Begin with the full commitment

For public procurement valuation, estimate the maximum payable over the whole term, including VAT and renewal or extension options. Consider requirements that can reasonably be aggregated and document legitimate reasons for treating them separately. Artificial subdivision to avoid procurement rules is prohibited. Trusts should assess their requirements as the contracting authority, rather than assume each academy has a separate threshold.

Prepare an estimate before selecting the route, then revisit it if the scope materially changes. Include all expected delivered-energy costs; do not omit embedded commission. Assess any separately procured advisory service on its own terms and avoid counting embedded remuneration twice. Retain calculations and assumptions so a reviewer can follow the reasoning.

Understand what the threshold does

For 2026 and 2027, the general sub-central goods and services threshold is £207,720 including VAT. It is a trigger for the applicable public procurement process, not a cap on spending or a requirement to use one named framework. Purchasing energy does not itself make a school a utility operator entitled to a higher utilities threshold.

Our recommendation is to obtain qualified procurement advice where the estimate is close to the threshold, the contracting entity is unclear or the arrangement combines supply with substantial additional services. Ask for a written route recommendation. Uncertainty is easier to resolve while requirements can still be adjusted than after a preferred offer has been selected.

Apply the right duties below the threshold

Schools are excluded from the regulated below-threshold requirements in Part 6 of the Procurement Act. DfE confirms the exclusion for academy trusts. This does not remove applicable financial governance, local competition rules or value-for-money expectations. A separate purchase by an LA requires its own assessment.

Set the competition method and evaluation criteria before receiving offers. Record who was invited, the brief they received and how the school dealt with material differences. Follow the applicable policy if a proposed exception is needed. Do not describe a locally authorised process as a statutory exemption unless the legal basis has actually been established.

Plan properly for above-threshold procurement

Competition is the default for public contracts. A compliant framework call-off or another permitted process may be available, but each has conditions. Direct award requires a valid statutory basis and the applicable transparency steps. The commodity-market justification is not a blanket shortcut for every school retail energy contract; nor does a short quote window automatically establish unavoidable urgency.

Procurements and frameworks started before the Procurement Act took effect may remain under the previous regime. Check the relevant history. Our recommendation is to design the timetable around both procurement milestones and energy-market execution, with approval arrangements agreed in advance. The adviser should explain how those two timetables will work together.

Keep one TPI accountable and retain independent checks

Select one adviser for the agreed exercise through an appropriate appointment process. Ask it to identify which suppliers it can access, its remuneration, conflicts and the services included. Keep the adviser appointment distinct from the award of supply. A broker's supplier panel is not automatically a public procurement framework.

DfE advises that a quotation-stage letter of authority should cover quotations only, should not authorise signature of supply contracts and should remain valid for no more than 12 months. Its minimum-standard questions also recommend at least one other supplier quotation even where the broker offers several. That supports an independent check without appointing multiple TPIs to approach the same market.

Before signature, confirm the authorised approver has the evaluation, current written terms, fee disclosure and required governance evidence. The school or trust retains responsibility for the decision. Guidance checked on 2 November 2026.