Guide
Reporting a nil return on a GCA framework.
A month with no business under a GCA framework agreement is still a required MI submission. This guide sets out, in the framework's own wording, what counts as a missed report and what Crown Commercial Service says happens next.
A nil month is still reportable
A month without business under the agreement is still reportable. The supplier completes "Report no business" in GCA's Report MI portal rather than uploading a blank workbook. GCA's own sign-in guidance for the portal puts it plainly: "If you didn't do any business, you still need to sign in and let us know."
Source: GCA, Report MI.
A missed nil declaration is an MI Failure
Crown Commercial Service's "Management Information Admin Fees and Default Charges" guidance, dated 21 February 2020 and published as a guide on GCA's Report MI service, defines an MI Failure as when an MI submission:
- Contains any material errors or material omissions; or
- Is submitted using an incorrect MI reporting template; or
- Is not submitted by the reporting date (is submitted late)
— and then adds one further line: "Including where a declaration of no business should have been filed." A missed nil declaration is an MI Failure in exactly the same sense as a late or incorrect sales report; the document does not treat it as a lesser case.
Source: Crown Commercial Service, MI admin fees and default charges (PDF), published via GCA Report MI.
Two separate clocks — don't merge them
The document sets two different mechanisms on two different rolling windows.
Admin Fees run on a rolling three-month window: "If, in any rolling three (3) month period, two (2) or more MI Failures occur, ... CCS shall have the right to invoice the Supplier Admin Fee(s) ... as they arise in subsequent Months." The fees are itemised — for example £2.50 for a chasing email, £5.00 for a phone call, £15.00 for a letter, £75.00 for a two-hour supplier meeting, and £300 per day for an audit of the business, plus Bank of England interest on any outstanding balance.
The MI Default runs on a separate rolling six-month window with its own count: "If two (2) MI Reports are not provided in any rolling six (6) month period then an MI Default shall be deemed to have occurred." On an MI Default, CCS "shall be entitled to" a Default Management Charge, suspension from the agreement, or termination of the contract — the three are joined by "and/or" in the document, not stated as automatic or cumulative.
Source: Crown Commercial Service, MI admin fees and default charges (PDF), published via GCA Report MI.
How the Default Management Charge is worked out
Where it applies, the Default Management Charge is set at "the higher of: the average Management Charge paid or payable by the Supplier in the previous six (6) Month period or, if the MI Default occurred within less than six (6) months from the commencement date of the first Call-Off Contract, in the whole period preceding the date on which the MI Default occurred; or the sum of five hundred pounds (£500)." The average is taken from the Management Charge already paid or payable, not from turnover directly, and the document does not spell out how a run of nil months feeds into that average — the £500 floor sets the minimum regardless of how low it runs.
If a supplier later provides enough Management Information to rectify a default, the document runs both ways: an overpayment is refunded net of any Admin Fees, and an underpayment is recovered as a debt together with interest.
Source: Crown Commercial Service, MI admin fees and default charges (PDF), published via GCA Report MI.
Keeping the nil month visible
UK Filing keeps the month and deadline visible so a quiet month doesn't get forgotten. The supplier still completes "Report no business" in GCA's Report MI portal — UK Filing does not submit on the customer's behalf.
What we couldn't confirm
GCA's public pages don't state where "Report no business" sits inside the signed-in Report MI portal, whether a missed nil month can be filed retrospectively, or whether the nil declaration is made once or separately for each agreement. Those sit behind sign-in or need confirming directly with [email protected].
This guide is not legal or compliance advice and does not guarantee portal acceptance of any submission. Not affiliated with, endorsed by, or operated by the Government Commercial Agency or Crown Commercial Service. Official templates and guidance are published at gca.gov.uk.
UK Filing prepares the verified RM6292 workbook every month and keeps nil months tracked alongside it — see RM6292 GCA MI reporting.