Governing Innovation-oriented Public Procurement: a comparative analysis of regulation and actor dynamics in Germany and the UK

Public institutions frequently use innovation-oriented public procurement for a multitude of goals, such as providing more efficient public services, new opportunities for SMEs and start-ups, contributing to more sustainable supply chains, etc. This paper investigates how innovation-oriented public procurement (IOPP) develops in terms of regulation and actors by delving into the cases of Germany and the United Kingdom. By analysing legal documents and supporting literature, the paper examines how the regulation of IOPP and the constellation of its actors contribute to its development. Drawing upon the Varieties of Capitalism framework, the paper anticipates distinct models of IOPP between Germany - a Coordinated Market Economy and the United Kingdom - a Liberal Market Economy. The paper goes further to explore sectoral differences and their influence on the variation of IOPP. The findings reveal significant differences between the case studies in regulatory frameworks, actor constellations, and sectoral focuses, and demonstrate that IOPP policy trajectory is influenced both by national institutional frameworks and sector-specific dynamics. This article contributes to a better understanding of IOPP as a relatively new approach in public procurement, emphasising the role of actors and regulation in shaping it.