A £120bn framework is a hunting licence, not a contract

The Government Commercial Agency published the full lot structure and supplier list for RM6378 last week, and the press releases have followed in a predictable stream.

Sodexo has “secured an eight-year place”. Amey is “named as supplier” on three of four lots.

Kier is “on the framework”. The Keyholding Company has “secured a place”. Each announcement leans on the same number: a spending ceiling of £120 billion, the largest FM procurement vehicle the UK has ever assembled.

It sounds like a win. It is not, or at least not yet.

A framework ceiling is permission to spend, not a commitment to spend. It represents the maximum aggregate value of call-offs that could theoretically be placed through the vehicle over its life. Actual spend through every previous CCS FM framework has run far below the headline, and the history of those frameworks says a significant proportion of appointed suppliers never win a meaningful call-off at all.

A place on RM6378 is a licence to hunt. The hunting still has to be done.

Why the announcements matter less than they look

Framework appointment is a two-stage evaluation: a selection questionnaire that filters on financial standing, insurance and basic capability, then a quality-and-price assessment that scores written submissions. The suppliers who pass are the suppliers who write well, carry the right accreditations and can absorb a bid cost that industry analysts put at £30,000 to £70,000 for a mid-market business. None of that tests delivery.

Delivery is tested at call-off, and this is where the model quietly changes character. Many call-offs are awarded on price with a pass/fail quality gate. A meaningful number are direct awards with no competition at all. The detailed quality answers that earned a supplier its framework place are not reassessed when a department actually buys something. So the framework rewards prose, and the call-off rewards price, and neither reliably rewards the supplier who would run the building best.

For a client, the practical reading is this: a supplier’s presence on RM6378 tells you they cleared a compliance bar. It tells you almost nothing about whether they are the right partner for your estate, and it should not shorten your own due diligence by a single day.

The bundle nobody asked for

The more consequential change in RM6378 is structural. For the first time, FM and security sit under one framework. Previous iterations kept them apart: RM6232 for workplace and FM services, RM6257 for security. Merging them is presented as simplification for buyers, and in narrow administrative terms it is. One route, one set of terms, one call-off process.

But the gravitational pull of a merged scope is towards a single integrated provider holding both the FM and the security contract for an estate. That favours the handful of national operators with the breadth to bid across every lot: Mitie, ISS, Sodexo, Serco, Equans, CBRE, OCS and their peers.

It disadvantages the specialist security firm or the regional hard-services contractor whose model does not fit a Total FM lot, however good they are at what they do.

And it concentrates operational risk. If one provider holds both services on a government estate and fails, the impact is compounded, not contained.

This is happening in the same year that OCS is buying Mitie for £3.1 billion, a deal that will, if cleared, put a single group in control of a very large share of the contracts this framework is designed to route. The market is consolidating on the supply side while the procurement vehicle is consolidating on the demand side.

Nobody has fully audited what that combination does to competition in three or four years’ time.

The question the framework cannot answer

There is one more reason to treat last week’s announcements with restraint. From 1 April 2027, PPN 024 requires central government departments, executive agencies and non-departmental public bodies to apply a Public Interest Test before any new service procurement or re-procurement worth more than £1 million goes to market.

The Test asks whether the service should be insourced before it asks which supplier should win it.

The guidance is explicit that establishing a framework does not itself trigger a Test, but an individual call-off above the threshold normally does, unless the service was tested when the framework was set up.

Whether departments discharge that obligation at framework level or at requirement level is, as Baachu Rain has pointed out, arguably the most consequential unresolved question in the policy. If Tests are applied requirement by requirement, a proportion of the RM6378 pipeline will never reach the market in its current form, because the department will decide to bring cleaning, or security, or workplace management back in-house first.

Analysts have already mapped roughly £1.75 billion of annual central government FM value with end dates that fall inside the Test’s early years.

The suppliers celebrating their framework places this week are, in many cases, the incumbents on those very contracts.

Their next renewal may involve defending not just their price against a competitor but the principle of outsourcing itself.

What buyers should actually do

None of this makes RM6378 a bad vehicle. It is a legitimate, compliant route to market and for many public bodies it will be the sensible default.

But the framework’s bundled lot structure should not be allowed to make your sourcing decision for you.

Before using an integrated lot, decide whether integration is right for your estate. A Total FM call-off is easy to procure and hard to unpick; a single-service or multi-service structure takes more contract management and gives you far more leverage when a provider underperforms. The framework offers both routes. The announcements only ever mention one.

We have written before about how to choose between TFM, IFM and single-service models, and the analysis applies with more force, not less, when a procurement vehicle is nudging you towards the bundle.

A place on a £120bn framework is a hunting licence. The contracts, the performance and the risk are all still to be decided, one call-off at a time. Treat the press releases accordingly.