PPN 006 and NHS Contracts: Carbon Reduction Plan Requirements
Author | Tim Maiden
Reading Time - 7 mins
Key takeaways
- The NHS applies Carbon Reduction Plan requirements to all new procurements that are in scope of the NHS guidance, not just contracts and frameworks worth £5 million or more.
- Assessment is pass or fail against four standard checks. Your emissions are never scored against other bidders.
- NHS suppliers must also complete the Evergreen Sustainable Supplier Assessment, with a compliant Carbon Reduction Plan being a core requirement.
- From 1 April 2027, higher-value procurements and new frameworks will require an enhanced 2027 NHS Carbon Reduction Plan, while lower-value procurements will continue to require the current NHS Carbon Reduction Plan.
- The enhanced 2027 NHS Carbon Reduction Plan must include all relevant Scope 3 emissions.
Does PPN 006 apply to NHS contracts?
In short: Yes. The NHS applies Carbon Reduction Plan requirements to all new procurements that are in scope of its guidance, not just those worth £5 million or more.
PPN 006 is the UK government procurement policy that requires suppliers to publish a Carbon Reduction Plan committing to net zero by 2050. Across most of the public sector the formal threshold is contracts or frameworks worth £5 million a year or more. The NHS has gone further. Since April 2024, the NHS has required Carbon Reduction Plans for all in-scope new procurements.
This catches many suppliers out. A business quite reasonably reads that PPN 006 is for £5 million contracts, concludes it does not apply to them, and then finds a full Carbon Reduction Plan requirement sitting in the conditions of participation for a much smaller NHS tender. If the NHS is your customer, contract value alone is not your guide.
This article covers what the NHS asks for specifically. If you need the full detail on writing a compliant plan, from data gathering to director sign off, start with our complete PPN 006 guide.
Why the NHS goes further than the rest of the public sector
In short: The NHS aims to be the world's first net zero national health service, with targets of 2040 for the emissions it controls directly and 2045 for the emissions it can influence, including its supply chain. Most of its footprint sits with suppliers, so suppliers carry much of the work.
Net zero by 2040
The target for the NHS Carbon Operational Footprint, the emissions the NHS controls directly, such as its buildings, fleet and energy.
Net zero by 2045
The target for the full NHS Carbon Footprint, which includes the emissions the NHS can influence, including everything it buys from suppliers.
The supply chain is the big one
The majority of the NHS carbon footprint comes from the goods and services it buys, which is why supplier requirements sit at the heart of the plan.
A roadmap, not a one off
The NHS net zero supplier roadmap tightens requirements in stages through to 2030, so what you need today is the floor, not the ceiling.
None of this means the NHS expects your business to hit net zero by 2040. Supplier requirements are anchored to the UK's 2050 target. But it explains why carbon questions now appear in NHS tenders of every size, and why they will keep getting more demanding.
Current NHS position: A PPN 006 Carbon Reduction Plan is required
In short: Since April 2024, in-scope NHS suppliers have needed a Carbon Reduction Plan. The key distinction is between the current NHS Carbon Reduction Plan requirements and the enhanced 2027 NHS Carbon Reduction Plan requirements for higher-value procurements and new frameworks from April 2027.
The current NHS Carbon Reduction Plan
The current NHS requirement follows the existing PPN 006-style Carbon Reduction Plan approach. Suppliers must publish a compliant plan that includes a net zero by 2050 commitment, baseline and current emissions for Scope 1, 2 and a limited sub-set of Scope 3, reduction measures, director-level approval and publication on the supplier’s website. This is the requirement lower-value NHS procurements continue to follow, including after April 2027.
The enhanced 2027 NHS Carbon Reduction Plan
From 1 April 2027, the enhanced 2027 NHS Carbon Reduction Plan applies to high-value NHS procurements of £5 million per annum and above, including VAT, and to all new NHS frameworks and dynamic markets where the requirement is relevant and proportionate. This enhanced version expands the reporting boundary to all relevant global Scope 1, 2 and 3 emissions. It does not remove the current CRP requirement for lower-value procurements; it creates a higher reporting standard for the higher tier.
What NHS buyers actually check: the four pass or fail questions
In short: NHS carbon requirements are assessed as pass or fail conditions of participation, built around four standard checks: a compliant published plan, a net zero commitment, baseline emissions data and current emissions data. Your footprint is never scored against other bidders.
NHS England sets standard assessment questions so that every buyer checks the same things in the same way.
For a Carbon Reduction Plan procurement, the buyer is verifying four things:
- A compliant plan, with a working link. You have submitted a Carbon Reduction Plan that follows the required format, and it is published at a live URL on your website.
- A net zero commitment. The plan confirms your commitment to net zero by 2050 or earlier, covering your UK operations as a minimum.
- Baseline emissions. The plan reports a baseline year for Scope 1, Scope 2 and the required Scope 3 categories, in CO₂e.
- Current emissions. The plan reports your most recent reporting year on the same basis.
Two practical points follow from the way this is assessed. First, it is pass or fail. Nobody compares your tonnage with the next bidder's, so a big footprint honestly reported beats a small one badly presented every time. Second, where you are applying to a framework or dynamic market, the assessment happens when you join, not at each call off.
What your plan must cover for an NHS bid
In short: The NHS follows the standard PPN 006 content requirements: a 2050 net zero commitment, Scope 1, Scope 2 and the necessary Scope 3 categories against a baseline, your reduction measures, board level sign off, and publication on your website with an annual update.
The content of the plan itself is the same as for any PPN 006 procurement, so we will not repeat the full build process here. In summary, your plan needs a net zero by 2050 commitment for at least your UK operations, emissions reported in CO₂e across Scope 1, Scope 2 and the required Scope 3 categories, details of your completed and planned carbon reduction initiatives, sign off by your board and a director, and publication on your website with a refresh at least every 12 months.
Use the government's official template, and see our step-by-step guide for how to gather the data and complete it.
NHS tender on the horizon?
We build compliant Carbon Reduction Plans with you, in plain English, and we have turned them around in as little as 36 hours when a deadline demanded it. See how we helped one business that was under big time pressure.
The Evergreen Sustainable Supplier Assessment
In short: Evergreen is the NHS's own self-assessment of a supplier's sustainability maturity. It sits alongside PPN 006 rather than replacing it, and a Carbon Reduction Plan is a core requirement within it. If you supply the NHS, expect to complete both.
The Evergreen Sustainable Supplier Assessment asks you to report where your business stands against the NHS net zero and sustainability agenda, and gives you a maturity level in return. It is free to complete, and NHS buyers increasingly ask for your Evergreen assessment as part of tendering or supplier relationship management.
The relationship between the two is simple to remember. PPN 006 is the pass or fail gate on a specific procurement. Evergreen is the ongoing picture of your sustainability maturity as an NHS supplier. Your Carbon Reduction Plan feeds both, which is another reason to build it properly once and keep it current, rather than treating it as paperwork for a single bid.
We support lots of businesses to complete their Evergreen Assessment. Reach out if you need help.
What changes in April 2027
In short: From 1 April 2027, NHS procurement moves to a new two-tier CRP model. Higher-value procurements and new frameworks must meet the enhanced 2027 NHS Carbon Reduction Plan requirements. Lower-value in-scope procurements continue with the current NHS Carbon Reduction Plan requirements.
NHS England has published the 2027 requirements in advance to give suppliers time to prepare. The biggest changes for the enhanced higher tier are the reporting boundary and Scope 3 coverage. The enhanced plan needs to cover relevant global Scope 1, 2 and 3 emissions, rather than being limited to the current CRP scope. This means many suppliers will need better data from overseas operations, purchased goods and services, supply chains, logistics and product-related emissions.
Lower-value procurements below £5m will continue with the current NHS Carbon Reduction Plan requirements.
Procurements that begin before 1 April 2027 continue under the current NHS CRP requirements. Procurements from that date will apply the relevant tier: current NHS CRP requirements for lower-value in-scope procurements, and the enhanced 2027 NHS CRP for high-value procurements and new frameworks. If a £5 million plus NHS contract or framework is in your pipeline for 2027 onwards, start widening your Scope 3 measurement now.
Special cases: NHS to NHS, subcontractors and small suppliers
NHS bidding to NHS
NHS organisations bidding for NHS contracts can rely on their published Green Plan instead of a Carbon Reduction Plan.
Subcontractors
Subcontractors are not in scope. The requirement sits with the bidding entity, though lead suppliers are encouraged to bring their supply chain along, and often do.
SMEs and VCSEs
The guidance suggests that smaller organisations can submit partial emissions data with a documented explanation, although there is no guarantee that this will be accepted.
Buyers can also disapply the requirements in genuinely exceptional circumstances, for example where applying them would distort a market and put service delivery at risk. Do not plan around this. Exceptions are for buyers to invoke, rarely, and never something a supplier can rely on.
Where NHS bids fail on carbon requirements
These are the patterns we see most often when suppliers stumble at the carbon gate of an NHS tender.
- Assuming the £5 million threshold protects you. It does not, because the NHS applies CRP requirements to lower-value in-scope procurements as well as to higher-value contracts and frameworks.
- Submitting an ESG statement instead of a Carbon Reduction Plan. The NHS checks for the specific required format and content, and a general sustainability document fails the check.
- Discovering Evergreen at the deadline. The assessment is not difficult, but doing it well in the final 48 hours of a bid, alongside everything else, is an avoidable scramble.
- A plan that exists but is not published. The published link is part of the pass. A plan sitting in a drive folder, or behind a broken URL, counts as no plan at all.
- Emissions data that has gone stale. Your most recent reporting year must be recent enough to be valid when you bid, which trips up suppliers who treated the plan as a one off exercise.
- Relying on a group plan you are not entitled to use. The bidding entity generally needs its own plan. Parent company plans only cover a subsidiary under specific conditions.
How to get NHS-ready before the tender lands
In short: Build your Carbon Reduction Plan before you need it, publish it, complete Evergreen, and register on the Central Digital Platform. A supplier with those four in place can respond to any NHS tender's carbon requirements in minutes rather than weeks.
Measure your footprint. Gather twelve months of data and calculate Scope 1, Scope 2 and the five required Scope 3 categories using the Greenhouse Gas Protocol and current UK government conversion factors.
Complete the official template and publish. Move your figures, targets and reduction measures into the government template, get director sign off, and publish it at a stable URL on your website.
Complete the Evergreen assessment. Do it once, properly, and keep it updated as your sustainability work progresses.
Register on the Central Digital Platform. You will need to share supplier information through it for public sector tenders, and registering early avoids a last minute blocker.
Diarise the annual refresh. Update your plan within six months of each financial year end so it is always valid when an opportunity appears.
Look ahead to 2027. If £5 million plus NHS work or frameworks are in your pipeline, start extending your measurement to relevant global Scope 1, 2 and 3 emissions now. If you mainly bid for lower-value NHS work, do not assume the requirement disappears: keep your current Carbon Reduction Plan compliant and up to date.
If you would rather have support, our PPN 006 Carbon Reduction Plan service takes you from raw data to a published, compliant plan, with real people rather than software doing the guiding.
