A debarment register with no entries and no independent trigger
The Procurement Act 2023 debarment regime went live on 24 February 2025, and 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, into cladding suppliers named in the Grenfell Inquiry report, were paused in July 2025 at the request of the CPS and the 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. No statutory timelines exist, and civil society, journalists and whistleblowers have no route to trigger an investigation. Tussell provides commercial contract-data analytics, and nobody 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 £1.8bn recovered. A debarment power that never debars anyone deters nothing before the next crisis.
An independently governed debarment investigation function with statutory timelines and a public investigation pipeline. A third-party referral channel would open it to civil society, auditors and whistleblowers, a deconfliction protocol would let criminal proceedings pause rather than kill debarment cases, and a funded red-flag analytics unit would work the 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.
Emergency procurement remains undeterred after £10.9bn of Covid fraud and error; the regime exists, the list is empty, and no independent trigger or analytics is resourced.