Payment Practices Reporting at Nine: How the April 2025 Threshold Uplift Quietly Shrank Britain's Slow-Pay Register

Eight years and ten months into Britain's mandatory payment-practices disclosure regime, the population required to publish it has just contracted. The Reporting on Payment Practices and Performance Regulations 2017 — the Statutory Instrument that forces large UK companies and large LLPs to file half-yearly returns on how long they take to pay their suppliers — is tethered to the Companies Act 2006 definition of large. When the Department for Business and Trade laid The Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 (SI 2024/1303), it lifted the audit and accounts thresholds by roughly 50% to track inflation. What it did not advertise loudly is that the payment-practices reporting threshold moved with them. For financial years beginning on or after 6 April 2025, several thousand companies have stepped out of the disclosure perimeter.

This piece works through what the 2017 regime actually requires, how the April 2025 threshold uplift reshapes the reporting population, what nine years of data reveal about Britain's payment culture, and where the long-promised statutory review now sits.

What the 2017 Regulations actually require

The Reporting on Payment Practices and Performance Regulations 2017 (SI 2017/395) and the parallel LLP version (SI 2017/425) came into force on 6 April 2017, following years of pressure from Federation of Small Businesses lobbying and the experience of the voluntary Prompt Payment Code. Where Section 172 statements live in the directors' report at Companies House, payment-practices reports live somewhere else entirely: the dedicated government service at check-when-businesses-pay-invoices.service.gov.uk. They are filed every six months, within 30 days of the half-year end, and they must be approved by a named director before submission.

The content is prescriptive. Each report must include, for the reporting period:

• Average time taken to pay invoices, measured in days from invoice receipt
• Percentage of invoices paid in each of three bands: within 30 days, between 31 and 60 days, and after 60 days
• Percentage of invoices not paid within the agreed terms
• Standard payment terms, including any changes in the period and how suppliers were notified
• Maximum contractual payment period and any sectoral exceptions
• The reporter's dispute-resolution process
• Whether the business offers e-invoicing, supply-chain finance, or deducts charges for inclusion on a supplier list
• Membership of any payment code (the Prompt Payment Code being the obvious one)

The dataset is published as open CSV. That detail matters more than the rules themselves — because it is open, journalists, supplier groups and the Small Business Commissioner have been able to compile league tables. The reputational sanction is now the dominant enforcement mechanism. The criminal-offence backstop, a summary-only fine for a director who knowingly or recklessly approves a false report, has been invoked a vanishing number of times across the regime's life.

The April 2025 threshold uplift: how the perimeter just shifted

Until April 2025, the 2017 Regulations caught a company or LLP that exceeded two of three thresholds for two consecutive financial years. SI 2024/1303 raised those thresholds in line with the wider accounts reform. The table below sets out the change.

The employee count was deliberately not moved. DBT has been clear that headcount is the more politically defensible test, and that any erosion of the 250-employee floor would have re-opened the parallel debate on the Gender Pay Gap Information Regulations 2017, which use the same number. In practical terms, a mid-market company with 220 employees and £45 million of turnover, which would have been caught under the old rules, now sits outside the perimeter. DBT's own impact assessment estimated that roughly 15% of previously-reporting entities would drop out of scope at the next two-financial-year reset — somewhere between 1,200 and 1,500 reporters off the register by the end of 2027, depending on how many cluster around the new turnover line.

For groups, the assessment is done at parent level on consolidated figures, but each qualifying UK subsidiary still has to file its own report unless it falls outside the test individually. That is one reason the gov.uk payment-practices dataset contains so many separately-filed entries from the same group: each large UK subsidiary is reporting in its own right.

What nine years of data have actually shown

The headline numbers from the open dataset over the regime's life make for awkward reading. Below is an indicative summary drawn from the published returns across the H1 2018 baseline period, the pandemic-era H2 2020 trough, and the most recent complete H2 2025 cycle.

The trend line is real but slow. Across nine years the median large-business average has shaved roughly four days off — much of that gain coming since the Small Business Commissioner began issuing public assessments under the Enterprise Act 2016, and since the Prompt Payment Code was reformed in 2021 to require signatories to pay 95% of invoices from small suppliers within 30 days. Construction remains the most stubborn sector, with median average days routinely above 45 even after the Construction Act payment provisions were tightened.

The dispersion is wider than the medians suggest. The Small Business Commissioner has, since 2022, published a quarterly intervention list of slow-paying large suppliers. At the most recent quarterly bulletin, ten reporters sat above the 70-day mark, and the longest reported average payment time on the register was 91 days. None of those firms have faced anything beyond reputational consequence — the 2017 Regulations carry no civil penalty regime of their own.

The Procurement Act, the 1998 Act and the regime's flanking enforcement

Four separate developments have changed the wider enforcement landscape without touching SI 2017/395 itself.

1. The Procurement Act 2023 commenced on 24 February 2025 and, via section 73, imports a statutory 30-day payment obligation into the entire public-sector supply chain — including sub-contracted tiers. Suppliers to a public body must, in turn, pay their own subcontractors within 30 days of a valid invoice, even where the head contract is silent.
2. The Late Payment of Commercial Debts (Interest) Act 1998 continues to provide a statutory 8% over Bank Rate interest claim plus fixed recovery costs of £40 to £100 per invoice. With Bank Rate at 4.25% as at May 2026, the statutory rate is 12.25%. Most small suppliers still do not claim it.
3. The Reporting on Payment Practices and Performance (Amendment) Regulations 2024, in force from 1 January 2025, extended the reporting fields to require disclosure of any standard payment terms that exceed 60 days, plus the share of invoices subject to retention in construction contracts — both designed to surface the harder cases.
4. The Small Business Commissioner's caseload has grown each year since 2020. The 2024-25 annual report logged a record £8.4 million of disputed late payments recovered through complaints.

The 2017 Regulations themselves were never designed as an enforcement regime. They were designed as a transparency regime that other actors — supplier representative bodies, journalists, the Commissioner, public-sector buyers — would use. Nine years in, that theory of change has, at best, worked at the margins.

What the regime still does not catch

Three significant gaps remain visible in the data.

• Construction retentions are reported as an aggregate share but not as a separate days-outstanding figure. A 5% retention held across the standard twelve-month defects period sits invisibly inside the headline metric.
• Group netting is permitted: a parent that nets supplier invoices against rebates can report a shorter average days-to-pay than the supplier experiences in cash terms. The Commissioner's office has raised this point in three consecutive annual reports without legislative follow-through.
• The 250-employee cliff edge continues to draw a sharp line through the mid-market. A 249-employee business with £80 million of turnover sits entirely outside the regime; a 251-employee business with £55 million turnover and £30 million balance sheet now sits inside it for the first time. The asymmetry is one reason DBT's 2025 consultation paper, Improving Prompt Payment, floated bringing all medium-sized companies above £54 million turnover into the perimeter regardless of headcount. That consultation closed in February 2026 and is awaiting government response.

The long-promised review

A statutory review of the 2017 Regulations was originally required within five years — that fell in 2022 and was completed quietly, with the principal recommendation being to extend the regime beyond its original 2024 sunset. The current regulations now run until 2031. A second review is due before that date, and the indications from DBT's policy paper Prompt payment and cash flow review, refreshed in October 2025, are that the next iteration is likely to:

• bring statutory civil penalties for non-filing into line with the Companies Act late-filing tiers, ending the current reliance on the criminal route
• introduce a public-procurement disqualification for repeat poor payers, integrating with the Procurement Act 2023 exclusion grounds
• harmonise reporting periods with the company financial year, ending the awkward calendar-based half-year cadence that currently sits at odds with most reporters' own accounting periods

None of that has primary legislation backing it yet. For now, the picture is unchanged: an open dataset, a slow-moving median, and a freshly reduced perimeter that will quietly remove several thousand returns from the register over the next two reporting cycles. The companies stepping out are not the worst payers — they are the mid-market reporters around the old £36 million turnover line, many of whom were filing serviceable 35-to-40-day average returns. The 91-day outliers remain firmly inside the perimeter, and firmly inside the Commissioner's quarterly bulletin. Whether that is the right outcome from a regime nominally designed to protect small suppliers is a question the next review will have to answer.