The framework that anchors UK FM procurement

The CCS FM framework suite has existed in various forms since the early days of Crown Commercial Service. RM6089 covered FM Marketplace. RM6232 extended the scope into Workplace Services. RM6257 covered Security Services separately. RM6378, the current iteration branded as Facilities Management and Security Services, consolidates FM and security under one framework for the first time. It is the framework that most central government departments are directed to use and that the wider public sector, including NHS bodies, local authorities, blue light organisations, and education institutions, can access.

The framework operates on a four year cycle, consistent with the Procurement Act 2023 maximum framework term. When it renews, the entire supplier panel is recompeted. Suppliers must bid again, be evaluated again, and be reappointed. Between renewals, the panel is closed under traditional framework rules, although RM6378 is also one of the first major test cases for the open framework concept under the Procurement Act 2023, which allows new suppliers to join at defined points during the term.

The spending ceiling is the number that makes headlines. It represents the maximum aggregate value of call offs that can be placed through the framework over its term. It is not a commitment to spend. It is a permission to spend up to that amount. Actual spend through the framework is substantially lower than the ceiling. But the ceiling matters because it signals scale. It tells the market that this is the framework that controls access to the largest share of public sector FM spend in the country.

A framework ceiling value is not performance. It is permission. And permission creates one of the biggest distortions in framework procurement: the illusion of opportunity. Many suppliers pursue framework places based on potential volume that may never materialise.

The scope: FM and security under one roof

One of the most significant changes in RM6378 is the consolidation of FM and security services into a single framework. In previous iterations these were distinct procurement routes. RM6232 covered workplace and FM services. RM6257 covered security. By merging them, CCS is pushing the market toward integrated service delivery: a single provider or a single prime contractor managing both FM operations and security provision.

The scope of RM6378 covers Hard FM, Soft FM, Total FM, security guarding, CCTV and surveillance services, helpdesk and workplace services, waste and environmental services, grounds maintenance, specialist estates support, and building engineering services. For buyers, this offers the attraction of simplified management through a single procurement route. For suppliers, it demands a breadth of capability that many specialist firms do not possess.

This consolidation creates a structural tension. It reduces procurement complexity for buyers but increases concentration risk in the supply chain. If a single provider holds both the FM and security contract for a public sector estate and that provider fails, the operational impact is compounded. The market is moving toward a concentration of risk that has not been fully audited.

Who this consolidation favours

The merged scope favours large, diversified FM providers who can credibly offer both FM and security: Mitie, ISS, Serco, Sodexo, G4S, CBRE, EMCOR, Equans, Vinci, OCS. These are the firms with the operational breadth to submit across multiple lots. Specialist security firms and specialist FM providers who excel in one domain but not both face a framework structure that is not designed for their operating model. The framework’s lot structure may include dedicated security lots, but the gravitational pull of the integrated model favours the generalist.

The lot structure: where the architecture shapes the market

RM6378 is divided into lots. Each lot covers a defined scope of FM services, further subdivided by value bands. The lot structure is not a neutral administrative division. It is the architecture that determines which suppliers can compete for which work, what the minimum entry requirements are, and how call offs are routed.

How lot boundaries shape competition

A supplier appointed to a Total FM lot cannot compete for work called off under a Soft FM lot even if it has the capability. A specialist cleaning provider on a Soft FM lot cannot bid for a bundled TFM call off. The lot structure creates walls between service categories that may or may not reflect how buyers actually need services delivered. A buyer whose requirement spans two lots faces a procurement problem the framework was not designed to solve.

The lot structure also creates tiering. Larger lots with higher value bands attract larger suppliers. Smaller lots with lower value bands are intended to create access for mid market and specialist providers. Whether this produces genuine competition within each lot or simply segments the market into predictable pools depends on how many suppliers are appointed to each lot and how call offs are distributed. In practice, the same Tier 1 providers often occupy multiple lots across different value bands, effectively crowding out the specialists the sub lot structure was designed to protect.

Turnover thresholds and the SME access problem

Framework entry requires suppliers to meet financial viability thresholds, typically expressed as minimum annual turnover relative to the lot value. A lot with a spending ceiling of £500 million may require suppliers to demonstrate turnover of £50 million or more. This is a risk management mechanism: the buyer wants assurance that the supplier can absorb the contract without financial distress.

In practice, turnover thresholds exclude mid market and regional suppliers who could deliver individual call offs competently but whose annual turnover does not meet the lot level requirement. Beyond turnover, the compliance burden of the framework itself acts as a filter. Significant insurance levels. National mobilisation capability. Extensive policy compliance documentation. Technical accreditations. Complex social value submissions.

Typical bid cost for a mid market FM supplier to prepare a single CCS framework submission runs to £30,000 to £70,000 or more, before a single call off is won.

Many SMEs cannot absorb that cost. Many that do absorb it never win a call off.

Article 9 of this series examines the regional inequality problem in detail. The turnover threshold and the bid cost barrier are two of the primary mechanisms by which framework structures exclude capable regional suppliers from national FM procurement.

The evaluation: what gets scored and what gets rewarded

Appointment to RM6378 requires passing a two stage evaluation: a selection questionnaire and a quality and price assessment. The selection stage filters for financial standing, insurance, health and safety, and basic capability. The evaluation stage scores suppliers on quality responses, pricing submissions, and social value commitments.

Quality at framework versus quality at call off

This is the structural tension at the heart of the model. Quality is assessed at framework appointment. The supplier writes detailed responses to questions about its approach to service delivery, mobilisation, innovation, technology, workforce management, and sustainability. These responses are scored. The scores determine who gets on the framework.

At call off, when an actual contract is being awarded, the quality dimension is typically weaker. Many call offs are awarded on price with a pass/fail quality threshold. Some are direct awards with no competitive element at all. The quality score that earned the supplier its place on the framework is not reassessed. The buyer is relying on an evaluation that was conducted months or years earlier, against generic questions, by a different team.

The quality assessment at framework level rewards suppliers who write well. The call off mechanism rewards suppliers who price low. The supplier that excels at both may not be the supplier that excels at delivery. Framework procurement tests compliance and prose. It does not test performance.

The practical consequence: the quality assessment at framework level rewards suppliers who write well. The call off mechanism rewards suppliers who price competitively. These are not the same capability. A supplier that excels at quality submissions and a supplier that excels at operational delivery are not necessarily the same supplier.

Social value: scored but not tracked

Social value is typically weighted at 10 to 20% of the quality score at framework appointment. Suppliers commit to apprenticeships, local employment, SME subcontracting, carbon reduction, and community engagement. These commitments contribute to the supplier’s score. Once appointed, there is limited mechanism for tracking whether the commitments are delivered at call off level. The framework rewards the promise. Nobody audits the outcome. Article 7 of this series examines the social value accountability gap in detail.

Call off mechanisms: direct award versus mini competition

Once a buyer has decided to use RM6378, the call off mechanism determines how the specific contract is awarded. There are two primary routes.

Direct award & Mini competition Breakdown

Direct award: The buyer selects a supplier from the framework panel without running a competitive process among the panel members. Direct award is typically used for lower value requirements, urgent needs, or situations where the buyer has a specific justification for selecting a named supplier.

CCS publishes guidance on when direct award is appropriate. In practice, direct award is used more frequently than the framework documentation implies, and the justification requirements are not always rigorously applied. Direct award removes competition from the call off entirely. The supplier is selected, not competed. The framework becomes a compliance wrapper around a non competitive decision. For buyers under time pressure, direct award offers speed and certainty. But it also concentrates spend in familiar providers. The bigger the framework, the stronger this effect. Buyers under pressure default to known suppliers, incumbent providers, national operators, and low risk mobilisation profiles. This is understandable. It is also how concentration builds invisibly.

Mini competition: The buyer invites all suppliers on the relevant lot (or a subset meeting specific criteria) to submit pricing and, in some cases, quality responses for the specific requirement. This is a competitive process within the framework panel. It produces a winner based on the call off evaluation criteria. Mini competitions produce genuine competition. But they also add time and cost to the process, which undermines one of the core arguments for using a framework in the first place. The buyer is running a procurement within a procurement. The framework was supposed to eliminate that burden.

Baachu Rain’s analysis of CCS FM framework call offs shows the split between direct award and mini competition and what it means for competition levels[cite: 1]. Article 4 of this series presents the concentration data on who actually wins.

Is RM6378 too big to challenge?

At what point does a framework stop being a procurement route and start becoming market infrastructure? RM6378 is approaching that line. If too much public sector FM spend flows through one procurement vehicle, several risks emerge. Supplier concentration increases. Innovation reduces because the framework specification becomes the ceiling of ambition rather than the floor. Regional access narrows because national frameworks favour national operators. Buyer flexibility decreases because the framework terms may not fit every requirement but the compliance incentive pushes buyers to use them anyway. Systemic mobilisation risk increases because a small number of providers carry a disproportionate share of the operational load.

Competition requires optionality. Dominance reduces it. A framework designed to create efficiency can unintentionally create dependency. And once buyers default to RM6378, suppliers depend on it, and the framework body generates revenue from it, reform becomes difficult. The system no longer serves procurement alone. It serves itself.

The PFI Reckoning series examines a specific dimension of this dependency: when authorities must reprocure FM services after PFI contract expiry, many default to RM6378 as the compliant route, even where the asset condition is unknown, the TUPE population is complex, and the framework specification does not address the compliance gap. Article 9 of that series covers the insource versus reprocure decision. The SFG20 Reckoning series examines how maintenance specifications referenced within framework contracts are themselves a standard that has not kept pace with operational reality.

The whale and the ecosystem

RM6378 is the largest single framework in UK FM. It shapes the market by determining who can compete, at what price, under what terms, and through what process. Understanding how it works is not optional for any FM supplier or buyer operating in the UK public sector.

But RM6378 is not the whole market. NHS SBS, ESPO, YPO, Pagabo, and the university purchasing consortia each control significant FM spend in their sectors. The framework landscape is not a monopoly. It is an oligopoly of buying organisations, each with its own commercial model, its own incentives, and its own definition of what value means.

The next article examines the commercial model that funds these organisations: the levy. The management fee that suppliers pay on call off spend. The revenue that makes framework bodies viable. And the incentive structure it creates. Because procurement is never just about compliance. It is also about incentives.