IT procurement is the work of buying technology products and services for an organization: planning what is needed, choosing a supplier, negotiating the contract, monitoring the supplier and ending or renewing the relationship.1,2
For an enterprise, the contract is also a risk control. US bank regulators and the EU's Digital Operational Resilience Act expect the buyer to manage a supplier's risk for as long as the relationship lasts. NIST publishes guidance for managing cyber risk across the supply chain.2,3,4
Facts checked against their sources on November 9, 2026. Numbers after a sentence link to its sources.
The IT procurement process, from requirements to renewal
US bank regulators set out the life of a supplier relationship in their June 2023 interagency guidance. It has five stages: planning, due diligence and third-party selection, contract negotiation, ongoing monitoring, and termination. The guidance applies to every stage, not only the purchase.2
Requirements and the market scan come first. The UK government's purchasing guidance tells buyers to work out as much of the full cost of building or buying as they can. They then set the most they will spend for the business outcome they want, survey what the market offers, and plan the product's life through upgrades and retirement.5
Evaluation tests the shortlist on real work. The same guidance suggests a trial on a small scale. The buyer tries to solve one small but hard problem, tests integration with current systems, checks the product with its users and confirms it meets accessibility rules.6
Negotiation usually starts from the supplier's standard contract. The interagency guidance says a buyer can ask for changes, extra provisions or addenda. Where its negotiating power is limited, the buyer should understand the limits and risks that result, and decide whether the residual risk is acceptable.7
At renewal, the UK guidance has commercial and technical teams keep working together on the ongoing value of each contract. It also says contracts cannot be extended automatically unless there are extenuating circumstances.8,9
Who owns the decision: IT, procurement or the business
In US federal agencies, the CIO approves IT acquisitions. OMB requires it under FITARA. GAO checked in January 2018. Only 11 of 96 IT contracts it sampled at 10 agencies had been reviewed and approved by the CIO. The 85 contracts not reviewed had a total possible value of about $23.8 billion.10
Procurement staff run the process. The US Bureau of Labor Statistics says purchasing managers coordinate buyers and develop the organization's procurement policies and procedures. Buyers weigh price, quality, availability, reliability and technical support when they choose a supplier.1,11
Accountability stays with the organization that buys. The interagency guidance says a bank's use of third parties does not diminish its responsibility to meet its legal and safety requirements. It carries that responsibility to the same extent as if it did the work in-house.12
Our pages on it procurement
- Source-to-Pay (S2P) Software and Procurement PlatformsBuyer Guide
- SaaS Management & OptimizationBuyer Guide
- Contract Lifecycle Management (CLM) SoftwareBuyer Guide
- RFP questions: commercialRFP questions
- RFP questions: legal contracting ipRFP questions
- RFP questions: migration exitRFP questions
- RFP questions: third party supply chainRFP questions
- Choose and buy technologyJob
- RFP questions by categoryPage
- Vendor selection and RFP readiness checklistFree tool
- Vendor RFP outlineFree tool
- SaaS contract red flags checklistFree download
- TCO / ROI BuilderBuild-vs-buy total cost of ownership over several years, with NPV and break-even.
- SaaS Sprawl DetectiveDuplicate, underused and shadow-IT SaaS subscriptions.
- SaaS license waste calculatorFree tool
- Third-party risk management and vendor securityArticle
- Technology vendor managementArticle
- Choosing a mobile procurement solutionArticle
Build vs buy, and when to run a formal RFP
The UK purchasing guidance lists when building makes sense:
- The user need is unique or rare.13
- Few suppliers can meet the requirements.13
- Commercial products cannot be scaled, adapted or integrated to meet core needs.13
- The organization must own the technology to keep modifying it.13
- The capability and resources to manage the project are in place.13
Buying fits when a commercial product meets most needs through configuration, with little customization. The guidance warns that even small modifications to off-the-shelf software can remove most of the benefits of using it. It advises changing settings instead, so the supplier still supports new versions.14
Bank regulators scale the depth of review to the risk. The interagency guidance says due diligence should match the risk and complexity of the relationship. Third parties that support critical activities get more of it.15
Public buyers use dollar thresholds. The US Federal Acquisition Regulation sets the micro-purchase threshold at $15,000 and the simplified acquisition threshold at $350,000. Simplified acquisition procedures are the methods in FAR Part 13.16
The UK guidance sends buyers to existing frameworks and approved sourcing routes, such as the Digital Marketplace, to avoid long and expensive procurement processes.17
Software and SaaS contract terms that matter
The US General Services Administration rewrites standard software terms for federal orders. Its acquisition manual deems set language part of the commercial supplier agreement for anything bought under a GSA contract, notwithstanding the agreement's other terms. The interagency guidance lists what a sound bank contract covers.2,18
| Term | What to ask for | Where it comes from |
|---|---|---|
| Automatic renewal | No license or subscription renews without express consent from someone authorized to give it. This covers annual software maintenance. | GSA's acquisition manual bars automatic renewal in commercial supplier agreements for federal orders.18 |
| Renewal price | The conditions under which prices can change, with a limit on increases. | The interagency guidance says contracts may set limits on any cost increases.19 |
| Changes to terms | The vendor cannot change terms that raise prices, cut service levels or reduce your rights without a signed amendment. | GSA treats such changes as material. They bind the government only through a bilateral modification.20 |
| Service levels | A service-level agreement with measures that can monitor performance, penalize poor performance or reward good performance. | Interagency guidance, on performance measures.21 |
| Exit and data return | Notice periods long enough for an orderly transition without prohibitive cost, timely return or destruction of your data, and a clear split of transition costs. | Interagency guidance, on default and termination.22,23 |
| Break clause | Where economic, a break clause at no more than 2 years, with minimal exit costs. | UK Technology Code of Practice, point 11.24 |
| Audit rights | Your right to audit the vendor and require remediation. Limits on how the vendor audits your license compliance and bills for it. | Interagency guidance on the buyer's audit right. GSA amends vendor audit clauses so any charge follows the contract's invoicing rules.25,26 |
| Data and IP ownership | Explicit ownership of your data, including data the service creates, and of the IP delivered. A stated limit on the vendor's use of your information. | UK Technology Code of Practice, point 11, and the interagency guidance on ownership and license.27,28 |
| AI training and portability | A permanent ban on training commercial AI models on your non-public inputs and outputs without consent. Data and model portability, and knowledge transfer from the vendor. | OMB memo M-25-22, April 2025, for US federal AI contracts.29,30 |
Third-party risk management: the interagency guidance, DORA and NIST SP 800-161
The Federal Reserve, the FDIC and the OCC issued their interagency guidance on third-party relationships in June 2023. It counts outsourced services and independent consultants as third-party relationships. A relationship can exist without a contract or payment.2,31
The guidance expects a bank to keep a complete inventory of its third-party relationships and to assess the risk of each one periodically.32
The EU's Digital Operational Resilience Act has applied since January 17, 2025. Every financial entity in scope must keep a register of its contractual arrangements with ICT third-party service providers. Supervisors collect the registers, and the European Supervisory Authorities use them to designate critical ICT providers for EU-level oversight.3
NIST SP 800-161 Revision 1 covers cybersecurity supply chain risk management. It was published in May 2022 and updated in November 2024. It guides organizations in identifying, assessing and mitigating cyber risk in the products and services they acquire, through C-SCRM strategies, policies, plans and risk assessments.4
SaaS spend and cloud waste: 2026 figures
Zylo's 2026 index also found that 61% of IT leaders had cut projects because of unplanned SaaS cost increases. Zylo builds the index on the SaaS licenses, spend and usage data it manages for customers.38
Where IT procurement goes wrong
- Nobody counts licenses after the purchase. In January 2024, GAO found that none of nine US agencies with large IT budgets had fully determined whether their five most widely used software licenses were over- or under-purchased. GAO names two controls: track the licenses in use, and compare that inventory with purchase records. It made 18 recommendations to the nine agencies.39,40
- IT buying happens where IT cannot see it. The 22 agencies in GAO's 2018 review identified $14.7 billion of IT contract obligations for fiscal 2016. GAO found another $4.5 billion they had not identified.41
- A bought product gets customized. The UK guidance says changes, customizations and workarounds can raise costs, make maintenance harder and restrict future upgrades.42
- There is no exit plan. The interagency guidance puts contingency plans for moving the work to another provider, or back in-house, in the planning stage, before any contract is signed.43
- An AI service locks the buyer in. OMB's April 2025 memo lists the protections US agencies can require: knowledge transfer, data and model portability, and rights to the code and models a vendor produces under the contract.30
Questions about it procurement
What is a procurement strategy?
A procurement strategy sets out the need, the build-or-buy decision and the commercial approach before anything is bought. The UK Technology Code of Practice calls it a purchasing strategy. It says the strategy must show that the buyer considered the commercial and technology aspects and the contractual limitations.44
What does a procurement manager do?
Purchasing managers plan and coordinate the work of buyers and purchasing agents, hire and train staff, and develop procurement policies and procedures. The median annual wage for US purchasing managers was $148,080 in May 2025, according to the Bureau of Labor Statistics.11,45
Does IT outsourcing transfer responsibility to the vendor?
No. US bank regulators count outsourced services as third-party relationships. Their June 2023 guidance says a bank stays responsible for meeting its requirements to the same extent as if it did the work in-house. In the EU, DORA requires financial entities to register their contracts with ICT service providers.3,12,31
Sources
- US Bureau of Labor Statistics, Occupational Outlook Handbook: Purchasing Managers, Buyers, and Purchasing Agents. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- European Banking Authority, Preparations for reporting of DORA registers of information. Retrieved November 9, 2026.
- NIST, SP 800-161 Rev. 1, Cybersecurity Supply Chain Risk Management Practices for Systems and Organizations. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- US Government Accountability Office, Information Technology: Agencies Need to Involve Chief Information Officers in Reviewing Billions of Dollars in Acquisitions (GAO-18-42, January 2018). Retrieved November 9, 2026.
- US Bureau of Labor Statistics, Occupational Outlook Handbook: Purchasing Managers, Buyers, and Purchasing Agents. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- US General Services Administration (Acquisition.gov), FAR 2.101, Definitions. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- US General Services Administration, GSAM 552.212-4, Contract Terms and Conditions: Commercial Products and Commercial Services. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- US General Services Administration, GSAM 552.212-4, Contract Terms and Conditions: Commercial Products and Commercial Services. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- US General Services Administration, GSAM 552.212-4, Contract Terms and Conditions: Commercial Products and Commercial Services. Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- US Office of Management and Budget, M-25-22, Driving Efficient Acquisition of Artificial Intelligence in Government (April 3, 2025). Retrieved November 9, 2026.
- US Office of Management and Budget, M-25-22, Driving Efficient Acquisition of Artificial Intelligence in Government (April 3, 2025). Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- Zylo, 2026 SaaS Management Index. Retrieved November 9, 2026.
- Zylo, 2026 SaaS Management Index. Retrieved November 9, 2026.
- Flexera, 2026 State of the Cloud Report. Retrieved November 9, 2026.
- Flexera, 2026 State of the Cloud Report. Retrieved November 9, 2026.
- Flexera, 2026 State of the Cloud Report. Retrieved November 9, 2026.
- Zylo, 2026 SaaS Management Index. Retrieved November 9, 2026.
- US Government Accountability Office, Federal Software Licenses: Agencies Need to Take Action to Achieve Additional Savings (GAO-24-105717, January 2024). Retrieved November 9, 2026.
- US Government Accountability Office, Federal Software Licenses: Agencies Need to Take Action to Achieve Additional Savings (GAO-24-105717, January 2024). Retrieved November 9, 2026.
- US Government Accountability Office, Information Technology: Agencies Need to Involve Chief Information Officers in Reviewing Billions of Dollars in Acquisitions (GAO-18-42, January 2018). Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- Federal Reserve, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023). Retrieved November 9, 2026.
- UK Government Digital Service, Technology Code of Practice, point 11: Define your purchasing strategy. Retrieved November 9, 2026.
- US Bureau of Labor Statistics, Occupational Outlook Handbook: Purchasing Managers, Buyers, and Purchasing Agents. Retrieved November 9, 2026.