Annual compliance report 2019
This report presents a commentary from our review of the report submissions made by contractors for the procurement of military goods, works and services.
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The regulatory framework for single source defence contracts was introduced by Part 2 of the Defence Reform Act 2014 (the Act) and the Single Source Contract Regulations 2014 (the Regulations). It requires contractors to submit a range of statutory reports to the MOD and the SSRO.
The SSRO’s Annual Compliance Report brings together our work in respect of:
- reviewing the extent to which persons subject to reporting requirements are complying with them, as required by section 36(2) of the Act; and
- considering any implications for the provision of the regulatory framework established by Part 2 of the Act and the Regulations, which we are required to keep under review by section 39(1) of the Act.
The report presents the issues that have been identified, the key resulting messages, and the actions taken or that need to be taken. It follows our review of submissions made for QDCs and QSCs entered into between 1 April 2015 and 31 March 2019.
During the period covered by the report, we worked to introduce further automatic validation into our Defence Contract Analysis and Reporting System (DefCARS), meaning that contractors are able to address issues before making a report submission and we hope the introduction of a third set of validation rules in May 2019 will continue this positive trend. We have also improved the way data is collected through DefCARS by introducing a ‘potential QDC/QSC’ facility to help contractors commence their reporting obligations before a contract is entered into and by developing a training environment to support internal DefCARS training by contractors.
As part of our move to a more risk-based approach to compliance monitoring, we have carried out targeted reviews of two initial report submissions and this work provided insight into how the regulatory framework and the MOD’s internal procedures were being applied. We intend to continue with targeted reviews during 2019/20.
We are currently undertaking a formal review of our compliance methodology. Any update to the methodology will be subject to public consultation in the Autumn and the current timetable is for publication of any revised compliance methodology by 31 January 2020, with implementation from 1 April 2020.