A debarment register with no entries and no independent trigger
The Procurement Act 2023 debarment regime went live on 24 February 2025, but the published list remains blank as of mid-2026: the gov.uk list itself states it 'will remain blank' until a minister decides to add a supplier. The first real investigations (cladding suppliers named in the Grenfell Inquiry report) were paused in July 2025 at the request of the CPS and Metropolitan Police to avoid prejudicing criminal proceedings. The Debarment Review Service, absorbed into the Government Commercial Agency in April 2026, acts only on referral from contracting authorities and ministerial discretion; there are no statutory timelines and no route for civil society, journalists or whistleblowers to trigger an investigation. Tussell provides commercial contract-data analytics but no one runs systematic corruption red-flag monitoring across the new Central Digital Platform data.
The PPE VIP lane showed what unpoliced emergency procurement costs: the Covid Counter-Fraud Commissioner put total scheme fraud and error at £10.9bn, with only £1.8bn recovered. A debarment power that never debars anyone provides no deterrent for the next crisis.
An independently governed debarment investigation function with statutory timelines, a public investigation pipeline, a third-party referral channel (civil society, auditors, whistleblowers), a deconfliction protocol so criminal proceedings pause rather than kill debarment cases, plus a funded red-flag analytics unit working on Central Digital Platform data.
// Build now: First artefact: red-flag analytics unit on public Central Digital Platform data producing shadow debarment dossiers; statutory regime is the end-state.
The debarment power that never debars leaves emergency procurement undeterred after £10.9bn Covid fraud; the regime exists but no independent trigger or red-flag analytics is resourced.