Central Digital Platform signals more change for public procurement 

A new central hub will change how public procurement works to make opportunities more visible and transparent, bringing additional requirements for suppliers. 

Contributors: Molly Hutchinson, Fiona Moss

After multiple changes to how public procurement works in recent years, more new regulations have been laid before parliament – and at least some of their provisions are expected to come into force on 1 April 2026. As a result, suppliers to government and public bodies will have to provide more information about their contracts.

The Procurement (Amendment) Regulations 2026 will require suppliers awarded below-threshold contracts to confirm their registration on the new Central Digital Platform and provide a unique identifier code.  

There are no new penalties for non-compliance, but there is a higher risk of challenge for not registering on the Central Digital Platform.

Suppliers will need to provide core information such as corporate identity data, contact details, and core eligibility information, while public bodies will be required to publish any payments they make over £30,000 with a view to improving public scrutiny of public spending.

Below-threshold contracts are notifiable if the value is £12,000 or greater for central government, or £30,000 or greater for contracts with other public authorities – and which are not exempt, not a concession contract, and not a utilities contract.

Suppliers to public bodies may already be familiar with the Central Digital Platform, as it has historically been the platform used to view invitations to tender, contract, and manage data relating to awards since the retirement of Contract Finder in February 2025.

Now is the time for public bodies and suppliers to such bodies to register on the new Central Digital Platform and ensure legal and procurement teams are made aware of the changes in anticipation of these amendments receiving parliamentary approval.

Key takeaways

• Register on the new Central Digital Platform.

• Brief/train staff on updated processes.

• Monitor parliamentary progress of amendments.

Changes to Agricultural Property Relief and Business Property Relief for Inheritance Tax 

April 2026 will usher in changes to the Inheritance Tax reliefs available for assets which qualify for Business Property Relief and Agricultural Property Relief. There is still plenty our experts can do to help. 

Contributors: Harriet Jones, Jon Gould, Shaun Thomas

Changes to the 100% rate of Agricultural Property Relief and Business Property Relief from Inheritance Tax take effect from 6 April 2026. 

These changes make it more important than ever to have plans in place to shield your estate from future tax liabilities. 

Here is a rundown of what you need to know. 

How are rules on Agricultural Property Relief and Business Property Relief changing?  

Currently, anyone who holds qualifying business and agricultural assets can provide for those assets to be transferred to the beneficiaries of their will – without their beneficiaries being liable to pay any Inheritance Tax upon on any such qualifying assets they inherit. 

While it was originally announced that the 100% relief would be restricted to the first £1 million from 6 April 2026, two key revisions to the proposals were announced in December 2025:

• The first £2.5 million of combined agricultural and business property will continue to receive 100% relief, with 50% relief on amounts over £2.5 million.  

• The £2.5 million allowance will be transferable between spouses – meaning that any unused allowance can be carried over to the surviving spouse’s estate, providing for an allowance of up to £5 million on the death of the second spouse. 

How will the Agricultural Property Relief and Business Property Relief changes affect you?  

If you are planning to transfer qualifying assets worth less than £2.5 million: Nothing changes – providing the qualifying assets which you are passing on do not exceed the £2.5 million threshold, your beneficiaries will not be liable to pay any Inheritance Tax on them.

If you are planning to transfer qualifying assets worth in excess of £2.5 million: While your beneficiaries will receive 100% Inheritance Tax relief on any qualifying assets up to £2.5 million, they will be liable to pay effectively 20% Inheritance Tax on any qualifying assets exceeding the threshold when the assets transfer to them.

If you are married and planning to transfer qualifying assets in excess of £2.5 million to your spouse or civil partner: Any of the £2.5 million allowance which is unused when your spouse inherits your qualifying assets is carried over to your surviving spouse’s estate – meaning that their beneficiaries could receive assets of up to £5 million without incurring Inheritance Tax liability. 

If you are unmarried and planning to transfer qualifying assets in excess of £2.5 million to your partner: The £2.5 million allowance for Inheritance Tax relief is non-transferable between unmarried couples – meaning that, while the £2.5 million allowance would apply to any qualifying assets transferred to your surviving partner as part of your estate (with any value in excess of this being liable for effectively 20% Inheritance Tax), any unused allowance cannot be carried over to their estate (meaning their beneficiaries will potentially become liable to pay Inheritance Tax).

If you are planning to gift your qualifying assets to someone in your lifetime: If you gift your qualifying assets to someone in your lifetime, they will be exempt from Inheritance Tax provided that you live for seven years after making the gift. However, if you were to pass away within seven years, the assets could then attract an Inheritance Tax liability – and, as the £2.5 million allowance applies from the point at which you made the gift during your lifetime, the allowance available for Inheritance Tax relief could potentially be reduced in cases where spousal exemption does not apply.

The changes might sound alarming, but there are plenty of options that our experts can explore with you.

When it comes to succession planning, it is never too early to start putting plans in place – and never too late to change them if the landscape shifts unexpectedly. 

The changes highlight the importance of putting succession plans in place if you have not done so already, ensuring that any pre-existing provisions you have made still reflect your wishes in light of the changes, and keeping a watchful eye on the legislative landscape to make sure it stays that way. 

Key takeaways

• Ensure you have adequate business and succession plans in place.

• Consider if you have, or could have, qualifying assets worth £2.5 million.

• Consider who you want to leave qualifying assets to in your will.

• Consider the implications of transferring to a spouse or civil partner.

ICO publishes updated guidance on international data transfers 

A long-promised update to guidance has been published by the Information Commissioner’s Office, designed to make it quicker and easier for businesses to understand their obligations when transferring data overseas.

Contributors: Meri Seiranian, Lisa Sweetman

The Information Commissioner’s Office (ICO) has finally published a long-awaited update to its international transfers guidance.  

Those familiar with this complex area of law will know that the updated guidance is long overdue, having been promised for several years. The ICO says the updated guidance is designed to make it quicker and easier for businesses to understand their obligations when transferring data overseas, while supporting responsible data flows that enable innovation and economic growth.

Key improvements include:

• Clearer content presented as standalone sections instead of one long piece of guidance, covering topics such as adequacy regulations, appropriate safeguards, completing transfer risk assessments, use of exemptions, and receiving personal information from the European Economic Area.

• A simple, three‑step test to help organisations quickly work out whether they are making a ‘restricted transfer’.

• New guidance on roles and responsibilities in complex, multilayered transfer scenarios.

• New language brought in by the Data (Use and Access) Act 2025, such as the standard required for ‘adequacy’, the standard required for ‘safeguards’, and the ‘data protection test’.

• Additional resources such as a brief guide, quick reference FAQs, and a glossary to support organisations without specialist expertise or experience in making international transfers.

The ICO reported that this update forms part of a wider ongoing project, with more updates forecast regarding transfer risk assessments, the international data transfer agreement, and cloud services involving international transfers. 

In addition, the ICO plans to add an interactive tool to help organisations assess whether a transfer is restricted and provide more examples and case studies that reflect the complexity of global transfer scenarios.

If your organisation transfers personal data outside the UK – whether making it accessible via cloud services, or transferring between overseas offices, international suppliers or other external processors – this update is likely to touch several parts of your compliance framework. The new ‘three‑step test’ clarifies when the rules apply, making it easier to identify restricted transfers early in your process. 

The introduction of the new ‘data protection test’ may require you to revisit existing assessments, as it sets a slightly different threshold from the previous EU‑style requirement of ‘essential equivalence’.

Roles and responsibilities are also more clearly defined, which matters in multi‑layered outsourcing chains where multiple processors or sub‑processors sit outside the UK. 

In addition, the ICO has raised the bar for relying on exceptions, meaning you will need to justify necessity and proportionality in order to take advantage of them. 

Overall, the update should streamline compliance in the long-term, but there will be some short-term pain for many organisations needing to update checklists, templates, and internal procedures to stay aligned.

What actions should you take?

A good starting point is to map your international data flows and apply the ICO’s ‘three‑step test’ across each one to determine which transfers fall within the restricted transfer regime. 

Next, review and update your transfer risk assessments to reflect the new ‘data protection test’ and ensure existing documentation does not reference the older ‘essential equivalence’ standard. 

Check agreements involving overseas processors and sub‑processors to make sure responsibilities are allocated correctly – especially where chains of multiple suppliers are involved.

Finally, refresh internal training so teams understand the new terminology and the updated approach to exceptions. If your organisation relies heavily on cloud services, you should monitor the ICO’s planned further guidance in this area.

While none of these changes are designed to be disruptive, failing to update outdated processes could mean transfers become non‑compliant.

Key takeaways

• Map international data follows against the ICO's three-step test.

• Review and update your transfer risk assessments.

• Check agreements involving overseas processors and sub‑processors.

• Deliver training for your teams.

Use of open-source AI in the spotlight as solicitor breaks legal privilege with ChatGPT upload 

The number of people in the UK proactively using a generative artificial intelligence (AI) tool has almost doubled in the last two years. With increased usage, comes increased risk. A simple copy-and-paste into an AI tool could turn into a data breach and result in an opponent being granted access to legally privileged documents and communications. 

Contributors: Amy Evans

In a recently-published case from the Immigration and Asylum Chamber, a solicitor typed into ChatGPT drafts of client emails explaining Home Office decisions asking the tool for improvements to them, and also uploaded Home Office decision letters to be summarised for his clients. The court confirmed that placing client documents into ChatGPT and other open-source AI tools ‘is to place this information on the internet in the public domain, and thus to breach client confidentiality and waive legal privilege’. 

This case echoes a federal decision from the United States earlier this year in which the defendant inputted information he had learned from counsel into ClaudeAI, created documents for the purpose of speaking with counsel to obtain legal advice, and subsequently shared those documents with counsel. The court held that all of these interactions with ClaudeAI, and the documents uploaded to the platform, were not subject to legal privilege and were open to the court (and the prosecutors) to view. As ClaudeAI (like ChatGPT) collects data from inputs to train its language model, the communications between the defendant and his legal advisers were no longer confidential – and, by extension, no longer privileged.  

In litigation, confidential communications between solicitors and their clients are, for the most part, protected by legal professional privilege when those communications relate to the giving or receiving of legal advice. The protection extends beyond emails to written instructions, strategic documents, and notes of advice.  

When confidentiality is waived, privilege is lost and the communications then become disclosable to the opposing party in the litigation.  

What steps should you take?

This does not mean AI should never be used when handling sensitive confidential information in litigation. Close-sourced AI tools are considered safe, as the information uploaded to them is not then placed in the public domain. It is the open-sourced AI which retains, stores and uses user inputs for model training which lacks the confidentiality and control that privilege requires. 

Sharing information in an open-sourced AI can also be a breach of an organisation’s GDPR obligations. Self-reporting to the Information Commissioner’s Office is mandatory where such a breach has occurred and should be reported within 72 hours of the data controller becoming aware of the breach.  

Key takeaways

• Never put sensitive data into open-source AI tools.  
  
  
• Organisations should ensure they have an adequate AI Acceptable Use Policy in place to make it clear when AI use is acceptable, what AI tools can be used, and what can be inputted and uploaded to AI. 
  
  
• Parties to litigation must be careful about the AI tools they use to avoid waiving legal privilege, otherwise they risk key documents becoming disclosable to their opponents. 

New enforcement powers for Office of Financial Sanctions Implementation 

The body behind UK sanctions regulation has updated its guidance on the civil enforcement of sanctions, including some significant new enforcement powers.

Contributors: Saleema Brohi, Victoria Drury 

The Office of Financial Sanctions Implementation (OFSI) is overhauling its financial enforcement framework following a consultation. 

The outcome of the consultation on improving civil enforcement processes for financial sanctions was published in January, and was followed shortly afterwards by an update to the OFSI’s guidance on 9 February 2026.  

Key changes include the reduction of the maximum voluntary discount to 30%, the introduction of a formal Early Account Scheme offering up to 20% discount for early detailed admissions, and the creation of a Structure Settlement Scheme offering up to 20% mitigation for uncontested cases.  

The OFSI will also introduce fixed monetary penalties for certain reporting and licensing breaches, and will double the statutory maximum penalty to £2 million or 100% of the breach value – whichever is greater.

For businesses, this marks a more structured and potentially more punitive enforcement landscape. Lower voluntary disclosure discounts and the higher maximum penalty significantly increase financial exposure and risk. 

The formalisation of the early engagement and settlement mechanisms provides clear incentives to engage with the OFSI to secure mitigation. Fixed penalties also allow the OFSI to address lower-level compliance failures more quickly and predictably.

What steps should you take?

Businesses should review their sanctions compliance frameworks, escalation protocols, and internal investigation capabilities. Systems should enable rapid identification and assessment of potential breaches, with clear pathways for decisions on voluntary disclosure, early account participation, and settlement.

Record-keeping and investigation capability should be robust to support timely, well-evidenced engagement with the OFSI. Senior management should also be briefed on the heightened enforcement environment and the company’s updated response approach.

Key takeaways

Review sanctions compliance and escalation.

Keep accurate records. 

Brief senior management on changes.

Government seeks views on flexible working, unions and ‘fire and rehire’ as employment law changes begin 

Alongside the first changes ushered in by the Employment Rights Act 2025, the government recently launched consultations on three key areas of the legislation to shape secondary legislation and codes of practice. 

Contributors: Clive Day, Cory Doran

The government is consulting on three areas of the Employment Rights Act 2025 (ERA) ahead of the implementation of sweeping changes to employment law.

Following the receipt of parliamentary approval in late 2025, the Act has two main implementation windows this year – in April and October – followed by a handful of other changes in 2027. 

The first of the changes have now taken effect, with the repeal of the Trade Union Act 2016 restrictions on 18 February 2026 bringing in enhanced worker protections which, for employers, could mean faster, less predictable disputes and a narrower margin for intervention.

Alongside that, the government has now launched public consultations on flexible working rights, the revised statutory code on trade union recognition and electronic balloting, and so-called ‘fire and rehire’ practices. 

Flexible working

The consultation on flexible working rights legislation will explore:

• The procedure employers must follow before refusing a request, including a requirement to meet with the employee within six weeks and provide written outcomes.

• How changes will support the ERA’s new statutory 'test of reasonableness' for rejecting a request.

• Preparatory steps for ACAS to update the statutory Code of Practice on flexible working to reflect the new reasonableness test.

Trade union recognition and electronic balloting

To align existing guidance with the forthcoming ERA provisions, the government opened a consultation on revising the Code of Practice on Trade Union Recognition and Derecognition. Another part of this consultation looks at unfair practices in respect of future electronic balloting for strike action. The draft codes address:

• Updated rules governing enhanced trade union access to workplaces both physically and digitally.

• What constitutes 'unfair practices' during recognition and derecognition campaigns.

• Measures to support the ERA reforms on statutory trade union ballots, including new balloting processes.

'Fire and rehire'

One of the more controversial areas of the Employment Rights Act is the restriction of so-called ‘fire and rehire’ practices. The consultation seeks to shape the final regulatory design and enforcement of these provisions. It focuses on: 

• Defining permissible employer conduct when seeking contractual changes.

• How far restrictions should be permitted in two potentially difficult areas: (i) shift patterns and (ii) expenses and benefits. 

• Ensuring reforms remain ‘fair and workable’ for both businesses and workers.

The consultations play an important role in tailoring the Employment Rights Act which will bring greater worker protection, increased procedural duties for employers, and a modernised industrial relations framework. Employers should stay closely engaged with consultation outcomes and prepare for staged compliance obligations extending into 2027.

Key takeaways

• Seek advice to prepare for new employment legislation.

• Be aware of care required if making changes to terms and conditions from 2027.

Major business rates revaluation looms as 1 April 2026 approaches 

A shake-up to business rates could bring a significant impact for landlords and tenants as the rateable values used to calculate a non-domestic premises’ rates liability change.

Contributors: Amy Evans

On 1 April 2026, a major business rates revaluation is being implemented, with changes to business rates multipliers and available reliefs.

The majority of rateable values are calculated by reference to market rent. Those businesses which have benefited from strong demand and rental growth since the last revaluation three years ago will therefore see the biggest increase. Industrial and manufacturing businesses are among the most impacted sectors, with warehouses, factories and distribution centres being disproportionately affected.

New, lower tax rates are being introduced for eligible retail, hospitality and leisure properties with a rateable value of less than £500,000. This is being funded by a new, higher tax rate on premises with rateable values of £500,000 and above – resulting in an end to the temporary relief previously applied to retail, hospitality and leisure premises.

It is good news for those premises who currently benefit from Small Business Rates Relief, as this will continue to be available for at least the next three years.

For businesses facing a large increase in bills following the revaluation, the government has set up a Transitional Relief scheme worth £3.2 billion. This will set caps on annual increases linked to a percentage of the increase and inflation over the next three years. The level of the cap depends on the rateable value of the premises. The cap will be automatic, and will be funded partly via a 1p supplement for businesses who are not eligible for the relief.

Rateable values are not just used to calculate business rates – they are also used to calculate the value of compensation that may be available to tenants when landlords oppose a renewal lease under the Landlord and Tenant Act 1954.

What steps should you take?

Where leases are due to expire within the next 12 months, landlords should review the current and future rateable values when determining when to serve notice under section 25 of the Landlord and Tenant Act 1954 opposing renewal. The amount of compensation which may be payable is linked to the date a landlord serves notice, or a counter-notice. Where rates are about to increase, the clock is ticking for landlords considering redevelopment or taking back possession for their own occupation to minimise the compensation payable.

Key takeaways

• Businesses can check their new rateable values for any premises they own now.
  
  
• For those eligible, no action is needed for businesses to benefit from the new Transitional Relief Scheme.
  
  
• For landlords looking to oppose a lease renewal, review the changes now to minimise compensation payable.