Carbon reduction plans for public contracts

When a buyer asks for one

Central government: PPN 006

The rule is Procurement Policy Note 006, updated in February 2025 for the Procurement Act 2023. It applies to central government departments, their executive agencies and non-departmental public bodies, for procurements advertised on or after 24 February 2025. Procurements started before then follow the older PPN 06/21. Under PPN 006 an in-scope buyer asks for a plan when:

• the contract's estimated value is above £5 million a year, including VAT. The value is averaged over the life of the contract, so a four-year contract worth £21 million in total is in scope even if year one is under £5 million;
• for a framework or dynamic market, an individual contract awarded under it is expected to be worth more than £5 million a year; and
• the buyer judges a plan relevant to the contract and proportionate to its nature, complexity and cost. The PPN expects that to be true in most cases, for example where the work uses buildings, transport or natural resources.

The plan is a condition of participation, assessed pass or fail. The PPN 006 FAQs say plans are not scored or compared with each other: a firm committed to net zero by 2030 gains nothing over one committed to 2050. The FAQs also say PPN 006 is not mandatory for the devolved administrations in Scotland, Wales and Northern Ireland. Councils, universities and housing associations are outside its scope, but their own tender documents can still ask for a plan, so read them.

Wales and Scotland have their own rules. In Wales, WPPN 006 asks Welsh Government departments, NHS Wales bodies and Welsh Government sponsored bodies to consider a carbon reduction plan in procurements of £6 million and over, and recommends it to other Welsh public bodies as best practice. In Scotland, buyers can use question 4C7 of the Single Procurement Document to ask for evidence of how you will address the climate emergency, with a Bidder Climate Change Plan template at the selection stage.

The plan is needed from the organisation that would sign the contract. Subcontractors do not need one, each member of a consortium does, and a firm trading for less than 12 months can confirm its net zero commitment and publish a full plan as soon as it can (PPN 006 assessment guidance, paragraphs 12 and 13).

NHS England asks more widely

NHS England's net zero supplier roadmap builds on PPN 006 but reaches further down. Its rules are written for procurement in England: NHS bodies in Wales, Scotland and Northern Ireland follow their own nation's rules. Its current requirements (version 3, December 2025) work in two tiers:

A net zero commitment is a public statement that you will reach net zero by 2050 or earlier for Scope 1, Scope 2 and the same five Scope 3 categories, naming the year, the emissions it covers and the entity committing. NHS England accepts any current plan written to PPN 006, applies the rules under the Provider Selection Regime for health care services too, and offers suppliers a plan checking service and webinars. Since April 2022 every NHS procurement has also given at least 10% of its weighting to net zero and social value.

The 2027 requirements, published in June 2026, apply to procurements started on or after 1 April 2027 and end the net zero commitment for new procurements. At £5 million a year or more, a 2027 NHS plan must cover your Scope 1 and 2 emissions and all relevant Scope 3 emissions across the Greenhouse Gas Protocol's 15 categories, with a net zero commitment for the whole organisation. The commitment and the emissions are global, not UK operations only. For tenders in the NHS's 2027/28 financial year, a gap in the extra Scope 3 data can pass if you explain it and set out how you will report it from the following year. A plan that meets the 2027 NHS rules also meets PPN 006. If you sell to the NHS, a PPN 006 plan written now is the right starting point either way.

Further ahead, the roadmap says NHS England will bring in requirements for the carbon footprint of individual products from April 2028, and that from 2030 suppliers will only qualify for NHS contracts if they can show their progress through published progress reports and continued emissions reporting.

What the plan must contain

The technical standard and the template set the content. A plan covers your UK operations and has six parts, in this order:

1. Commitment to net zero by 2050 at the latest. An earlier year is fine.
2. Baseline emissions: the year you measure progress from. If you have never measured your emissions, your current reporting year becomes the baseline, and you say so.
3. Current emissions for the latest reporting year.
4. Reduction targets: the emissions you project over the next five years, in tonnes and as a percentage.
5. Carbon reduction projects: what you have done since the baseline (LED lighting, a travel policy, electric vehicles, ISO 14001) and what you plan next. These must be measures you can apply while doing the contract.
6. Declaration and sign-off, in the template's wording.

Figures are in tonnes of carbon dioxide equivalent (CO2e), covering the seven greenhouse gases named by the Kyoto Protocol, worked out with the UK government's conversion factors for company reporting for your reporting year and following the Greenhouse Gas Protocol corporate standard. There is no requirement to have your footprint audited.

Sign-off, publishing and keeping it current

• The plan states that the board of directors (or equivalent management body) approved it, with the date, and is signed off by a director (or equivalent), named with their job title and the date. For an LLP, the members approve and a designated member signs. A physical signature is not needed. Neither PPN 006 nor NHS England says how a sole trader or an ordinary partnership signs (NHS England accepts a company director's approval where there is no board), so if that is you, ask the buyer.
• Publish it on your UK website with a link in a prominent place on your homepage. With no website, you must send a copy in writing to anyone who asks within 30 days.
• Update it at least once a year, within six months of your financial year end. One current plan does for every tender.

How a buyer checks it

The assessment guidance gives every in-scope buyer the same four questions: confirm that you have published a plan to the required standard, with a link to it; confirm you are committed to net zero by 2050, with your target year; then your baseline and reporting year emissions for Scopes 1, 2 and 3. Questions 1 and 2 are pass or fail. The emissions figures are for information only.

A plan fails if it:

• does not commit to net zero by 2050;
• leaves out some or all of the required emissions without an acceptable explanation;
• says nothing about the environmental measures you will apply on the contract;
• has no completed, signed declaration; or
• reports on a period more than 18 months before the tender notice, without an acceptable explanation (for NHS England until April 2027, 12 months before the procurement started).

The plan must also have been signed off and published since the tender notice, or in the 12 months before it. The FAQs are clear that a corporate social responsibility statement, a policy or a Science Based Targets commitment cannot be used instead of the template, though you can mention them inside your plan. Higher emissions than last year do not fail you.

Writing one yourself

For a firm with one or two premises and a few vehicles, the figures come from bills and records you already keep.

1. Download the Carbon Reduction Plan template from the PPN 006 page on GOV.UK. It is an .odt file, which Word opens.
2. Pick a 12-month reporting year, usually your financial year, and use the same period for every figure.
3. Gather the figures: electricity and gas in kWh from your bills, fuel or mileage for company vehicles, any refrigerant top-ups, business travel in vehicles you do not own, an estimate of staff commuting, waste by weight and type, and any deliveries you pay a carrier for.
4. Convert each one with the government conversion factors for that year, and add them up by scope.
5. Write the targets and the measures in plain words, using what you have actually done.
6. Have the board approve it and a director sign it off, then publish it and link it from your homepage.
7. Put a reminder in the diary to update it within six months of your next year end.

The UK Business Climate Hub, a collaboration between government and business groups that NHS England points small suppliers to, has free tools and guidance for small and medium-sized firms.

When paying someone helps

A specialist is worth the money when the arithmetic is harder than the template suggests: a large vehicle fleet, manufacturing or logistics, several sites, a group of companies where the bidding entity's emissions have to be separated from its parent's, an NHS tender that needs the fuller 2027 plan, or a deadline too close to do it yourself. Before you pay, ask:

• Is the price fixed, and what would make my plan cost more?
• Which conversion factors will you use, and will I get the workings so I can check every figure?
• Does the plan follow the PPN 006 template and the five Scope 3 categories, or the 2027 NHS rules if I need those?

The plan is yours, not theirs: the PPN 006 FAQs say a plan prepared by a third party must still meet the requirements, and your own director signs it. As no audit is required, do not pay for verification unless a buyer asks for it.

A carbon reduction plan is one of the items in our before you bid checklist, and it is separate from social value: environmental commitments for a particular contract can be scored at the award stage under the Social Value Model, explained in our social value guide.

Sources

• PPN 006: Taking account of Carbon Reduction Plans (Cabinet Office, updated 10 July 2025)
• PPN 006: Technical standard for completion of Carbon Reduction Plans (Cabinet Office)
• PPN 006: Guidance on adopting and applying conditions of participation (Cabinet Office)
• PPN 006: Frequently asked questions (Cabinet Office, June 2025)
• Carbon Reduction Plan template (Cabinet Office, April 2025)
• UK government conversion factors for company reporting (Department for Energy Security and Net Zero)
• Greener NHS: suppliers and the net zero supplier roadmap (NHS England)
• Carbon reduction plan and net zero commitment requirements (NHS England, version 3, December 2025)
• 2027 NHS carbon reduction plan requirements (NHS England, June 2026, updated July 2026)
• WPPN 006: Decarbonisation through procurement, taking account of carbon reduction plans (Welsh Government, February 2025)
• Procurement and climate change (Scottish Government)
• UK Business Climate Hub

All opened and checked on 29 October 2026.

With thanks to Oz Kilbride of Carbon Plan Desk, who reviewed this guide in October 2026.