Organisations
In 2022, the NHS became the first health system to embed net zero in legislation, through the Health and Care Act 2022. This places duties on NHS England, and all trusts, foundation trusts, and integrated care boards to consider statutory emissions and environmental targets in their decisions.
Trusts and ICBs are expected to meet these duties through the delivery of board-approved green plans.
The NHS’s commitment to net zero was reinforced by Lord Darzi in his independent investigation of the NHS in England (September 2024).
Green plans
In 2021 guidance: How to produce a Green Plan: A three-year strategy towards net zero, NHS England asked systems and trusts to develop green plans spanning 3 years. The plans have led to significant progress towards achieving net zero, including over £1 billion in funding secured by NHS trusts through the Public Sector Decarbonisation Scheme (PSDS), which is expected to reduce NHS energy costs by over £260 million a year.
These plans are being refreshed in 2025 in line with new statutory guidance: NHS England » Green plan guidance. The updated guidance will help NHS organisations develop robust plans to support world-leading patient care, save money and minimise waste – continuing the NHS’s journey to achieving net zero.
Refreshed green plans should be approved by the organisation’s board or governing body, published in an accessible location on the organisation’s website and shared with NHS England by 31 July 2025.
Reporting
Since 2008, the NHS has tracked and reported its carbon footprint, regularly improving its methods and monitoring across the NHS. Robust and effective monitoring is vital if the NHS is to meet its net zero targets.
Sustainability reporting requirements for NHS organisations are summarised in statutory green plan guidance, with further detail in the Department of Health and Social Care (DHSC) group accounting manual, the Foundation trust annual reporting manual and the NHS Standard Contract.
ICBs and trusts are required to report an annual summary of progress on delivery of green plans to their board and publish this in their annual report, including actions taken and planned, with quantitative progress data.
Task Force on Climate-related Financial Disclosures (TCFD)
The DHSC group accounting manual (GAM) sets out how TCFD requirements are being applied to NHS bodies, including explicitly stating that disclosure of Scope 1, 2 and 3 emissions is not required for NHS bodies as this is reported by NHS England.