Summary

  • Three quarters of the £3.5m levy is shared equally; the remaining quarter reflects the GCA’s estimate of expected work, using suppliers’ 2025 perceptions of retailer compliance.
  • The policy publishes a 6.05%–12.98% contribution range, but not each retailer’s amount or the inputs behind its individual calculation.

The Groceries Code Adjudicator’s 2026/27 funding policy turns a supplier survey into one part of the regulator’s cost-allocation method. Of the £3.5 million levy on 14 designated retailers, 75% is divided equally to meet costs the GCA says apply across the group. The remaining 25% is allocated variably, using suppliers’ perceptions of each retailer’s overall compliance with the Groceries Supply Code of Practice in the 2025 annual survey.

The GCA describes that perception measure as the best reflection of the expense and time it expects to spend on each retailer. Lower perceived compliance means a larger share of the variable component. This is a workload proxy chosen by the regulator; it is not a published count of staff hours, an adjudicated finding of breach, or a measure of legal liability. The policy does not disclose a retailer-by-retailer contribution table or the individual inputs used in each calculation.

The total also combines two fiscal periods. £3,110,147 is for expenses in 2026/27. The other £389,853 covers 2025/26 expenses previously met through a short-term loan from the Secretary of State. The Government consented to the amount and methodology on 9 March 2026, and the GCA published the policy on 25 September as required by section 19(8) of its 2013 Act.

The stated contributions range from 6.05% to 12.98% of the total levy: £221,794 at the bottom and £454,285 at the top. Those are endpoints, not a ranked disclosure of all 14 contributions. The GCA says a newly designated retailer would pay a flat one-fourteenth share, prorated for the remaining financial year, without contributing to the 2025/26 component; the added payments would lift the total above £3.5 million. Any levy left unused after year-end is returned in proportion to each retailer’s contribution.

This design is easier to assess when the survey signal is kept distinct from the experience it is meant to represent. In its response to the 2025 statutory review, the GCA reported average perceived compliance of 93% in 2025, compared with 92% in 2023. Separately, the Government review records that 10 of 28 suppliers interviewed said they would not raise a Code issue with the GCA in future, alongside concerns that a supplier can be identifiable even when information is described as anonymous in a small supply chain.

Those findings do not appear as inputs to the levy formula, but they matter when asking how representative a survey-based signal can be.

The subsequent 2026 supplier survey is a different measurement round: its announcement reports an average perception of 92%. The levy policy explicitly names the 2025 survey, so the newer result should not be substituted for the measure that informed this funding year. The regulator’s remit is to encourage, monitor and enforce the Code in relationships between large UK grocery retailers and their direct suppliers.

The governance question is not whether perception is useful. It is what the public can test when perception is used to distribute a quarter of an institution’s funding burden. A proxy can connect lived supplier experience to expected regulatory work, but the policy’s aggregate range leaves outsiders unable to reconstruct how much of a retailer’s contribution came from the shared base and how much from the variable estimate. The distinction matters because an allocation rule can influence incentives even when it is not a penalty and makes no finding of misconduct.

Sources