Preparing for the refreshed Queensland Procurement Policy 2026
29 January 2026
What you need to know
- As of 1 January 2026, the Queensland Procurement Policy 2026 (QPP 2026) is the Queensland Government's new overarching policy for the procurement of goods and services, and will replace the Queensland Procurement Policy 2023 (QPP 2023).
- QPP 2026 has undertaken “the biggest overhaul of procurement policies in decades” by reducing the ‘red tape’ that inhibited many businesses from getting a slice of the billions of dollars spent by the public sector on procurement.
- One of the five pillars under QPP 2026 focuses on the simplification of the procurement process to make it easier to do business with the Queensland Government.
- With this simplification, comes the removal of the Ethical Supplier Threshold and the Ethical Supplier Mandate, both of which were core concepts under QPP 2023. Rather than a prescriptive regime detailing the management of failures by the supplier to uphold QPP 2023, tender or contractual requirements, there is a shift towards an incentive-based scheme under the new Procurement Assurance Model (PAM).
What you need to do
- An ‘agency’ caught by QPP 2026 should review existing arrangements to consider whether there is sufficient contractual coverage to satisfy the renewed requirements and amend its invitation and contract documentation going forward to align with the requirements under QPP 2026.
- Suppliers intending to do business with the Queensland Government should get familiar with the simplified procurement process, and in particular, understand the three core interlinked assurance systems under PAM.
Queensland’s new procurement policy
Changes at a high-level
On 11 November 2025, the Queensland Government released QPP 2026 to replace QPP 2023. QPP 2026 is centred around five pillars.
QPP 2026 seeks to be a “transformational new framework” by making it easier to do business with the Queensland Government, opening doors for small and family businesses, developing more opportunities, transparency and value. At a high-level, the key changes stemming from some of the five pillars include:
- Value for Queensland – strengthening transparency and accountability through the Queensland Government Procurement Spend Portal (which is a public facing, interactive report that displays high-level government spend) and publishing category strategies on how the Queensland Government spends its money by 31 March each year. A live version of the portal is now accessible here.
- Easy to do business – expecting information to be requested from suppliers ‘just in time’ during tender evaluation processes rather than frontloading every requirement and simplifying procurement processes by publishing streamlined invitation and contract documentation for each procurement category by 31 December 2026 (refer to the ‘Revamping template documentation’ section below more information).
- Practical, economic, environmental and social impact – introducing the PAM as an incentive-driven scheme to support accountability for suppliers’ adherence to the Queensland Government Supplier Code of Conduct 2026 (SCC 2026) as well as economic and social impact commitments (refer to the ‘Transitioning to an assurance model’ section below for more information).
As part of QPP 2026, the Queensland Procurement Policy Reporting Framework (QPPRF) has also been developed and defines the data to be collected, the format in which it is collected and how the data will be used to generate insights to support reporting against QPP 2026. The QPPRF will deliver several analyses and reports including the Queensland Government Procurement Spend Portal, Ministerial dashboard and Queensland Government Procurement Committee dashboard to outline metrics against targets, and category dashboards for more tailored data.
Government agencies are required to apply the ‘Queensland Procurement Rules’ detailed under Part 2 of QPP 2026 (the Rules) and the PAM under Part 3 of QPP 2026 to deliver the new strategy. All parts of QPP 2026 commenced on 1 January 2026, with the exception of the PAM incentive scheme, which commences on 1 January 2027.
Revamping template documentation
As part of the third pillar under QPP 2026, which focuses on simplifying access to procurement opportunities, the Queensland Government is set to publish streamlined invitation and contract documentation for each procurement category by 31 December 2026.
Under QPP 2023, the Queensland Government has only published template documentation in relation to the procurement categories indicated with a tick below.
| Procurement category | Templates |
| Building Construction and Maintenance (Department of Housing and Public Works) | Yes1 |
| General Goods and Services (Department of Housing and Public Works) | Yes2 |
| Information and Communication Technology (Department of Customer Services, Open Data and Small and Family Business) | Yes3 |
| Medical Goods and Services (Queensland Health) | No* |
| Social Services (Department of Families, Seniors, Disability Services and Child Safety) | Yes4 |
| Transport Infrastructure and Services (Department of Transport and Main Roads) | No* |
| * Since QPP 2026 states that streamlined invitation and contract documentation will be published for each procurement category, we expect to see new templates for Medical Goods and Services and Transport Infrastructure and Services prior to 31 December 2026. | |
As we await the updated and new template documentation, it is important to also consider the changes in QPP 2026 with respect to mandatory provisions under invitation and contract documentation (refer to the ‘Invitation and contract documentation requirements’ section below for more information) – there has been a radical simplification.
Transitioning to an assurance model
Under QPP 2023, the Ethical Supplier Mandate outlined how the Queensland Government is to navigate instances where a supplier fails to uphold a policy, tender or contractual requirement. The Ethical Supplier Mandate is extensively prescriptive on applicable categories of non-compliance and its corresponding demerit points. Obligations were further imposed on relevant agencies to not engage any suppliers that have been suspended under the Ethical Supplier Mandate.
With the new procurement policy, the Ethical Supplier Mandate will transition to a new mechanism to support accountability for suppliers’ adherence to SCC 2026, as well as economic and social impact commitments. This framework is named the Procurement Assurance Model (PAM). PAM shifts the focus towards incentive-based assurance. The Queensland Government Procurement Assurance Branch (PAB) (formerly the Queensland Government Procurement Compliance Branch) will apply the PAM to manage supplier commitments going forward.
PAM aims to uphold ethical suppliers and ethical supply standards through three assurance mechanisms:
- Incentive scheme – commencing 1 January 2027. Its purpose is to incentivise high-performing and ethical suppliers. The exact centralised verification system that is independent from self-reporting by suppliers is still subject to detailed stakeholder consultation and design work. At this stage, QPP 2026 contemplates that there will be a business intelligence system that scans public regulator outcomes to ensure that a minimum standard of adherence to SCC 2026 is achieved. Accreditation under this scheme is non-mandatory and not a pre-requisite to tender for Queensland Government work.
- Capability building – the first phase of capability resources are to be available from 1 January 2026 and there are more initiatives to follow. There are both proactive and reactive forms of capability building, with the latter form being mandatory. Reactive capability building is the intended replacement for default penalties for low and moderate non-compliance. Generally, the purpose is to provide training, either preventatively or in a manner to address identified gaps, to improve ethical supply practices.
- Accountability – implementation of the accountability system commenced on 1 January 2026. Presently, QPP 2026 does not provide any additional detail under this limb. Whilst this is listed as a separate limb to the PAM, the focus appears to be placed on the prioritisation of other elements mentioned in the PAM including capability building.
Invitation and contract documentation requirements
Those in business with the Queensland Government are familiar with the prescriptive requirements imposed under QPP 2023 that are then expressly included in invitation and contract documentation.
An overview of the changes of such requirements between QPP 2023 and QPP 2026 are outlined below.
| Element | QPP 2023 | QPP 2026 | Relevant changes |
| Ethical Supplier Threshold | Yes | No | The Ethical Supplier Threshold is no longer implemented in the QPP 2026 and ceased to be in effect on 31 December 2025. Both invitation and contract documentation required certain declarations by, and conditions imposed on, the supplier as a precondition to doing business with the Queensland Government. In particular, QPP 2023 provided a prescriptive list of conduct that the supplier must not have engaged in to be considered for the procurement opportunity (referred to as the “Ethical Supplier Threshold”). The Ethical Supplier Threshold outlined set wage and entitlement standards. Under QPP 2026, the concept of the Ethical Supplier Threshold, and any obligation for declarations and conditions in relation to the Ethical Supplier Threshold in invitation and contract documentation, has been removed. The Ethical Supplier Threshold remained in place up until 31 December 2025 with no equivalent concept introduced under QPP 2026. |
| Queensland Government Supplier Code of Conduct | Yes | Yes | QPP 2026 still imposes the same requirements for invitation and contract documentation to include declarations and conditions for supplier compliance with the SCC 2026. However, it does take it one step further with respect to breaches of SCC 2026. Going further than the existing requirement for suppliers to warrant adherence to and a condition requiring supplier compliance with SCC 2026, QPP 2026 also requires the contract documentation to specify that a breach of SCC 2026 is a breach of the contract itself. Along with a new procurement policy, a new SCC 2026 has also been published to replace its predecessor. |
| Dumped Goods | Yes | No | Whilst QPP 2026 still contains the definition for dumped goods, there is no corresponding use of such term. |
| Commitment to prevent and end domestic and family violence | Yes | No | QPP 2026 does not contain any requirement that invitation documentation must expressly reference a commitment to prevent and end domestic and family violence. |
| Information and cyber security risks | No | Yes | The Queensland Government seems to have reflected its concern to the rise of cyber security incidents in Australia through the introduction of a new requirement under QPP 2026. Contract documentation is required to include appropriate clauses to manage information and cyber security risks. Whilst the exact form or content of these clauses has not been provided, we suspect there will be an expectation for baseline protections over both information and cyber security commensurate to the nature and value of the procurement in question, and in particular, the types of information being handled by the supplier. |
What does this mean for you?
The updated policy reinvents the framework for public procurement by empowering new ways of doing business with the Queensland Government.
As a supplier wishing to get one foot into the door of public procurement – opportunity knocks. The process has been vastly simplified to maximise opportunities and push those along to small and family businesses. In addition to understanding the requirements under the new SCC 2026, suppliers should also keep an eye out for any communications around the still-developing incentive scheme that is set to commence in 2027 and the capability building streams available to help support ethical supply practices and processes.
It goes without saying that agencies caught by QPP 2026 will need to get familiar with the five pillars and the Rules. To reflect the changes between the two procurement policies, agencies should revisit their template invitation and contract documentation to assess whether any changes need to be made to align the documentation with the new requirements. There should be conversations around the adequacy of existing information and cyber security clauses proportionate to the value and risk involved with the procurement at hand. For agencies in procurement categories without template documentation, stay alert to monitor any relevant communications from category lead agencies to understand when new contract templates will be developed, approved by the Minister and rolled out.
Noting the already sizeable change to the length of the procurement policy as against its predecessor, the Department of Housing and Public Works has demonstrated an intention to further develop requirements relating to the enforcement of the regime. Agencies and suppliers should both remain aware of any developments in this space.
Want to know more?
- Queensland Procurement Policy 2026 (November 2025)
- Queensland Government Supplier Code of Conduct 2026 (November 2025)
Authors: Christina Zhang, Lawyer
- As at 12 January 2026, the suite of BCM standard contract templates has been updated to implement the Queensland Procurement Policy 2026 and are for use from 1 January 2026. See the Queensland Government webpage titled ‘Government building construction and maintenance standard contracts’ for more information: https://www.forgov.qld.gov.au/finance-procurement-and-travel/procurement/buy-for-queensland-government/buying-categories/building-construction-and-maintenance/bcm-contract-selection-management-and-advice/bcm-contracts-templates.
- As at 12 January 2026, some General Goods and Services (GGS) terms and conditions and templates have been updated. A total review of the GGS templates and terms and conditions will be released late 2026. See the Queensland Government webpage titled ‘General goods and services – templates’ for more information: https://www.forgov.qld.gov.au/finance-procurement-and-travel/procurement/procurement-resources/templates-including-terms-and-conditions/general-goods-and-services-templates.
- As at 12 January 2026, the Queensland Government has not specified that it will revisit the ICT contract templates to align with QPP 2026. The webpage still notes that the QITC documents are updated to reflect the Ethical Supplier Threshold. See the Queensland Government webpage titled ‘Create an ICT contract’ for more information: https://www.forgov.qld.gov.au/finance-procurement-and-travel/procurement/buy-for-queensland-government/buying-categories/ict-products-and-services/create-an-ict-contract.
- As at 12 January 2026, the Queensland Government is reviewing the content to align with QPP 2026. See the Queensland Government webpage titled ‘Social services – templates’ for more information: https://www.forgov.qld.gov.au/finance-procurement-and-travel/procurement/procurement-resources/templates-including-terms-and-conditions/social-services-templates.
