful structure for a procurement or commercial team.
- Step 1. Screen the project at pipeline stage instead of waiting for the business case to be mature. Record any assumption that could change the conclusion and when it will be reviewed.
- Step 2. Ask whether the service has been outsourced before and whether reliable service and asset data exists. Keep the analysis proportionate to the value, risk, novelty and criticality of the requirement.
- Step 3. Assess how much transformation is bundled into the requirement. Capture the source evidence and name the person accountable for the next decision.
- Step 4. Examine supplier-market depth and how much influence the public buyer has in the market. Record any assumption that could change the conclusion and when it will be reviewed.
- Step 5. Identify specialist commercial, financial, legal, workforce and technical expertise that may be needed. Keep the analysis proportionate to the value, risk, novelty and criticality of the requirement.
- Step 6. Build the resulting evidence and assurance work into the project timetable. Capture the source evidence and name the person accountable for the next decision.
What good looks like
Good practice is visible in the decision trail, not only in the final document. A reviewer should be able to follow the line from the service need, through market and cost evidence, to the route, evaluation, contract terms and management arrangements. Where several functions contribute, the file should show who owns each decision and where challenge occurred. The same principle applies to handover: useful assumptions, models, KPI definitions, risks, supplier information and approval conditions should move into mobilisation and contract management instead of being left in the sourcing archive. This continuity is particularly important for long-running public services, where staff can change but the organisation remains accountable for the outcome.
Recommendations for procurement teams
The following recommendations are suitable for teams that want to embed the topic into normal ways of working rather than create a parallel compliance process:
- Use a short documented complexity assessment at initiation.
- Revisit the assessment when scope or market conditions change.
- Allow extra time for delivery model analysis and market engagement where uncertainty is high.
- Treat weak service data as a project risk and workstream.
- Escalate limited-market concerns early because they affect risk and contract design.
- Use independent challenge where the consequences of a poor sourcing decision are significant.
Common pitfalls to avoid
The most common problems are usually process failures rather than a lack of templates. Watch particularly for the following:
- Using contract value alone as the test for complexity.
- Assuming the presence of an incumbent means the market is understood.
- Ignoring first-generation outsourcing risks because the service itself is familiar.
- Waiting until tender documents are drafted before discussing complexity.
Easy-to-read takeaway
For is your outsourcing project complex? practical warning signs for public sector teams, the core discipline is to start early, connect the analysis to a real decision and preserve enough evidence for the next stage of the lifecycle. The source material should help teams make better decisions, not merely produce more paperwork. Before acting on a live procurement, confirm the current version of the Procurement Act 2023, regulations, Procurement Policy Notes and any organisation-specific approvals or delegations. This is especially important for thresholds, notice duties, exemptions and policy requirements that can change over time.
Source basis
Primary source used: Approval Processes Guidance Note, May 2021. Related articles in this collection also draw on the other supplied Cabinet Office, HM Treasury and Procurement Act materials where the topics overlap.
This article is general procurement support content. It should be read alongside current legislation, statutory guidance and your organisation’s own governance and legal advice.