Hot topics in 2026 for UK public sector cloud contracts

In issuing the G-Cloud 15 tender documents (expected to close for bidder submissions on 30^th January 2026), the Crown Commercial Services (CCS) noted that: ‘The Public Cloud market (in the Public Sector) was estimated to be worth £6bn in 2024 according to the Department for Science, Innovation and Technology and Government Digital Service’ (see also our update on the G-Cloud 15 Framework: G-Cloud 15 (G15) Framework: Key changes for UK public sector cloud suppliers). As the demand and number of contracts (whether via a CCS framework or otherwise) for cloud services may have grown over the last few years, there are a number of key topics both buyers and suppliers are likely to be considering in UK public sector cloud contracts this year:

1. Data sovereignty – As a greater number of UK public sector buyers embrace the flexibility and scalability of cloud-computing through the provision of cloud services by global providers, buyers are likely to continue to focus on data sovereignty as a key issue in future cloud deals. A sovereign cloud means, in the case of the UK, a customer’s data is stored and managed entirely within the UK and is subject to the laws of the UK including the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and Data (Use and Access) Act 2025 (see also our update on the Cyber Security and Resilience Bill: UK Cyber Security and Resilience Bill – What You Need to Know). As UK public sector buyers monitor geopolitical changes in 2026, the demand for secure UK sovereign cloud environments is likely to increase as buyers continue to seek greater control over both data storage and transfer by its cloud provider, regardless of where such a cloud provider may be headquartered.

    

2. Security standards – The National Procurement Policy Statement (NPPS) which came into effect on 24 February 2025 under the Procurement Act 2023 stipulated that contracting authorities should be ‘mitigating supply chain and national security risks by ensuring appropriate controls are in place such as the Cyber Essentials standard for cyber security’. CCS also notified bidders to G-Cloud 15 to make it clear that Cyber Essentials was now a mandatory requirement for all Lots having previously been exempt. As UK public sector buyers increasingly rely on the Cyber Essentials certification to demonstrate compliance with the Government’s cyber security strategy, suppliers should ensure that it has the necessary certification in place before looking to increase its direct UK public sector business.

    

3. Pricing transparency – In June 2025, the UK Government’s Digital Service (GDS) confirmed it had been developing a cloud costs data solution with an aim ‘to get a central picture of the total usage and a breakdown of spend on cloud services across the public sector…so that future cloud services will be able to be procured and provisioned in the most cost efficient manner’. Such procurement tools may put suppliers under increasing pressure to justify why one UK public sector buyer is being offered a particular price that does not appear to align with pricing offered to other contracting authorities. Suppliers must now make pricing publicly available for G-Cloud 15 on the Digital Marketplace and the direct award criteria for call-offs under G-Cloud 15 now requires the final step of the criteria to consider the supplier with the ‘lowest price’ under the framework. We expect, in time, that government will intend for this data to become publicly available on the Central Digital Platform to all authorities, as part of the progressive development of data analysis tools that the CDP is intended to provide.  

    

4. Direct or indirect – Given the increasing pressure from the UK Government on contracting authorities to buy cloud services ‘smarter’, buyers may be more likely to consider whether direct contracts with cloud vendors are preferable to purchasing via a reseller or partner. There are, however, a significant number of considerations for both buyers and suppliers when determining if a direct contract is preferable to a reseller arrangement, including the supplier’s ability to comply with any mandatory requirements imposed by CCS and/or individual buyers such as Cyber Essentials certifications or flow down of obligations to subcontractors (e.g. prompt payment). The evolution of the G15 terms indicates that the UK Government may now be more focused on standardising public sector contracts than it is with aligning cloud services terms with supplier standard terms. If this trend continues and there is too great a divergence between public sector templates and supplier standard terms, we may see some suppliers start to favour indirect sales over direct. (see also: Reseller to direct: Top tips for technology suppliers to the UK public sector).

    

5. Social value and carbon reduction – Social value is now a firm fixture in public procurement, with a minimum of 10% of the evaluation of any contract award reserved for it. Winning tenders can often be separated by the tightest margins, which means that the extent to which a supplier can demonstrate its social value solutions can and will often determine the result of the procurement, rather than the technical quality of the cloud product and the price alone. Suppliers that are looking to enter the UK market should familiarise themselves with the Social Value Model, which provides guidance on the type of questions that a contracting authority may ask in a procurement process. Suppliers should also be aware of the need for the bidding entity to produce, as a condition of participation in the procurement process, a carbon reduction plan for any tenders for a contract worth over £5m (including VAT) per year, which will contain a commitment to achieving net zero by 2050, emissions footprint data, current emissions reporting, reduction targets and a requirement to publish the plan on its website.

    

If you have any questions in relation to UK public sector technology contracts, please do get in touch with Hannah Barton, Patrick Parkin or your usual Burges Salmon contact.