Transparency in the use of artificial intelligence (AI) is being enforced in UK procurement, as AI use becomes increasingly present in our procurement practices
Transparency upholds accountability, builds trust and reduces the risk of inaccuracies. By using AI systems and tools, bidders can streamline the tender process, liberating time to focus on crafting responses to produce winning submissions. While AI offers remarkable efficiencies, transparency in its application is critical. In this article, we discuss the need for transparency when using AI in procurement and guidance to achieve transparent AI use.
AI in procurement
The use of AI in procurement has evolved significantly, with applications ranging from early tools such as spelling and grammar checkers in Microsoft Word to more advanced large language models (LLMs), which help to generate content.
Today, AI is increasingly adopted in procurement practices to enhance bid development, supporting tasks such as information extraction, answer planning, and automated decision-making. These applications deliver notable benefits, including faster outputs/deliverables early in the bid process and reduced human error in information extraction of large documents. As AI becomes more integrated into procurement, there is a requirement for clear communication around its role and limits.
Exploring the current focus on transparent AI use in procurement
Transparency in the use of AI enables the commissioning client to understand the extent to which AI tools have been used in procurement processes. Without it, risks such as biased outcomes, misuse of sensitive data and diminished accountability may arise. Opaque systems may erode trust and compromise the integrity of procurement processes. Transparency in AI has become best practice for fostering confidence among contracting authorities, bidders and consultancies as the industry acclimatises to AI integration. Prioritisation of transparent AI use will continue to be important while attitudes adapt, acting as a mechanism to uphold accountability and informed decision-making during the transitional period.
AI disclosures
AI disclosure questions in tender documents and AI disclosure clauses in contracts are two solutions to concerns surrounding AI transparency. These disclosures provide a structured way for us and our clients to declare the extent to which AI has been used in each bid.
These disclosures reassure contracting authorities that procurement activities remain fair, ethical and accountable, while mitigating risks of misuse or misunderstanding. Increasingly, contracting authorities are embedding transparency questions into tender documentation, signalling a shift toward formalised expectations.
We are currently at a pivotal point at which the evolution of legal disclosure regulations must be closely monitored by all involved in the procurement process. As these frameworks solidify, it is essential to understand the regulatory foundations driving this shift.
Regulatory considerations
Transparency in AI in procurement is increasingly mandated by regulations and ethical standards. A Procurement Policy Note (PPN) on the use of AI in tenders was published in March 2024 (PPN 02/24: Improving Transparency of AI Use in Procurement), with a revised version published in February 2025 following the implementation of the Procurement Act 2023 and the Procurement Regulations 2024. In PPN 017: Improving transparency of AI use in procurement it is stated that:
“There are potential benefits to suppliers using AI to develop their bids, enabling them to bid for a greater number of public contracts. It is important to note suppliers’ use of AI is not prohibited during the commercial process, but steps should be taken to understand the risks associated with the use of AI tools in this content, as would be the case if a bid writer has been used by the supplier.”
Government guidance aligns the interrogation of AI used for bid writing to that of any ‘risks’ there may be regarding a human bid writer, for example, elevated tender submissions. Here, there is a connection made between using AI and using external bid writers to craft responses. This analogy aligns the treatment of AI use with conventional practices.
AI in its current form, however, is not as flexible or able to engage in real-time discussions during the tender evaluation process. Unlike human consultants, AI lacks the capacity for real-time interaction and clarification during the tendering process and tailored strategic writing when crafting responses. This difference is influencing the due diligence process as contracting authorities are proactively requesting transparency from clients through AI disclosures.
Why is transparency important to contracting authorities?
It is important for contracting authorities to know if there has been the use of AI in the creation of a tender submission.
AI disclosures support contracting authorities in carrying out the due diligence required to ensure the integrity of tenders in the age of AI. If our clients use AI to help craft their tender submissions, contracting authorities may want to undertake additional due diligence to confirm their capacity and capability to meet contract requirements. The level of due diligence should be proportionate to the specific risks associated with the use of AI and could involve activities such as site visits, additional clarification questions, supporting documents or supplier presentations. This process would be carried out to ensure suppliers can reliably deliver on their commitments and is consistent with how authorities typically address any potential issues in tender submissions. See PPN 017 for more detailed information on due diligence practices.
By asking bidders to disclose AI used in tender preparation, contracting authorities can inform their review process accordingly and manage associated risks. These risks relate to data privacy/confidentiality; intellectual property; bias/fairness; transparency; accountability; quality; legislative compliance; and reputation.
A guide for transparent AI use in bidding (in line with PPN 017)
The following best practice will apply for contracting authorities seeking AI transparency in procurement:
- include non-scored AI disclosure questions in pre-qualification questionnaires (PQQ) and invitation to tender (ITT)
- conduct proportionate due diligence to verify bidder credibility and capacity
- allocate time and resource to address AI-related bid clarification questions during procurement
- collaborate with internal teams to enhance understanding of AI and discolsure requests
- recognise AI is likely to play an increasingly significant role in public procurement and adopt an open, balanced and informed approach
- update practices as understanding of and attitudes towards AI evolve.
We recommend the following actions for our clients to enhance transparency in AI use:
- provide clear, honest answers to scored and non-scored AI disclosure questions in PQQs and ITTs
- maintain transparent records of AI platforms and tools used to support due diligence reviews
- submit bid clarification questions to the commissioning client when AI-related questions/requirements are unclear
- actively participate in discussions with your procurement teams to address AI-related queries and concerns, for example what AI can and cannot be used for during the tender
- invest in training to ensure procurement teams understand AI and its potential risks and benefits.
Conclusion
As AI becomes embedded in the procurement process, its use will shift from being a novelty to a business-as-usual aspect of efficient bid development. From our experience, this transition is already well under way. By openly disclosing the use of AI tools and following regulatory guidance, all stakeholders – clients, consultants, and contracting authorities – can remain confident in an open and fair procurement process. AI disclosures exemplify how UK procurement authorities are proactively adapting to emerging technologies (alongside other industries), representing a commitment to maintaining responsible and accountable procurement practices.