What is PPN 006?
PPN 006 is a Procurement Policy Note from the Cabinet Office called "Taking account of Carbon Reduction Plans in the procurement of major government contracts". It was published on GOV.UK on 17 February 2025 as an update of PPN 06/21, which was first issued in June 2021.
It tells central government buyers to make a Carbon Reduction Plan (CRP) a condition of participation in major contracts. The plan confirms the bidder's commitment to reach net zero by 2050, gives its current carbon footprint and sets out the environmental management measures it has in place and will use on the contract.
Three supporting documents sit alongside the note: a technical standard for completing the plan, guidance for buyers on applying it as a condition of participation, and a set of frequently asked questions, added in July 2025. The official template was added as an editable file on 17 April 2025.
The Cabinet Office says the February 2025 update "does not constitute a change in policy". It brings the wording into line with the Procurement Act 2023 and the Procurement Regulations 2024.
PPN 006 or PPN 06/21: which one applies?
It depends on when the procurement started. Central government buyers must apply PPN 006 to relevant procurements advertised on or after 24 February 2025, the date from which the Procurement Act 2023 applies to new procurements.
For procurements commenced, and contracts awarded, before 24 February 2025, the Cabinet Office says to refer to PPN 06/21. PPN 06/21 covers procurements subject to the Public Contracts Regulations 2015 that were advertised on or after 30 September 2021.
| When the procurement started | Legal framework | Policy note |
|---|---|---|
| Advertised on or after 24 February 2025 | Procurement Act 2023 | PPN 006 |
| Commenced before 24 February 2025 | Public Contracts Regulations 2015 | PPN 06/21 |
The plan itself barely changed. The sections, the five Scope 3 categories and the sign-off rules are the same. What changed is the legal framework, the contract value test and how the plan is assessed, set out in the comparison below.
You will see PPN 06/21 written in several ways, such as PPN 0621, PPN 06 21 or PPN 06-21. They all refer to the same 2021 note.
Which contracts need a Carbon Reduction Plan?
PPN 006 applies to all central government departments, their executive agencies and non-departmental public bodies. The test is the contract, not the size of the bidder.
- Contract value: an estimated value above £5 million a year, including VAT. This is the advertised contract value averaged over the life of the contract, so a four-year contract worth £21 million in total is in scope even if the first year is worth less than £5 million.
- Contract type: public contracts for goods, services or works under the Procurement Act 2023. Special regime contracts are excluded. Section 10(6) of the Act defines these as concession contracts, defence and security contracts, light touch contracts and utilities contracts.
- Frameworks and dynamic markets: covered only where the individual value of a contract awarded under them is expected to be greater than £5 million a year, including VAT.
- Relevance: buyers apply it unless it would not be relevant to the contract or proportionate to its nature, complexity and cost. The PPN expects it to be relevant in most cases, for example where delivering the contract uses buildings, transports goods or people, or uses natural resources.
The buyer guidance gives two examples of exceptional circumstances where it may not be relevant or proportionate: a civil emergency, and a market so distorted, narrowed or struggling that delivery of public services is likely to be put at risk or value for money severely compromised. The list is not exhaustive, and departments would need to document their reasons for not applying it.
On the devolved governments in Scotland, Wales and Northern Ireland, the FAQ says PPN 006 "is not stated to be mandatory for Devolved Administrations".
NHS contracts have their own rules
NHS England's Carbon Reduction Plan requirements build on PPN 006. NHS contracts of £5 million a year or more (including VAT) already need a plan. For NHS procurements starting on or after 1 April 2027, contracts below £5 million a year (and above the procurement thresholds) need a plan in the PPN 006 format, and contracts of £5 million a year or more need the fuller 2027 NHS plan, which covers all relevant Scope 3 emissions. NHS England says any existing, current plan written to PPN 006 will be accepted for its 2024 CRP requirements.
What a PPN 006 Carbon Reduction Plan must contain
The content is set by the PPN 006 template and its technical standard. A plan must:
- Confirm the organisation's commitment to net zero by 2050 at the latest. An earlier year is fine: the FAQ gives the example of one supplier committing to 2050 and another to 2030, and both pass.
- Give a baseline year and its emissions. If you have never measured your emissions, say so and use your first reporting period as the baseline.
- Report current emissions for a single year, using the same reporting period throughout the plan.
- Include all Scope 1 and Scope 2 emissions. Scope 2 covers purchased electricity, steam, heat and cooling.
- Include five Scope 3 categories: 4, 5, 6, 7 and 9 (see the table below).
- Report in tonnes of CO2e, covering the seven Kyoto Protocol gases listed in the technical standard, which include hydrofluorocarbons (HFCs) used as refrigerants. Calculations must use the UK Government conversion factors.
- Cover emissions from your sources in the United Kingdom, drawing the boundary by financial control, operational control or equity share.
- Set emissions reduction targets. The template words this as a projection "over the next five years".
- Set out the environmental management measures in effect that you will be able to apply when performing the contract. The template gives examples such as ISO 14001 or PAS 2060 certification, LED and PIR lighting controls, less company travel and an electric fleet. Future projects are for information only.
- Include the standard declaration and clearly state that the board of directors (or equivalent management body) approved the plan, with the date of approval. For a limited liability partnership, the members approve it.
- Be signed off by a director (or equivalent), or a designated member of an LLP, with their name, job title and the date. A physical signature is not needed, but the plan should clearly state that it has been signed.
- Be published on your UK website, with the link in a prominent place on your homepage. If you have no website, you must provide a copy in writing to anyone who asks within 30 days.
| Scope 3 category | What it covers |
|---|---|
| 4. Upstream transportation and distribution | Transport of goods you buy between your direct (tier 1) suppliers and your own operations, plus transport and distribution services you pay for, including deliveries of products you sell, in vehicles and facilities you do not own or control |
| 5. Waste generated in operations | Disposal and treatment of your waste in facilities you do not own or control |
| 6. Business travel | Staff travel for work in vehicles you do not own or operate, such as trains, flights and employees' own cars |
| 7. Employee commuting | Staff travel between home and work in vehicles you do not own or operate. Homeworking emissions are optional |
| 9. Downstream transportation and distribution | Transport and storage of products you sell, between your operations and the end consumer, where you do not pay for it |
There is no requirement to have your footprint audited. The technical standard names ISO 14064-3 and ISAE 3410 as widely used verification standards but makes neither compulsory.
How buyers check a plan, and what fails
The plan is a pass or fail condition of participation. It is not scored or compared with other bidders' plans, and the emissions figures are for information only. The FAQ says a rise in emissions compared with the baseline or a previous year does not mean the plan fails.
Buyers check that the plan is published on your website, has been signed off at an appropriate level, and was published since the tender notice or in the 12 months before it. They then apply the assessment table from the buyer guidance.
| What the buyer finds | Outcome |
|---|---|
| A plan with a net zero by 2050 commitment, emissions for all required scopes, environmental management measures for the contract, and a reporting period no more than 18 months before the tender notice | Pass |
| No Carbon Reduction Plan submitted (businesses trading for less than 12 months are treated differently) | Fail |
| No commitment to net zero by 2050 | Fail |
| Emissions missing for some or all scopes, with no explanation | Fail |
| Emissions missing for some or all scopes, with an acceptable explanation | Pass |
| Reporting period more than 18 months before the tender notice was published, with no explanation | Fail |
| Reporting period more than 18 months before the tender notice, with an acceptable explanation | Pass |
| No environmental management measures that you will be able to apply when performing the contract | Fail |
| No completed and signed declaration in the plan | Fail |
| A parent company plan that does not meet the parent company conditions | Fail |
A corporate social responsibility statement, policy or case study cannot be accepted instead of a plan. Commitments under the Science Based Targets initiative or Race to Zero are not a substitute either, although you can list them as one of your environmental management measures.
The FAQ says a supplier only needs one plan, valid for 12 months, which can be used for every procurement where the measure applies.
PPN 06/21 vs PPN 006: what changed
| PPN 06/21 | PPN 006 | |
|---|---|---|
| Legal framework | Public Contracts Regulations 2015 | Procurement Act 2023 and Procurement Regulations 2024 |
| Applies to | Procurements advertised on or after 30 September 2021; still used for procurements commenced before 24 February 2025 | Relevant procurements advertised on or after 24 February 2025 |
| Contract value test | Above £5 million a year, excluding VAT | Above £5 million a year, including VAT |
| Where it sits in the process | Selection criterion, in the selection questionnaire | Condition of participation |
| Multi-supplier arrangements | Framework agreements and dynamic purchasing systems | Frameworks and dynamic markets |
| Age of the reporting period | No more than 12 months before the procurement commenced | No more than 18 months before the tender notice was published |
| Template declaration | "Completed in accordance with PPN 06/21"; Scope 1 and 2 reported "in accordance with SECR requirements" | "Completed in accordance with PPN 006"; SECR requirements "(where required)" |
| Plan content | Net zero by 2050, Scope 1, Scope 2, Scope 3 categories 4, 5, 6, 7 and 9, board approval, director sign-off, published on your website | Unchanged |
Counting VAT in the value test means more contracts can be caught. NHS England notes that this "could mean that more activity is captured compared to the application of previous PPN 06/21".
Streamlined Energy and Carbon Reporting (SECR) applies to quoted companies, large unquoted companies and large LLPs. The PPN 006 declaration says Scope 1 and Scope 2 are reported in line with SECR "(where required)". Smaller suppliers outside SECR still report all their Scope 1 and Scope 2 emissions in the plan.
If you already have a plan written for PPN 06/21, most of the content carries over. Update the declaration to refer to PPN 006, bring the figures up to a recent reporting year and check that the plan states the board approval date and the sign-off date.
Parent companies, consortiums, subcontractors and new businesses
- Subsidiaries: the plan should cover the bidding entity. A parent company's plan is only accepted if the bidder is wholly owned by the parent, the plan states that the 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 Cabinet Office says relying on a parent's plan may only be a temporary measure.
- Consortiums: each consortium member completes its own plan.
- Subcontractors: PPN 006 does not require a plan from subcontractors unless they are also bidding in their own right. Some main contractors ask their suppliers for emissions data under their own policies, which is separate from PPN 006.
- New businesses: a supplier trading for less than 12 months should not be disadvantaged. It should confirm its commitment to net zero by 2050 and publish a full plan as soon as possible.
- Overseas suppliers: the rules apply equally. A supplier with no UK operations, and so no UK emissions data, can meet them by confirming its net zero commitment and describing the environmental management measures it has in place where it operates.
How to write a PPN 006 Carbon Reduction Plan
- Pick your reporting year, usually your latest complete financial or calendar year, and use the same period for every figure. The technical standard says to review and update the plan within 6 months of your financial year end.
- Decide your boundary for your UK emissions sources, using one method: operational control, financial control or equity share.
- Gather the activity data: gas, electricity and any heat or steam from bills, fuel for company vehicles, refrigerant topped up in air conditioning, deliveries, waste, business travel and commuting.
- Convert each figure to CO2e with the UK Government conversion factors for the year your data covers, and add up Scope 1, Scope 2 and each Scope 3 category.
- Fill in the GOV.UK template: your net zero year, baseline, current emissions, a five-year reduction target and the measures you have in place.
- Get board approval and a director's sign-off, and record the name, job title and both dates in the plan.
- Publish it on your UK website with a clear link from the homepage. Keep earlier plans online and update the plan at least once a year.
To see every step with real numbers, read our Carbon Reduction Plan example for a fictional 45-person company, calculated with the 2025 UK Government factors.
Build your plan with the official factors
Our Carbon Reduction Plan builder asks for your energy, fuel, travel and waste figures, applies the UK Government conversion factors for your reporting year and lays the result out in the PPN 006 template, with the board approval and sign-off dates included. It costs £99 one-off, with no VAT.
Questions
What is PPN 006?
PPN 006 is the Cabinet Office procurement policy note on taking account of Carbon Reduction Plans in major government contracts. It applies to central government procurements advertised on or after 24 February 2025 with an estimated value above £5 million a year, including VAT, and makes a Carbon Reduction Plan a pass or fail condition of participation.
Has PPN 006 replaced PPN 06/21?
For new procurements, yes. PPN 006 is the February 2025 update of PPN 06/21 and applies to relevant procurements advertised on or after 24 February 2025. Procurements commenced and contracts awarded before that date still follow PPN 06/21. The Cabinet Office says the update is not a change in policy.
What is the PPN 006 threshold?
An estimated contract value above £5 million a year including VAT, averaged over the life of the contract. PPN 06/21 used £5 million a year excluding VAT. For frameworks and dynamic markets, PPN 006 applies where an individual contract awarded under them is expected to be worth more than £5 million a year.
What does a PPN 006 Carbon Reduction Plan need to include?
A commitment to net zero by 2050 at the latest; baseline and current emissions in tCO2e for Scope 1, Scope 2 and Scope 3 categories 4, 5, 6, 7 and 9; reduction targets; the environmental management measures in place; the standard declaration; the date of board approval; and sign-off by a director with name, job title and date. It must be published on your UK website.
Which Scope 3 categories does PPN 006 require?
Five: upstream transportation and distribution (category 4), waste generated in operations (5), business travel (6), employee commuting (7) and downstream transportation and distribution (9). Homeworking emissions are optional within employee commuting.
Does a Carbon Reduction Plan need to be audited?
No. The PPN 006 technical standard mentions ISO 14064-3 and ISAE 3410 as widely used verification standards, but says there is no requirement to have your carbon footprint audited.
How recent must the data in a Carbon Reduction Plan be?
Under PPN 006 the reporting period should fall no more than 18 months before the tender notice is published, unless you give an acceptable explanation. The plan should also have been published since the tender notice or in the 12 months before it, and it should be reviewed and updated within 6 months of your financial year end.
Do subcontractors need a Carbon Reduction Plan under PPN 006?
No, unless they are also bidding for the contract in their own right. A plan is required from the organisation the buyer will contract with. In a consortium, each member completes a plan.
Will we fail if our emissions have gone up?
No. The emissions figures are for information only and are not used to assess the bid. The PPN 006 FAQ says an increase compared with the baseline or a previous year does not mean the plan fails, although you may wish to explain it.
Sources
- Cabinet Office: PPN 006, Taking account of Carbon Reduction Plans in the procurement of major government contracts (published 17 February 2025, updated 10 July 2025) (checked 10 October 2026)
- Cabinet Office: PPN 006, Taking account of Carbon Reduction Plans (HTML) (checked 10 October 2026)
- Cabinet Office: PPN 006 technical standard for completion of Carbon Reduction Plans (checked 10 October 2026)
- Cabinet Office: PPN 006 guidance on adopting and applying conditions of participation (checked 10 October 2026)
- Cabinet Office: PPN 006 frequently asked questions (checked 10 October 2026)
- Cabinet Office: PPN 006 Carbon Reduction Plan template (ODT) (checked 10 October 2026)
- Government Commercial Function: Procurement Policy Note 06/21 (published 5 June 2021, updated 17 April 2023) (checked 10 October 2026)
- Government Commercial Function: PPN 06/21, Taking account of Carbon Reduction Plans (PDF) (checked 10 October 2026)
- Government Commercial Function: Guidance on adopting and applying PPN 06/21, selection criteria (April 2023) (checked 10 October 2026)
- legislation.gov.uk: Procurement Act 2023, section 3 (public contracts) (checked 10 October 2026)
- legislation.gov.uk: Procurement Act 2023, section 10 (special regime contracts) (checked 10 October 2026)
- NHS England: Carbon reduction plan and net zero commitment requirements (version 3, 10 December 2025) (checked 10 October 2026)
- NHS England: 2027 NHS carbon reduction plan requirements (updated 21 July 2026) (checked 10 October 2026)
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