Welsh contracting authorities have been told to prepare for a year‑end rule change. The Senedd has approved regulations updating Schedule 9 of the Procurement Act 2023 so suppliers from Iraq and Kazakhstan are recognised as treaty state suppliers under Welsh law, with the instrument made on 17 December and due to take effect on 31 December 2025.

Speaking in the Chamber on 16 December, Cabinet Secretary for Finance and Welsh Language Mark Drakeford said the update ensures Iraqi and Kazakh suppliers must be treated in line with the new agreements, with reciprocal access for Welsh exporters. He added the change “strengthens our compliance with international commitments.”

In practice, treaty state supplier status means no discrimination in covered procurements. Guidance from the Welsh Government and the UK Cabinet Office confirms such suppliers have the same rights and access to remedies as UK suppliers, where the relevant agreement applies.

Which deals are being implemented? The UK–Iraq Partnership and Cooperation Agreement was signed in London on 14 January 2025, and the UK–Kazakhstan Strategic Partnership and Cooperation Agreement was signed in Astana on 24 April 2024. Both include procurement chapters and replace EU‑era arrangements that no longer applied to the UK after Brexit.

For buyers in Wales, the update removes lingering ambiguity by aligning Welsh‑regulated procurements with the UK’s treaty obligations. Put simply: when a contract is within scope of either agreement, councils, health boards and national bodies must give Iraqi and Kazakh suppliers the same opportunities as UK firms.

Not everything flips overnight. The Welsh regulations include transitional provisions so procurements already started before the relevant agreement takes effect are not caught if a tender or transparency notice has been published, a below‑threshold notice issued, or a below‑threshold award process has already begun. A Senedd committee also noted a technical point about the definition of “below‑threshold contract”, which Ministers plan to address in early 2026.

Timing matters. The procurement chapters in the two treaties only apply once those treaties are in force. At UK level, the parallel instrument implementing the same treaty list for England and reserved procurements comes into force on 30 December 2025; Wales follows immediately after.

For firms in North Wales and the North West that sell into the Welsh public sector-or hope to compete in Iraq or Kazakhstan-the change is about eligibility and access, not guaranteed awards. Covered procurements must be open on a non‑discriminatory basis, with enforceable rights if a buyer falls short; some sectors (such as health, R&D and broadcasting) may be exempt in the market‑access schedules.

As Mr Drakeford put it, the new regime is about “shifting it from a process that is simply cost driven to one that actively supports inclusive economic growth, fair work and environmental responsibility.” Procurement leads should refresh templates and training on treaty‑state access, record when each process started, and double‑check whether the contract is actually covered by the market‑access schedules in the two agreements.