NHS Carbon Reduction Plan: what suppliers need now and from April 2027

The NHS Net Zero Supplier Roadmap

In 2020 the NHS became the world's first health system to commit to reaching net zero. Its Delivering a net zero NHS strategy set two targets against a 1990 baseline: net zero by 2040 for the emissions it controls directly, with an 80% cut by 2028 to 2032, and net zero by 2045 for the emissions it can influence, with an ambition of an 80% cut by 2036 to 2039.

The 2045 target covers emissions the NHS influences through the goods and services it buys. In September 2021 the NHS England Public Board approved a roadmap to help suppliers align with the NHS net zero ambition up to 2030. The roadmap builds on government procurement policy, including PPN 006.

NHS England says support will be available at each stage of the roadmap for small and medium-sized enterprises (SMEs) and voluntary, community and social enterprises (VCSEs).

What NHS suppliers need now

For procurements that start before 1 April 2027, NHS England's current guidance (version 3, dated 10 December 2025) applies two tiers:

• Carbon Reduction Plan: contracts worth £5 million a year or more, including VAT, and all new frameworks and dynamic markets run by NHS organisations, whatever the contract value, where relevant and proportionate.
• Net Zero Commitment: contracts below £5 million a year, including VAT, that are above the relevant published procurement threshold.

VAT has been included in the £5 million figure since 24 February 2025, to match PPN 006 and the Procurement Act 2023. The rules apply to NHS organisations and anyone buying on their behalf, under both the Procurement Act 2023 and the Provider Selection Regime for health care services. The Provider Selection Regime has no spending thresholds of its own, so NHS England uses the Procurement Act thresholds as a guide.

The plan or commitment is in addition to the minimum 10% net zero and social value weighting that NHS procurements have used since April 2022. Where buyers assess it, the result is pass or fail: plans are not scored or compared against each other. Subcontractors are not in scope, although suppliers are encouraged to work with them to cut emissions.

What an NHS Carbon Reduction Plan must include

NHS England's Carbon Reduction Plan requirements align with PPN 006, and it accepts any current plan developed under the PPN 006 guidelines. The plan must:

• commit to net zero by 2050 or earlier, covering at least your UK operations (a global boundary is also accepted)
• give baseline and current emissions for scope 1 and 2 and five scope 3 categories: upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution
• report emissions in CO2e for the seven Kyoto Protocol gases: carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulphur hexafluoride and nitrogen trifluoride
• set out the environmental management measures in effect, such as certification schemes or specific carbon reduction measures, that you can apply when performing the contract
• be approved by the board, or by a company director if there is no board
• be clearly signposted and published on your website
• be updated at least once a year

It should follow the structure and length of the PPN 006 template, though stylistic differences are fine, and the emissions should be prepared in line with the PPN 006 technical standard. That standard requires the UK Government conversion factors for calculating CO2e.

A plan can cover a parent company as well as the bidding company if the bidder is wholly owned by the parent, the plan states that the parent's net zero commitment applies to the bidder, the measures can be applied by the bidder on the contract, and the plan is published on the bidder's own website.

The NHS Net Zero Commitment

The Net Zero Commitment is the lighter requirement for lower-value contracts. It is a public commitment to net zero by 2050 or earlier for your UK scope 1 and 2 emissions and the same five scope 3 categories, clearly signposted and published on your website. It should state the target year, the emissions covered and the name of the organisation making the commitment. NHS England suggests this format:

A supplier whose Carbon Reduction Plan meets the requirements already meets the Net Zero Commitment requirements. NHS England encourages a 2045 target, although 2050 meets the minimum.

For procurements starting on or after 1 April 2027, no new procurements will use the Net Zero Commitment. Lower-value contracts will need a full Carbon Reduction Plan instead.

What changes on 1 April 2027

NHS England published its 2027 requirements on 9 June 2026 and updated them on 21 July 2026. From 1 April 2027 they replace the current guidance. Procurements that started before that date carry on under the old rules. Both tiers now need a full plan:

Framework and dynamic market owners can apply the 2024 plan instead if they decide the 2027 plan is not proportionate or relevant for that framework or market. The 2027 NHS plan keeps the structure and length of the PPN 006 template but goes further:

• Global boundary. For the chosen reporting entity, the net zero commitment and emissions must use a global geographical boundary, so they are not limited to UK territorial emissions. The commitment is for the whole organisation and should, as a minimum, apply to the supplier dealing with the NHS. A parent can report on the supplier's behalf if it applies the same global boundary.
• All relevant scope 3. Baseline and current emissions must include every relevant scope 3 category under the GHG Protocol Corporate Value Chain (Scope 3) Standard, which sets out 15 categories to consider. You must explain why any category is not relevant. Estimates, such as spend-based methods, are allowed.
• The same core content. Net zero by 2050 or earlier, CO2e for the seven Kyoto gases, environmental management measures you can deliver on the contract, board or director approval, and publication on your website.

A plan that meets the 2027 NHS requirements also meets PPN 006. NHS England allows for first-year gaps: a supplier with gaps in the additional scope 3 data in NHS financial year 2027/28 tenders passes if it gives an acceptable explanation and a plan to report those emissions from the following year. For framework agreements and contracts under the Provider Selection Regime, NHS England asks buyers to write annual plan updates into the contract terms.

Board or director approval

Both NHS plans must be ‘board approved or company director approved if no board is in place’. The PPN 006 technical standard sets out how to show this:

• state that the board of directors (or equivalent management body) has approved the plan, with the date of approval; for an LLP, the members approve it
• have it signed off by a director (or equivalent), or a designated member for an LLP, giving their name, job title and the date
• you do not need a physical signature, but the plan should clearly state that it has been signed

A plan without a completed and signed declaration fails the assessment under both the PPN 006 guidance and the 2027 NHS requirements. The Evergreen assessment also expects board-level approval of carbon reduction initiatives, targets and emissions at every maturity level.

The Evergreen Sustainable Supplier Assessment

Evergreen is NHS England's online self-assessment for suppliers to share sustainability information with the NHS. It is hosted on Atamis, the health family e-commerce system, and any supplier that provides or plans to provide goods or services to NHS England, an integrated care board or an NHS trust in England can complete it. Suppliers receive a maturity score from Level 1 to Level 4. NHS England recommends completing it every year, and the score is valid for 12 months.

Evergreen is not designed to be scored or evaluated in procurement, with two exceptions:

• NHS Supply Chain frameworks. Suppliers bidding for future frameworks must submit an Evergreen assessment and reach Level 1. It replaces the Carbon Waste and Water Reduction Assessment that NHS Supply Chain used before.
• NHS England medicines tenders. Tenders run by the Medicines Value and Access directorates have required an Evergreen assessment since January 2024, and a carbon reduction plan that meets the requirements since April 2024.

At every level, the Carbon Reduction Plan and related information must have been published within the 12 months before the assessment is submitted, and emissions must follow the GHG Protocol.

NHS Carbon Reduction Plan vs PPN 006

PPN 006 is the Cabinet Office procurement policy note for central government departments, their executive agencies and non-departmental public bodies. NHS England builds on it, uses assessment questions aligned to the four in PPN 006, and accepts a PPN 006 plan for the 2024 tier. The main differences:

Approval rules are close. PPN 006 asks for sign-off by a director and a statement that the board (or equivalent management body) has approved the plan, with the date. NHS England asks for board approval, or a director's approval where there is no board.

How to get your plan ready

1. Check which tier applies: the contract value including VAT, and whether the procurement starts before or after 1 April 2027.
2. Gather a year of data for scope 1 and 2 (fuel, electricity, heat, company vehicles and refrigerant top-ups) and the five scope 3 categories, or every relevant scope 3 category for the 2027 NHS plan. If your company reports under SECR, your energy figures are a good starting point.
3. Calculate emissions in CO2e with the UK Government conversion factors, as the PPN 006 technical standard requires.
4. Set out the environmental management measures you have in place, get board or director approval, and record the approval date.
5. Publish the plan on your website, link to it prominently from your homepage, and update it at least once a year.
6. Complete the Evergreen assessment on Atamis if you bid for NHS Supply Chain frameworks or NHS England medicines tenders.

If you cannot get all the data, NHS England allows, in exceptional circumstances, a plan with the emissions you do have, an explanation of what is missing and the steps you will take to improve the data. The buyer assesses the explanation case by case.

Our Carbon Reduction Plan builder produces a plan in the PPN 006 format, the format NHS England uses for the 2024 tier, as Word and PDF files, for £99. It does not produce the 2027 NHS plan, which needs global emissions and all relevant scope 3 categories.

Sources

1. NHS England: Suppliers, including the net zero supplier roadmap (checked 10 October 2026)
2. NHS England: Carbon reduction plan and net zero commitment requirements for the procurement of NHS goods, services and works (version 3, 10 December 2025) (checked 10 October 2026)
3. NHS England: 2027 NHS carbon reduction plan requirements for the procurement of NHS goods, services and works (published 9 June 2026, updated 21 July 2026) (checked 10 October 2026)
4. NHS England: Evergreen sustainable supplier assessment (checked 10 October 2026)
5. NHS England: Delivering a net zero NHS (checked 10 October 2026)
6. Cabinet Office: PPN 006, Taking account of Carbon Reduction Plans in the procurement of major government contracts (checked 10 October 2026)
7. Cabinet Office: PPN 006, Taking account of Carbon Reduction Plans (HTML) (checked 10 October 2026)
8. Cabinet Office: PPN 006 technical standard for completion of Carbon Reduction Plans (checked 10 October 2026)
9. Cabinet Office: PPN 006 guidance on adopting and applying conditions of participation (checked 10 October 2026)