Step-by-step guide to investigating procurement irregularities

A concise guide for investigative reporters on tracing, documenting and exposing irregularities in municipal procurement

Quick hook
A few routine files can crack a corrupt procurement cycle: a strangely timed contract amendment, an invoice paid before delivery, or a newly formed company that suddenly wins big tenders. This guide turns that breadcrumb trail into a repeatable investigation you can run in weeks—not years.

It shows which documents matter most, how to stitch them into a defensible timeline, how to map the people behind the deals, and what to do next if the paper trail points to wrongdoing.

What this guide helps you do
– Collect the right records fast
– Build a clear, auditable timeline
– Connect officials, intermediaries and suppliers
– Gauge legal, fiscal and public-interest impact
– Prepare a publishable, legally defensible dossier

Core documents to prioritize (high value, high yield)
– Procurement plans, tender notices and award letters (official portals, TED where applicable)
– Signed contracts, annexes, amendments and change orders
– Bid evaluation reports and scoring sheets
– Invoices, payment orders, bank confirmations and municipal ledgers
– Delivery notes, acceptance certificates, performance reports
– Internal memos, meeting minutes, approval stamps and circulation lists
– Email headers, audit logs, file timestamps and metadata
– Corporate registry extracts, beneficial‑ownership filings and director/shareholder records
– FOI responses, certified extracts and archived web pages (Internet Archive)

Practical tip: capture metadata.

A file’s timestamp, user ID and hash are often the evidence that converts a suspicion into a legal lead.

Step-by-step evidence collection
1. Start public: download tender pages, award notices and contracts from procurement portals. Save PDFs and screenshots; hash filenames if you can.

2. Request gaps: file FOI/FOIA requests for missing minutes, evaluation sheets and payment proofs—set calendar reminders for statutory deadlines.
3. Lock the forensics early: request server extracts or preserved email archives if access is restricted. Keep a chain-of-custody log.
4. Gather corporate records: pull registry extracts, incorporation dates and beneficial‑ownership data for every bidder and subcontractor.
5. Cross-check finances: match invoices to payment orders and bank entries. Flag payments without matching deliverables.
6. Archive everything: secure storage, consistent file names and an indexed master list for cross-referencing.

Building the reconstruction — a master timeline that survives scrutiny
– Work strictly chronologically. Start with the tender publication date and move forward to bid submissions, evaluation, award, signing, amendments and payments.
– For each timeline entry record: document title, source (URL or registry), file name, metadata (timestamps), and a one-line explanation of relevance.
– Link entries by unique IDs—contract number, procurement reference or company registration—to show chains of decision and money.
– Mark missing pieces as “open questions” and assign an investigator and due date to obtain them.
– Use version control or locked spreadsheets so every change to the timeline is auditable.

Mini example: If a contract amendment raising value is dated two weeks after an invoice appears, flag that node for forensic review—did the supplier bill before scope was formally expanded?

Mapping the people and entities (how to expose the network)
– Create short profiles for: procurement officers, evaluation panel members, signatories, supplier executives, intermediaries and any related parties.
– Sources for profiles: appointment notices, organizational charts, email headers, corporate filings, property records and social-media footprints.
– Look for red flags: late company incorporations, sudden capital injections, shared addresses or repeated payments to similar accounts.
– Map connections visually if you can—simple network graphs reveal repeated intermediaries and recurring vendors quickly.

Evidence standards: avoid speculation
– Every factual claim should link to a primary document, two independent sources, or one incontrovertible primary record.
– Where links are circumstantial, label them as such and list targeted steps to verify (FOI, bank subpoenas, witness interview).
– Preserve responses from implicated parties and append them to the dossier.

Assessment: what the documents can show you
– Procedural lapses: missing minutes, unexplained bypassing of open tender rules, or repeated emergency procurement justifications.
– Financial red flags: duplicated invoices, payments that exceed market benchmarks, or funds to newly formed entities with no track record.
– Conflicts of interest: undisclosed beneficial owners, intermediaries tied to officials, or family/previous-employment links.
– Metadata anomalies: timestamps that don’t align with institutional logs, or edits that suggest after-the-fact document manipulation.