Regularity, Propriety, Value for Money and Feasibility: A Procurement Governance Guide

Purpose: How the four Accounting Officer standards can be used as a practical lens for major procurement and spending decisions.

How the four Accounting Officer standards can be used as a practical lens for major procurement and spending decisions. 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

• Managing Public Money says proposed expenditure should meet Accounting Officer standards of regularity, propriety, value for money and feasibility.
• Use of public funds also requires adequate legal powers, budget cover and the necessary Treasury consent or delegated authority.
• A Spending Review allocation or policy approval does not necessarily amount to the separate spending approval required for a transaction.
• Departments operate within delegated authorities, with expenditure outside delegation requiring explicit approval.
• Accounting Officers are accountable to Parliament for stewardship of public resources.

What the guidance means in practice

The source material gives several anchors for that process. Managing Public Money says proposed expenditure should meet Accounting Officer standards of regularity, propriety, value for money and feasibility. Use of public funds also requires adequate legal powers, budget cover and the necessary Treasury consent or delegated authority. A Spending Review allocation or policy approval does not necessarily amount to the separate spending approval required for a transaction. 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. Departments operate within delegated authorities, with expenditure outside delegation requiring explicit approval. Accounting Officers are accountable to Parliament for stewardship of public resources. Departments are expected to maintain controls, reporting and management information that support timely decisions. 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.

1. Step 1. Regularity: confirm powers, budgets, delegations and applicable rules. Record any assumption that could change the conclusion and when it will be reviewed.
2. Step 2. Propriety: consider standards, public expectations, transparency and conflicts. Keep the analysis proportionate to the value, risk, novelty and criticality of the requirement.
3. Step 3. Value for money: test economy, efficiency, effectiveness and whole-life outcomes. Capture the source evidence and name the person accountable for the next decision.
4. Step 4. Feasibility: assess whether the organisation, market, timetable and delivery model can actually deliver. Record any assumption that could change the conclusion and when it will be reviewed.
5. Step 5. Identify approvals and conditions before commercial commitments are made. Keep the analysis proportionate to the value, risk, novelty and criticality of the requirement.
6. Step 6. Retain evidence of the assessment and revisit it if the project changes materially. 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:

• Build the four tests into approval papers explicitly.
• Use specialist advice where legal powers, classification or consent is uncertain.
• Do not make supplier commitments before required approval.
• Explain material uncertainty rather than using false precision.
• Connect feasibility to market and delivery-model evidence.
• Give senior decision makers a clear view of residual risk and conditions.

Common pitfalls to avoid

The most common problems are usually process failures rather than a lack of templates. Watch particularly for the following:

• Assuming an approved budget is sufficient authority to proceed.
• Treating legal compliance as the only governance test.
• Calling a project feasible merely because a procurement can be launched.
• Seeking approval retrospectively after commitments have been made.

Easy-to-read takeaway

For regularity, propriety, value for money and feasibility: a procurement governance guide, 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: Managing Public Money, April 2026. 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.