On 1 July 2022, the NHS became the first health system to embed net zero into legislation, through the Health and Care Act 2022. This places duties on NHS England, and all trusts, foundation trusts, and integrated care boards to contribute towards statutory emissions and environmental targets.

The Act requires commissioners and providers of NHS services specifically to address the net zero emissions targets. It also covers measures to adapt to any current or predicted impacts of climate change identified within the 2008 Climate Change Act.

Trusts and integrated care boards (ICBs) will meet this new duty through the delivery of their localised Green Plans, and every Trust and ICB in the country now having a board-level lead. To support them, statutory guidance, including The Delivering a Net Zero National Health Service report, and the Net Zero Supplier Roadmap, are available to assist with the delivery of these duties.

Green Plans

To support our net zero ambition, each trust and integrated care system should have a Green Plan which sets out their aims, objectives, and delivery plans for carbon reduction. In each case, this should be signed off by the Trust Board, with a board-level ‘net zero lead’ responsible for overseeing its delivery. Given the pivotal role that integrated care systems (ICSs) play, each system will also need to develop its own Green Plan, based on the strategies of its member organisations.

How to produce a Green Plan: A three-year strategy towards net zero (June 2021 update) – This guidance explains how NHS organisations should construct their Green Plans, the areas and initiatives that the plans should cover, and signposts to supporting resources.


Since 2008, the NHS has tracked and reported its carbon footprint, regularly improving its methods and monitoring across the NHS. Annex 2 of Delivering a Net Zero National Health Service report describes the analytical approach to this in detail. Robust and effective monitoring is a necessity if the NHS is to meet its net zero targets.

To support the NHS’s net zero ambition, new data collection methods are being developed to enable the more granular calculation of carbon footprints at regional, ICS and trust levels. The Greener NHS Data Collection was launched on 30 April 2021 to understand actions that are taking place over 2021/22 and provide a baseline from which progress can be understood.

The latest government guidance on sustainability reporting for public sector organisations can be found on the Department of Health and Social Care website. This guidance is in addition to the Green Plan guidance for NHS organisations highlighted above.