Does the UK Procurement Act 2023 Change Language Rules for Defence Bids

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Counsel reviewing defence procurement documents at a desk

No. The UK Procurement Act 2023, in force since 24 February 2025, changed how defence contracts are advertised and awarded, not the language a bid is written in. A UK defence tender still runs in English, and the Act adds no requirement to translate your bid into another language. What it retired is the Defence and Security Public Contracts Regulations 2011 (DSPCR 2011), the transparency route through Tenders Electronic Daily (TED), and the old notice system, replacing them with the Central Digital Platform and Find a Tender.

AD VERBUM is an EU-hosted AI+HUMAN hybrid translation company that pairs a client-tuned LLM with certified defence linguists for tender documentation, under AQAP 2110 and ISO 27001. We translate defence bids in both directions: foreign documentation into English for UK procurements, and English source into the national languages that EU procurement law still requires.

The reform matters most for suppliers who cross a border. Bid into the UK from another country, or bid from the UK into an EU member state, and the language obligation sits outside the Act, in the procurement law of the buyer's country. Our guide to defence tender translation under Directive 2009/81/EC covers the EU side in full.

What the Procurement Act 2023 actually changed

The Act took effect on 24 February 2025 and pulled most UK public procurement into one regime. For defence it replaced the DSPCR 2011, which had transposed the EU defence procurement directive into UK law and stayed on the books as retained EU law after Brexit. From that date the DSPCR guidance is no longer maintained and must not be applied to new procurements, as the House of Commons Library briefing sets out.

Section 7 of the Act defines a defence and security contract, and the definition is broader than the one in the DSPCR. Notices now publish through the Central Digital Platform and surface on Find a Tender, which replaced TED in the UK on 31 December 2020. There is no publication into all 24 EU official languages the way TED works. A UK notice appears in English, and the Central Digital Platform went live with the Act on 24 February 2025.

Researchers comparing bid document context during translation review

What language a UK defence bid must be in

In practice, a UK contracting authority runs its procurement in English. The Procurement Regulations 2024 require each tender notice to state the languages in which a tender may be submitted, so the permitted language is set per procurement rather than by a blanket rule. In Wales a buyer may also run in Welsh. For most UK defence work the language is English.

That does not remove translation from the deal. It moves it to the edges, where a document crosses a border:

a foreign prime or subcontractor bidding into the UK needs its technical documentation, certificates, and quality records in English before submission
a UK supplier bidding into an EU member state needs the bid in that state's national language, because Directive 2009/81/EC leaves the tender language to national law
consortium documentation shared across borders, such as a NATO codification file or an inter-company agreement, needs consistent terminology in each partner's language
security and personnel records that support a bid often have to match the language of the vetting authority that reads them

Our list of defence tender documents that need certified national-language translation sets out which of these carry a certification requirement and which do not.

Why the Act does not touch your cross-border translation duty

The Procurement Act 2023 is UK law for UK buyers. It cannot change what an EU member state asks of a bid submitted to its own defence ministry. Directive 2009/81/EC still governs defence and sensitive-security procurement across the EU, and it leaves the procedure language to each country, so a bid into France, Germany, or Poland follows French, German, or Polish rules, not the Act.

For UK suppliers this is the practical shift. Before Brexit a UK firm found EU defence notices on TED, in one familiar system. Now the EU market runs on TED and national portals, the UK market runs on Find a Tender, and a cross-border bid means working two procurement systems and two languages at once. Our guide to running a defence bid across TED, Find a Tender, and Prozorro walks through the mechanics.

Compliance specialists reviewing translated tender records

The dual-use trap the reform leaves in place

One risk survives every procurement reform on both sides of the Channel. Sending controlled technical data to a translator can itself be a regulated transfer. Under Regulation (EU) 2021/821 Article 2, technical assistance includes transmitting controlled technology by electronic means, so emailing a controlled manual to an unvetted linguist in another country can count as an unlicensed transfer. National authorities enforce it: BAFA in Germany, the DGA and national services in France, and UAMA in Italy.

The buyer's procurement rules do not shield you from this. A defence bid that includes controlled specifications needs a translation supplier that handles the data inside a controlled environment, with vetted linguists and no public-cloud transit. Our explainer on whether sending a technical manual to a translator breaches EU dual-use rules covers the trigger in detail.

What to require of a defence translation supplier

The Act rewired the paperwork, not the standard your documentation has to meet. When you choose who translates a defence bid, the criteria that matter are the ones AD VERBUM is built around:

AQAP 2110 quality assurance, so translation output carries the traceability and configuration control NATO-bound documentation expects. AD VERBUM is certified to AQAP 2110 by Bureau Veritas
ISO 27001 information security with EU-hosted infrastructure and no public-cloud processing, so controlled technical data stays inside a controlled environment, backed by secure enterprise workflows rather than an NDA alone
certified linguists under ISO 17100, with nationality vetting where a contract requires it and independent revision on every file
coverage in both directions, English for UK bids and the national languages Directive 2009/81/EC requires, across 150+ languages with 3,500+ subject-matter linguists

We track procurement across 31 EEA markets and Switzerland through our Defence Monitor platform, so the bid team sees the notice and its language requirement together, in time to act on both.

Our defence translation services

Our translation services for regulated sectors run on ISO 27001 and ISO 42001 certified, EU-hosted infrastructure, with no reliance on public cloud tooling for core processing. Every project runs through our AI+HUMAN hybrid workflow: we ingest client Translation Memories and Term Bases first, our proprietary LLM-based LangOps System generates output constrained by client terminology on client-tuned open-weight models, and our certified subject-matter experts review for technical accuracy and regulatory compliance. Our QA is aligned to ISO 17100 and ISO 18587, with sector-specific requirements such as AQAP 2110 quality assurance and Regulation 2021/821 controlled-data handling applied where relevant. We serve Life Sciences, Legal, Finance, Defense, and Manufacturing clients across 150+ languages with 3,500+ subject-matter linguists. For teams managing audit-sensitive content, contact us to discuss your security and compliance requirements directly.

FAQ

Does the Procurement Act 2023 require you to translate a defence bid?

No. The Act changed the UK procurement regime from 24 February 2025 and replaced the DSPCR 2011, but a UK defence tender runs in English and the Act adds no translation duty. Cross-border language rules sit in the buyer's national law, and under Directive 2009/81/EC across the EU.

What replaced the DSPCR 2011 for defence contracts?

The Procurement Act 2023, in force 24 February 2025. Its Section 7 now defines defence and security contracts, more broadly than the DSPCR did, and the older DSPCR guidance is no longer maintained for new procurements.

In what language must a UK defence tender be submitted?

English in practice. The Procurement Regulations 2024 require each notice to state the languages a tender may be submitted in, so the permitted language is set per procurement. In Wales a buyer may also run in Welsh.

Does the Act change EU defence bid language rules?

No. Directive 2009/81/EC still governs EU defence procurement and leaves the tender language to each member state, so a UK supplier bidding into the EU follows that country's language, not the Act.

Is sending a controlled defence manual to a translator still a risk after the reform?

Yes. Regulation (EU) 2021/821 Article 2 treats electronic transmission of controlled technology as a transfer, enforced by BAFA, the DGA, and UAMA. Use a supplier with vetted linguists, EU-hosted infrastructure, and no public-cloud transit.

Who should translate a UK or EU defence bid?

A supplier certified for defence work. AD VERBUM translates defence bids under AQAP 2110 and ISO 27001 on EU-hosted infrastructure, in both English and the national languages Directive 2009/81/EC requires, with certified linguists and independent revision.