NHS Carbon Reduction Plans from April 2027: what suppliers need

Published 30 September 2026 — reviewed against the regs as they stand.

Quick answer: from 1 April 2027, NHS procurements above the published threshold ask every bidder for a published Carbon Reduction Plan (CRP). Contracts under £5 million a year (including VAT) need a 2024 CRP: UK operations, scope 1 and 2, and five named scope 3 categories. Contracts of £5 million a year or more, and every new framework and dynamic market, need a 2027 NHS CRP: a global boundary and every relevant scope 3 category. Both commit to net zero by 2050 or earlier, are approved by the board and published on your website, and follow the government’s PPN 006 template. The check is pass/fail: a plan that falls short stops the bid at the first stage.

What changes on 1 April 2027

NHS England published the new requirements on 9 June 2026. From 1 April 2027 they “replace the previous CRP and net zero commitment (NZC) requirements”, and no new procurement will use the Net Zero Commitment. They apply to procurements run under both the Procurement Act 2023 and the Provider Selection Regime. Procurements that started before 1 April 2027 carry on under the old guidance.

The biggest change is at the smaller end. Until 31 March 2027, a bid for an NHS contract under £5 million a year needs only a Net Zero Commitment. From 1 April 2027 the same bid needs a full Carbon Reduction Plan, with your emissions in it.

Which plan does your contract need?

The 2024 CRP applies to “procurements of lower value (below £5 million per annum including VAT, and above the relevant published procurement thresholds)”. Below the published threshold, neither plan is asked for. The threshold depends on the buyer and the type of contract, so check the tender notice.

The 2027 NHS CRP applies to “procurements of high value (£5 million per annum and above, including VAT)”, to all new frameworks “irrespective of the value of the framework contract, where relevant and proportionate”, and to all new dynamic markets whatever their value. For frameworks it is applied when the framework itself is tendered, not at each call-off. The owner of a framework or dynamic market can drop to the 2024 CRP where the fuller plan is “not proportionate and relevant”.

What a 2024 CRP must contain

• A net zero commitment: net zero by 2050 or earlier, for your UK operations as a minimum.
• Your emissions, baseline and current, for:
  • scope 1 — fuel burned in your own buildings and vehicles, and refrigerant leaks;
  • scope 2 — the electricity (and any heat) you buy;
  • five scope 3 categories, numbered as the GHG Protocol numbers them:
    • 4 — upstream transportation and distribution (freight and deliveries you pay for);
    • 5 — waste generated in operations;
    • 6 — business travel;
    • 7 — employee commuting;
    • 9 — downstream transportation and distribution (transport of what you sell, where you don’t pay for it).
• CO2e covering the seven greenhouse gases of the Kyoto Protocol.
• The environmental management measures in effect — what you already do to cut emissions.
• Board approval, or approval by a company director where there is no board.
• Publication: “clearly signposted and published on the supplier’s website”.
• Format: the structure and length of central government’s PPN 006 template, “though stylistic differences are acceptable”.

What the 2027 NHS CRP adds

The 2027 NHS CRP has the same list with two changes, both substantial:

• A global boundary. “A global geographical boundary must be applied for the net zero commitment and emissions reporting.” A UK subsidiary of an international group reports the group’s emissions, not just its own.
• All relevant scope 3. “Suppliers must report emissions for all Scope 3 categories deemed relevant”, and for any category judged not relevant, “an explanation… must be provided”. The guidance allows spend-based estimates.

There is a first-year allowance: in tenders run in the NHS 2027/28 financial year, gaps in scope 3 data can pass with “an acceptable explanation and plan for building capability”.

How the plan is checked in a tender

The plan sits under the conditions of participation. NHS England’s guidance is plain: “Suppliers whose 2027 NHS CRP or 2024 CRP does not meet the minimum requirements will not be able to proceed to the next stage”, and “CRPs will not be scored or compared against each other”. In the tender questions you confirm that you are publicly committed to net zero by 2050, and give baseline-year and reporting-year figures for scopes 1, 2 and 3.

So a CRP will not win you a contract, but a missing or deficient one loses it before the quality and price are looked at.

How recent your plan has to be

The NHS test is that the reporting period must fall “no more than 18 months prior to the date of the tender notice being published”. An older period fails unless there is an “acceptable explanation”. On our reading, a plan reporting the year to 31 March 2026 stays in date for tenders published up to about the end of September 2027. Buyers are also told to include “the requirement for annual updates within the terms and conditions”, so a contract you win will expect the plan to be refreshed each year.

Central government uses different wording (below), so a plan that is in date for one buyer may not be for another.

Central government contracts: PPN 006

Central government’s version is Procurement Policy Note 006, Taking account of Carbon Reduction Plans in the procurement of major government contracts. It applies to procurements started on or after 24 February 2025 (PPN 06/21 covers earlier ones), by central government departments, executive agencies and non-departmental public bodies, for contracts with an estimated value “above £5 million per year (including VAT)”.

Its technical standard asks for:

• a commitment to net zero by 2050 for your UK operations;
• scope 1 and 2 and the same five scope 3 categories (4, 5, 6, 7 and 9), for sources in the UK;
• a footprint that adheres to the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard, “conducted to a reasonable level of assurance”, using the UK Government’s published conversion factors;
• sign-off by a director (or equivalent, or a designated member of an LLP);
• review and update “within 6 months of your organisation’s financial year-end”;
• publication on your UK website, on the PPN 006 template.

It is also a check, not a score: PPN 006’s FAQ says plans “should not be ‘scored’”. Its recency test differs from the NHS one: the plan must have been published since the tender notice, or in the 12 months before it.

NHS Supply Chain: Evergreen Level 1 since April 2026

NHS Supply Chain runs its own gate. “From 6 April 2026, all suppliers submitting tenders will be required to have achieved Evergreen Level 1 at the point of tender close.” The Evergreen Sustainable Supplier Assessment is hosted on Atamis, and its criteria were updated in April 2026. NHS England describes Level 1 as having “Published a Carbon Reduction Plan aligned to PPN requirements, with a UK net zero commitment and emissions reporting”. Level 2 is aligned to the April 2027 requirements (global boundary, all relevant scope 3), and Level 3 adds 2045 targets that are independently validated.

For a supplier on NHS Supply Chain frameworks, a published CRP is therefore already the entry ticket, not a 2027 problem.

After 2027: the rest of the roadmap

The NHS Net Zero Supplier Roadmap keeps going after April 2027. Its next step, from April 2028, is that “New requirements will be introduced overseeing the provision of carbon footprinting for individual products supplied to the NHS”. NHS England’s supplier page also lists a 2030 step, under which suppliers “will only be able to qualify for NHS contracts if they can demonstrate their progress through published progress reports and continued carbon emissions reporting”; the June 2026 roadmap document does not repeat it, so treat the detail as unsettled.

The direction is clear either way. The plan you write for 2027 is the baseline you will be measured against later, so the numbers in it need to be ones you can reproduce.

Getting a plan ready: what to gather

A CRP reports a 12-month period, usually your financial year. Collecting the data is most of the work; the arithmetic is quick once you have it.

Then:

1. Pick a baseline year. Usually the first year you have good data for; the PPN 006 template asks for it (“Baseline year: 20XX”).
2. Convert to CO2e with the UK Government’s conversion factors. The 2026 set was published on 11 June 2026 and corrected on 31 July 2026 for values in the flat file “initially reported as 0” — use the corrected file. The factors are published under the Open Government Licence.
3. Write the measures and the commitment. What you already do, and your net zero year. The PPN 006 template also has a line for a five-year projection.
4. Get it approved by the board or a director.
5. Publish it on your website where a buyer can find it, and keep your workings. A buyer can ask how a figure was made.

Watch-outs

• Exactly £5 million. The NHS says “£5 million per annum and above”; PPN 006 says “above £5 million”. A contract valued at exactly £5 million a year is in scope for the 2027 NHS CRP but outside PPN 006.
• Three recency tests. NHS: a reporting period within 18 months of the tender notice. PPN 006: a plan published since the tender notice or in the 12 months before it. PPN 006’s technical standard: an update within 6 months of your financial year-end.
• Targets. The roadmap talks about suppliers publicly reporting targets, but the NHS minimum requirements set no numeric reduction target beyond the net zero commitment. Don’t promise a figure you can’t evidence.
• Assurance. PPN 006 wants the footprint “conducted to a reasonable level of assurance”. Keep the bills, surveys and records behind every number; a calculation is only as good as what went into it.

Free help

• The PPN 006 guidance, technical standard and template.
• The UK Business Climate Hub, whose policy content is reviewed and endorsed by DESNZ, and the SME Climate Hub calculators.
• NHS England’s Sustainable Supplier Accelerator, which the 2027 guidance points SMEs to.

Sources

• NHS England, 2027 NHS Carbon Reduction Plan requirements for the procurement of NHS goods, services and works (published 9 June 2026).
• NHS England, Carbon Reduction Plan requirements for the procurement of NHS goods, services and works — the rules until 31 March 2027 (version 3, 10 December 2025).
• NHS England, Market sounding findings: net zero supplier requirements from April 2027.
• NHS England, Greener NHS: suppliers and the Evergreen Sustainable Supplier Assessment.
• NHS Supply Chain, Evergreen: what suppliers need to know for April 2026 (26 February 2026).
• Cabinet Office, PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts (17 February 2025; template April 2025; FAQ July 2025).
• DESNZ, Greenhouse gas reporting: conversion factors 2026 (11 June 2026, corrected 31 July 2026).