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FOI for Procurement & Spending Data

Procurement and spending data is some of the highest-value information for accountability journalism. This guide covers mandatory disclosures, how to phrase requests for spreadsheets not PDFs, typical exemptions, and how to cross-reference with Companies House.

Information only. FOI exemption claims — particularly s.43 commercial interests — require careful analysis. If an authority refuses your request, see FOI Refusals for challenge routes, including internal review and ICO complaint. Full disclaimer.

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Why procurement and spending data matters for journalists

Public bodies spend hundreds of billions of pounds each year on goods, services, and contracts. That spending — and the procurement decisions that drive it — is one of the most important areas of public accountability. Stories about councils awarding contracts to politically connected companies, NHS trusts overpaying for consumables, or government departments using emergency procurement procedures to bypass competition rules are all grounded in spending and procurement data.

The good news for journalists is that a substantial amount of this data is now mandated for proactive publication. The Local Government Transparency Code 2015 requires English councils to publish monthly transaction data for all spending over £500, all contracts above £5,000, senior pay data, and asset registers. The Procurement Act 2023 (replacing the Public Contracts Regulations 2015) strengthened transparency obligations further. Many stories can be built without filing a single FOI.

Where proactive publication is incomplete, out of date, or does not drill into the detail you need, FOI requests fill the gap. The key is to request specific data in an analysable format — spreadsheets rather than PDFs, precise date ranges, and named suppliers or cost centres.

When procurement FOI requests are most valuable

  • 1You want to know which suppliers have received the most money from a public body over a given period.
  • 2You are investigating whether a single supplier is receiving an unusual proportion of contracts without open competition.
  • 3You want the full text of a contract, including performance clauses, penalties, and exit provisions.
  • 4You are looking at emergency or direct-award procurement where normal competition was bypassed.
  • 5You want to cross-reference supplier payments with Companies House to check for conflicts of interest.
  • 6The proactively published spending data is incomplete, out of date, or not machine-readable.
  • 7You want to compare procurement in two different financial years to identify significant changes.

Red flags in procurement stories

  • A contract was awarded without a competitive tender process to a recently incorporated company.
  • The winning supplier has directors who are connected to officers or elected members at the awarding authority.
  • The contract value is just below a threshold that would trigger wider publication or scrutiny.
  • An emergency procurement procedure was used without an obvious emergency being cited.
  • A framework contract has been extended repeatedly beyond its original term without retendering.
  • The public body's own internal audit reports flag concerns about procurement compliance.
  • A contract was modified significantly after award — effectively giving the incumbent a different contract.

Procurement FOI request checklist

  • I have checked the authority's open data pages for proactively published spending data before filing.
  • I have searched Find a Tender (findatender.service.gov.uk) for contract award notices.
  • I have searched Contracts Finder for central government contracts.
  • My request specifies the format I want (e.g., CSV or Excel spreadsheet) not just "data".
  • My request specifies a precise date range rather than an open-ended period that could trigger cost ceiling arguments.
  • My request identifies the supplier, cost centre, or contract type I am interested in, to narrow scope.
  • I have considered which exemptions are likely to be claimed and prepared counter-arguments.
  • I have noted the 20 working day response deadline and set a calendar reminder.
  • If the authority claims s.43 commercial interests, I have checked whether the contract has ended (weakening the exemption).
  • I have cross-referenced the supplier name against Companies House for directors, PSC, and filing history.

Copy-paste request template: spending data

Dear FOI Officer, Under the Freedom of Information Act 2000, I request the following information: 1. A spreadsheet of all payments made to [SUPPLIER NAME / OR: all suppliers within [CATEGORY/COST CENTRE]] between [START DATE] and [END DATE], including for each payment: - Date of payment - Supplier name and company number (if known) - Amount paid (excluding VAT) - Cost centre or budget code - A brief description of the goods or services provided - Invoice number or purchase order reference 2. A copy of any contract(s) with [SUPPLIER NAME] in force during this period, including the contract value, start date, end date, and any extension clauses. Please provide the spending data as a CSV or Excel file. If any information is withheld, please cite the specific exemption and explain why the public interest in maintaining the exemption outweighs the public interest in disclosure. Yours faithfully, [YOUR NAME]

FOI Builder tool

Use our FOI Builder to generate a tailored procurement or spending request for your specific authority and topic.

Open FOI Builder

Typical exemptions and how to challenge them

s.43 Commercial Interests

Qualified exemption. The authority must demonstrate that disclosure would or would be likely to prejudice commercial interests. For completed contracts, this is much harder to establish. Challenge: point out the contract has ended; note that the existence, value, and supplier are already published on Find a Tender; ask the authority to identify which specific pricing or commercial element would be prejudiced and how.

s.40 Personal Data

Absolute exemption for personal data where disclosure would breach data protection law. Commonly claimed to withhold the names of individual officers who sign off payments. Challenge: ask for payment data anonymised to cost-centre level (no individual names needed); note that senior officers' roles and responsibilities are often public via organograms; request redacted versions of contracts with personal data removed.

s.36 Prejudice to Effective Conduct of Public Affairs

Qualified exemption requiring a "reasonable opinion" from a qualified person. Sometimes claimed for information about ongoing procurement exercises. Challenge: ask for information relating to completed exercises only; request the qualified person's opinion in writing; request an internal review.

Cost ceiling (s.12)

Not an exemption but an exclusion: if complying would exceed £450 (central government) or £600 (other authorities) estimated cost, the authority can decline. Challenge by narrowing the date range, specifying a particular supplier, or splitting the request. Ask the authority what it can provide within the limit.

Common mistakes

  • Requesting "all spending" with no date range or supplier filter — this will almost always be refused on cost grounds.
  • Accepting a PDF dump when you requested a spreadsheet — push back; machine-readable format is a legitimate request.
  • Ignoring the proactively published data on the council's open data pages — always check first.
  • Not cross-referencing Find a Tender before the FOI — you may already have the contract award notice you need.
  • Assuming s.43 is an absolute exemption — it is qualified, and the public interest test almost always favours disclosure for completed public contracts.
  • Failing to request an internal review when you receive a refusal — you must exhaust internal review before complaining to the ICO.
  • Not tracking the response deadline — 20 working days is strict; a missed deadline is itself a ground for ICO complaint.

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Frequently asked questions

What is the Local Government Transparency Code and what must councils proactively publish?
The Local Government Transparency Code 2015 requires councils to proactively publish spending data over £500 on a monthly basis, details of contracts worth over £5,000, senior salaries and pay multiples, and information about assets. This mandatory publication removes the need to file an FOI for this baseline data — you should always check the council's open data pages first. The Code applies to English councils; Wales, Scotland, and Northern Ireland have their own frameworks.
What is Find a Tender and how useful is it for journalists?
Find a Tender (findatender.service.gov.uk) is the UK's post-Brexit replacement for the EU's TED (Tenders Electronic Daily) database. Public authorities must publish contract opportunities and awards above certain thresholds (£138,760 for central government services; £213,477 for other authorities, subject to periodic revision). Contract award notices show the winning supplier, the contract value, and the procurement procedure used. It is a valuable starting point for procurement stories — particularly for spotting single-supplier contracts, short-cuts to open competition, and unusual contract structures.
How do I phrase an FOI request to maximise disclosure of spending data?
Request specific data in a machine-readable format rather than asking for 'all spending'. Good phrasing: 'Please provide a spreadsheet of all payments made to [supplier name or SIC code range] between [date range], including the date, amount, cost centre, invoice number, and a brief description of goods/services.' Specify the format (CSV, Excel) to avoid receiving a PDF that is hard to analyse. Narrow the date range to reduce the cost ceiling argument. Where you do not know the supplier name, specify the contract type or policy area instead.
What is the s.43 commercial interests exemption and how do authorities misapply it?
Section 43 of the FOIA exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any person. It is a qualified exemption — meaning the public interest in disclosure must be weighed against the prejudice. Authorities often over-claim s.43 for completed contracts where there is no ongoing competitive process. If the contract is complete, the commercial sensitivity argument is much weaker. Challenge by: asking whether the contract has ended; pointing out that the value and supplier are already public via Find a Tender; and requesting the ICO's guidance on the commercial interests exemption.
Can I request the contracts themselves, not just the payment data?
Yes. The full text of public contracts is generally disclosable under FOIA, and there is a government presumption of transparency for contracts. Common redactions are: genuinely commercially sensitive pricing schedules, trade secrets, and personal data of individual officers. However, the fact that a contract was signed, the overall contract value, the duration, and the key deliverables are almost always disclosable. In practice, many central government contracts are now published proactively on Contracts Finder.
How do I cross-reference procurement data with Companies House?
Once you have the supplier name, look them up on Companies House (find-and-update.company-information.service.gov.uk). Key checks: who are the directors and persons with significant control (PSC) — are they connected to public officials or decision-makers? Has the company been recently incorporated before winning a contract? What are the filed accounts — is the company a shell? Are there any County Court Judgements or insolvency proceedings? Companies House data combined with FOI spending data is a powerful accountability pairing for procurement stories.

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