DMFD293 Procurement for the supply of fuel cards

1.1.    London Fire Brigade (LFB) uses fuel cards to give operational staff a convenient and discounted way to pay for fuel for any type of vehicle at public petrol stations. LFB used fuel cards to pay for over a million litres of fuel in 2025-26 at an aggregate cost of almost £1.7 million. 

1.2.    LFB had a two-year contract for the supply of fuel cards which ended June 2026 (see DMFD237). LFC-26-050 explains how LFB’s spending on fuel cards has been affected by increases in wholesale fuel prices linked to the closure of the Strait of Hormuz. LFB reports that its spending on fuel cards exceeded the amount approved by DMFD237 which has been reported through the quarterly financial updates. 

1.3.    LFB is seeking approval to spend on a new two-year contract for the supply of fuel cards, which it plans to procure via a Government Commercial Agency (GCA) framework. 

1.4.    Between contracts, LFB will let a short-term call-off contract with its current fuel card supplier via a compliant public sector procurement framework and in accordance with its scheme of governance. LFB will report on the cost of interim arrangements as part of its regular financial reporting. 
 

2.1.    LFB expects that a new contract for fuel cards will support the delivery of its frontline services, and mitigate risks associated with fuel shortages. Fuelling LFB vehicles at public forecourts maximises the quantity of fuel LFB holds under its private bulk fuel storage arrangements.  

2.2.    LFB anticipates that by using the Government Commercial Agency (GCA) framework to run a competitive process to award the new contract, it will secure good value for money. Wholesale fuel prices remain uncertain, so if LFB identifies that its spending on fuel cards is likely to significantly exceed the amount set out in part 2, it will bring a further decision to the Deputy Mayor.  
 

3.1.    The LFC, and the Deputy Mayor for Planning, Regeneration and the Fire Service (the Deputy Mayor), are required to have due regard to the Public Sector Equality Duty (section 149 of the Equality Act 2010) when taking decisions. The Public Sector Equality Duty requires the identification and evaluation of the likely potential impacts, both positive and negative, of the decision on those with protected characteristics (see paragraph 3.3).  

3.2.    It is important to note that consideration of the Public Sector Equality Duty is not a one-off task. The duty must be fulfilled before taking a decision; at the time of taking a decision; and after the decision has been taken. 

3.3.    The protected characteristics are: age, disability, gender reassignment, pregnancy and maternity, marriage and civil partnership (but only in respect of the requirements to have due regard to the need to eliminate discrimination), race (ethnic or national origins, colour or nationality), religion or belief (including lack of belief), sex, and sexual orientation. 

3.4.    The Public Sector Equality Duty requires decision-takers in the exercise of all their functions, to have due regard to the need to: 

•    eliminate discrimination, harassment and victimisation and other prohibited conduct 
•    advance equality of opportunity between people who share a relevant protected characteristic and persons who do not share it 
•    foster good relations between people who share a relevant protected characteristic and persons who do not share it. 

3.5.    Having due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to: 

•    remove or minimise disadvantages suffered by persons who share a relevant protected characteristic where those disadvantages are connected to that characteristic 
•    take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it 
•    encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low. 

3.6.    The steps involved in meeting the needs of disabled persons that are different from the needs of persons who are not disabled include, in particular, steps to take account of disabled persons’ disabilities. 

3.7.    Having due regard to the need to foster good relations between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to: 

•    tackle prejudice  
•    promote understanding. 

3.8.    LFB reports that it has not carried out an Equalities Impact Assessment as the use of fuel cards does not impinge on protected characteristics
 

Procurement comments

4.1.    LFC-26-050 sets out how LFB will identify a fuel cards supplier in a way that is compliant with the Public Sector Procurement regulations and its own procurement standing orders. LFB proposes to tender the requirement via the Government Commercial Agency, previously known as the Crown Commercial Services, (GCA) RM6367 framework, which is compliant with the Procurement Act 2023.

Sustainability comments

4.2.    LFB has not identified any significant sustainability impacts from this request. LFC-26-050 notes that LFB’s most recent fuel cards contract included a requirement to provide data for carbon reporting. 

Conflicts of interest

4.3.    There are no conflicts of interest to declare from those involved in the drafting or clearance of this decision.
 

5.1.    LFC-26-050 seeks approval to commit revenue expenditure to procure a new two-year contract for fuel cards which will be a like-for-like replacement. 

5.2.    Due to the continuing uncertainty around the US-Iran conflict and the continuing blockade of the Strait of Hormuz, it is difficult to accurately predict how long the increase in UK fuel prices will last. The figures included in LFC-26-050 Part 2 assume, as a worst-case scenario, that the increase in UK fuel prices will last until the end of the 2026-27 financial year. LFB will monitor this assumption closely as part of its budget process for 2027-28.

5.3.    Once the new contract is in place, LFB expects to mitigate any budget pressure arising from increasing fuel prices initially through underspends elsewhere in the Fire Stations budgets. LFB will undertake regular monitoring and reporting on LFB’s revenue budget. If an in-year pressure cannot be mitigated through other underspends in the Fire Stations budgets, LFB proposes to fund this from its General Reserve. 

5.4.    LFB notes that LFC-26-050 is linked to the HVO Strategic Fuel Purchasing paper (LFC-26-049) which is also seeking approval to spend from the Deputy Mayor. LFB reports that both papers impact the Fire Stations Fuel budget and will be carefully monitored during the 2026- 27 financial year along with any required draw on the General Reserve.
 

6.1.    The LFC’s General Counsel’s department confirms the following. 

6.2.    Under section 9 of the Policing and Crime Act 2017, the London Fire Commissioner (the LFC) is established as a corporation sole with the Mayor appointing the occupant of that office. Under section 327D of the GLA Act 1999, as amended by the Policing and Crime Act 2017, the Mayor may issue to the Commissioner specific or general directions as to the manner in which the holder of that office is to exercise his or her functions.

6.3.    By direction dated 1 April 2018, the Mayor set out those matters, for which the LFC would require the prior approval of either the Mayor or the Deputy Mayor for Planning, Regeneration & the Fire Service (the Deputy Mayor).

6.4.    Paragraph (b) of Part 2 of the said direction requires the LFC to seek the prior approval of the Deputy Mayor before “[a] commitment to expenditure (capital or revenue) of £150,000 or above as identified in accordance with normal accounting practices…”. 

6.5.    The Deputy Mayor's approval is accordingly required to authorise the LFC to commit revenue expenditure of up to the amount set out in the part 2 report for the purposes of supplying fuel cards. 

6.6.    The General Counsel has reviewed the report and notes that the arrangement proposed is consistent with the LFC’s power under section 5A of the Fire and Rescue Services Act 2004 to do anything it considers appropriate for the purposes of the carrying out of any of its functions.

6.7.    Furthermore, under section 7 (2)(a) of the aforementioned legislation, the LFC has the power to secure the provision of personnel, services and equipment necessary to efficiently meet all normal requirements for firefighting.

6.8.    The General Counsel also notes that the proposed service will be procured in compliance with the Procurement Act 2023. The procurement route proposed will be via the Crown Commercial agency (GCA) RM6367 Framework. In the event that interim arrangements are required as mentioned at paragraph 1.4 of the report, then the most appropriate route that is compliant with LFB’s Scheme of Governance will apply.