Guidance: SMR Conflict of Interest Matrix

This note explains what has changed in the Conflict of Interest (COI) Matrix, why the change has been made, and what it means for suppliers.

This file may not be suitable for users of assistive technology.

This file may not be suitable for users of assistive technology.

The COI Matrix was published in August 2025 and became the reference document for managing potential conflicts of interest across the SMR Programme. It was developed earlier in the programme, when the market and delivery approach were still being worked through.

GBE‑N has since reviewed market feedback, delivery steps, and the practical requirements of upcoming work packages. Having reflected on the extent to which any associated conflicts of interest can be effectively identified, managed, and controlled, GBE‑N has decided to update the matrix and supplementary guidance.

This change does not remove conflict of interest controls or diminish the standard expected of suppliers. What has changed is how certain scenarios are assessed. Interactions between the Delivery Partner procurement and the Balance of Plant, Associated Developments, Engineering Partner, and Site Groundworks and Civils procurements will no longer automatically be excluded at Tier 1 level in all cases. Instead, these interactions will be assessed on a case-by-case basis, with suppliers required to demonstrate that any actual or potential conflict can be appropriately identified, controlled, and managed.

The updated material also provides clearer definitions and refined drafting to support a more consistent understanding of key roles, tiers, and delivery structures.