Credit Reference Agency · UK public procurement notice

The Open University (OU) and Open University Student Budget Account Ltd (OUSBA) propose to extend the existing Credit Reference Agency (CRA) services contract with TransUnion. This direct award relies on Schedule 5, justification 7 of the Procurement Act 2023, as the services constitute an extension of existing services where a change of supplier would result in incompatibility with current systems and disproportionate technical difficulties in operation and maintenance.

OUSBA operates a regulated Consumer Credit Loan facility that enables students to spread the cost of their tuition fees. In order to comply with Financial Conduct Authority (FCA) requirements, OUSBA must undertake affordability and creditworthiness checks, which are fully embedded within its credit decisioning systems and operational processes. These systems are tightly integrated with TransUnion's credit reference data, data structures, scoring methodologies, APIs, and reporting mechanisms.

A change in CRA supplier would not be a like‑for‑like replacement. Different providers use materially different data schemas, bureau attributes, scoring models, and interface structures. Replacing TransUnion would therefore require extensive re‑engineering of OUSBA's systems, including remapping data fields, redesigning credit decision trees, formulas and exception handling, reconfiguring system integrations and security controls, and rebuilding reporting and dispute‑handling processes. Extensive testing would also be required to ensure that customer outcomes are not adversely affected and that regulatory compliance is maintained.

These incompatibilities would result in disproportionate technical difficulties, both during implementation and in the ongoing operation and maintenance of a live, regulated lending platform. Introducing incompatible data and processing logic would materially increase the risk of system instability, incorrect credit decisions, and regulatory non‑compliance. The scale, complexity, and regulatory sensitivity of the changes required mean that a supplier switch cannot be undertaken without significant technical disruption.

The proposed contract extension does not materially change the nature or scope of the existing services and is limited to maintaining continuity with the current integrated solution. It represents the most proportionate means of ensuring compatibility with established systems and controls, enabling OUSBA to continue operating its regulated lending activity while any future competitive procurement is planned and implemented in a controlled and compliant manner.

For these reasons, the extension of the existing CRA contract with TransUnion satisfies the conditions set out in Schedule 5, justification 7, as a change of supplier would result in incompatible services and give rise to disproportionate technical difficulties in operation and maintenance.