From 1 April 2027 this guidance replaces the previous carbon reduction plan guidance and associated requirements.

For in-scope procurements commenced before 1 April 2027, the requirements set out in the Carbon reduction plan requirements for the procurement of NHS goods, services and works should be applied and continued to be followed.

Overview

The NHS net zero supplier roadmap sets out the steps suppliers must take to align with the NHS net zero ambition. The purpose of this guidance is to provide further details on the implementation of the upcoming milestone in the roadmap.

From April 2027, the NHS will implement new proportionate requirements for suppliers to publicly report targets, emissions and publish a carbon reduction plan (CRP) for all of their relevant global scope 1, 2 and 3 emissions.

From 1 April 2027, the NHS CRP requirements described in this guidance replace the previous CRP and net zero commitment (NZC) requirements for the procurement of NHS goods, services and works for all in-scope procurements; and therefore, no new procurements will be in scope of the NZC requirements.

Procurements commenced prior to 1 April 2027 should continue to apply the requirements set out in the previous CRP and NZC requirements for the procurement of NHS goods, services and works guidance.

This guidance builds on and is intended to be used in conjunction with central government’s guidance documents on PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts.

A summary of stakeholder feedback and how that has been reflected in the final policy, is available in Detailed Market Sounding Findings: Supplier Roadmap – April 2027 Scope 3 Reporting and Target Setting Supplier Requirements.

The requirements apply to the commissioning and purchasing of goods, services and works (including pharmaceuticals and healthcare services) by in-scope organisations.

In-scope organisations are all NHS organisations which commission or procure such goods, services or works, including where they have appointed a third party to act on their behalf.

To ensure the milestone requirements are applied in a proportionate and relevant manner, the policy is applied in a 2-tiered approach. This ensures that the majority of NHS suppliers are advancing along the NHS Net Zero Supplier Roadmap. The requirements will be applied in a tiered approach as follows:

• A 2027 NHS Carbon Reduction Plan (2027 NHS CRP) tier.
• Applied to procurements of high value (£5 million per annum and above, including VAT) and all new frameworks operated by in-scope organisations, irrespective of the value of the framework contract, where relevant and proportionate to the framework.
• A 2027 NHS CRP covers all scope 1, scope 2 and relevant scope 3 emissions as defined in the section 2027 NHS CRP requirements, this builds on and expands the existing CRP content in place since April 2023 for the NHS and defined in PPN006 (2024 CRP).
• A 2024 CRP tier:
• Applied to procurements of lower value (below £5 million per annum including VAT, and above the relevant published procurement thresholds).
• A 2024 CRP covers all scope 1 and scope 2 emissions and a subset of scope 3 emissions as defined in the section 2024 CRP requirements. This requirement reflects the existing CRP content in place since April 2023 for the NHS and aligns with the CRP content defined in PPN 006.

Detailed information on procurements in scope of the requirements is set out in the section CRP requirements.

In some circumstances, it may not be relevant or proportionate to apply these CRP requirements. Examples of such circumstances are set out in Annex 5; further guidance on proportionality is provided in the CRP requirements section.

To ensure compliance with NHS England’s Central Commercial Function framework accreditation scheme, all future accredited frameworks are expected to apply the requirements set out in Table 1 below.

The requirement to provide a CRP is in addition to the inclusion of a minimum 10% weighting on net zero and social value in NHS procurements, which has been required since April 2022.

Carbon reduction plan requirements

Table 1 sets out when and how to apply updated CRP requirements. These requirements apply to procurements conducted under both the Procurement Act 2023 (PA23) and the Provider Selection Regime (PSR).

As the PSR is not applied in accordance with spend thresholds, this policy uses the relevant thresholds used under PA23 as a guide to determine which requirements apply to PSR procurements.

This is to ensure consistent application of this policy to all procurement activity carried out by in-scope organisations.

Throughout this guidance, these thresholds are referred to as ‘the relevant published procurement thresholds’.

Table 1: Application of CRP requirements

* Where frameworks are operated by in-scope organisations, and the organisations determine the 2027 NHS CRP requirements not to be proportionate and relevant to the nature of the new framework, the owner should apply the 2024 CRP requirements. For information on how to apply this in markets with large numbers of small and medium-sized enterprises (SMEs) or voluntary, community and social enterprises (VCSEs), see section Further information: SMEs and VCSEs.

** When applying this policy under the PSR to lower value procurements, in-scope organisations should assess whether the application of the CRP requirements is relevant and proportionate to the value and nature of the contract, using published procurement thresholds as a guide, in combination with market intelligence, including pre-market engagement.

2027 NHS carbon reduction plan requirements

A CRP identifies a supplier’s current carbon footprint and their plan to achieve net zero emissions; sets out their baseline emissions; demonstrates board‑level approval and commitment to delivering the proposed decarbonisation action.

To comply with the 2027 NHS CRP Requirements, the CRP must:

• confirm the supplier’s commitment to achieve net zero by 2050 or earlier for their whole organisation (refer to Annex 1: 2027 NHS CRP Additional Technical Standard specifics for further detail)
  • as a minimum, this commitment should apply to the supplier engaging with the NHS
• provide the supplier’s baseline and current emissions for the sources included in scope 1 and 2, and all relevant scope 3 emissions in adherence with the GHG Protocol Standard, which identifies 15 emissions categories to be considered
• provide emissions reporting in CO₂e (carbon dioxide equivalent) for the 7 greenhouse gases covered by the Kyoto Protocol:
  • carbon dioxide [CO₂]
  • methane [CH₄]
  • nitrous oxide [N₂O]
  • hydrofluorocarbons [HFCs]
  • perfluorocarbons [PFCs]
  • sulphur hexafluoride [SF₆]
  • nitrogen trifluoride [NF₃]
• set out the environmental management measures in effect, including certification schemes or specific carbon reduction measures adopted; these should be measures the supplier can deliver when performing the contract and should support the supplier to achieve net zero by 2050 or earlier
• be board approved or company director approved if no board is in place
• be clearly signposted and published on the supplier’s website

Where a supplier meets the requirements of a 2027 NHS CRP, this will also ensure compliance with the requirements of PPN 006 as a 2027 NHS CRP requires suppliers to go further in terms of emissions accounting.

When producing a 2027 NHS CRP, suppliers should use Annex 1 of this guidance in conjunction with the government’s Technical standard for completion of CRPs.

A 2027 NHS CRP should follow the structure and length of central government’s PPN 006 CRP template, though stylistic differences are acceptable.

A comparison between the 2027 NHS CRP Requirements and the 2024 CRP requirements is available in Annex 2 of this guidance.

2024 carbon reduction plan requirements

The 2024 CRP technical carbon accounting and target setting requirements align with those of central government’s PPN 006.

Therefore, any existing and current CRP developed according to the central government guidelines of PPN 006 will be accepted by the NHS for the 2024 CRP requirements.

To comply with the 2024 CRP requirements, the CRP must:

• confirm the supplier’s commitment to achieve net zero by 2050 or earlier for their UK operations as a minimum geographical boundary
  • note that a global emissions boundary meets the requirements
• provide the supplier’s baseline and current emissions for the sources included in scope 1 and 2 of the GHG Protocol, and a defined subset of scope 3 emissions (at a minimum); the 5 GHG Protocol scope 3 categories are:
  • upstream transportation and distribution
  • waste generated in operations
  • business travel
  • employee commuting
  • downstream transportation and distribution
• provide emissions reporting in CO₂e (carbon dioxide equivalent) for the 7 greenhouse gases covered by the Kyoto Protocol:
  • carbon dioxide [CO₂]
  • methane [CH₄]
  • nitrous oxide [N₂O]
  • hydrofluorocarbons [HFCs]
  • perfluorocarbons [PFCs]
  • sulphur hexafluoride [SF₆]
  • nitrogen trifluoride [NF₃]
• set out the environmental management measures in effect, including certification scheme or specific carbon reduction measures adopted; these should be measures the supplier can deliver when performing the contract and support the supplier to achieve net zero by 2050 or earlier
• be board approved or company director approved if no board is in place
• be clearly signposted and published on the supplier’s website

When producing a 2024 CRP, suppliers should follow the government’s Technical standard for completion of CRPs.

The 2024 CRP should follow structure and length of central government’s PPN 006 CRP template, though stylistic differences are acceptable.

A comparison between the 2027 NHS CRP Requirements and the 2024 CRP requirements is available in Annex 2 of this guidance.

Supplier entity in scope

A CRP should be specific to the supplier engaging with the NHS, or they may cover the supplier engaging with the NHS and its parent entity if the following criteria are met:

• The supplier engaging with the NHS is wholly owned by the parent entity.
• The commitment to achieving net zero by 2050 or earlier is set out in the CRP for the parent entity and is supported and adopted by the supplier engaging with the NHS, demonstrated by the inclusion of a statement that this will apply to the supplier engaging with the NHS.
• The environmental measures set out in the CRP are stated to be able to be applied by the bidding entity when performing the relevant contract.
• The CRP is published on the supplier’s website.

Applying CRP requirements under procurement regimes in England

The CRP requirements apply under two procurement regimes: PA23 and PSR. This section sets out how the requirements should be applied.

The Procurement Act 2023

The CRP requirements apply under the PA23 and should be applied in line with this guidance.

Annex 3 provides a decision flow diagram to help in-scope organisations understand how the CRP requirements should be reported for their procurement.

Reporting and assessment mechanism

In-scope organisations should include the relevant assessment questions, as set out in the CRP assessment methodology section of this guidance, in relevant supplier questions under the conditions of participation, set out in accordance with the PA23.

Application of requirements to frameworks and open frameworks

All new NHS frameworks* or open frameworks, irrespective of contract value, are required to apply the 2027 NHS CRP requirements, unless deemed not proportionate.

[*All new frameworks operated by in-scope organisations; where in-scope organisations are defined as NHS organisations as well as organisations acting on their behalf.]

Where NHS framework owners determine the 2027 NHS CRP requirements are not proportionate and relevant to the nature of the framework the owner should apply the 2024 CRP requirements.

Contracting authorities should engage the market early to ensure understanding of supplier progress and to ensure application of the requirements will not cause undue burden or create barriers to entry.

Where the conditions of participation for a framework or open framework does not include the 2027 NHS CRP requirement, framework providers should consider actions to support suppliers during the term of the contract to upskill them in developing a 2027 NHS CRP as a supplier to the NHS.

The 2027 NHS CRP requirements should be applied at framework/open framework tender, rather than to individual call-offs.

Dynamic markets

All new dynamic markets, irrespective of contract value, are required to apply the 2027 NHS CRP requirements as part of the conditions of membership.

Where NHS dynamic market owners determine the 2027 NHS CRP Requirements are not proportionate and relevant to the nature of the dynamic market the owner should apply the 2024 CRP requirements.

Where the conditions of membership for the dynamic market does not include the 2027 NHS CRP requirement, dynamic market providers should consider actions to support suppliers during the term of the membership to them in developing a 2027 NHS CRP as a supplier to the NHS.

2027 NHS CRP requirements should not form part of conditions of participation when awarding contracts under dynamic markets. This is to ensure that suppliers, particularly SMEs, are not required to submit information to multiple in-scope organisations.

Direct awards

Direct awards [DAs] (where the requirement is not otherwise covered; for example, in framework, open framework or dynamic market) are in scope of the requirements outlined in this guidance.

Due to the nature of these procurements, the requirements should be included, where possible, as part of any selection criteria utilised in accordance with Section 41 of the Procurement Act 2023.

Where it is determined that selection criteria will not be used, suppliers should be encouraged to submit their CRP but these should not be assessed as a pass-fail requirement.

The Provider Selection Regime

The Provider Selection Regime (PSR) regulates the arrangement of healthcare services in-scope of the regime.

Relevant authorities arranging contracts for health care services in accordance with PSR rules are in scope of the 2027 NHS CRP requirements.

Where in-scope health care services are provided by NHS providers, please refer to the NHS to NHS Contracts section under Further Information.

PPNs do not apply to procurements under the PSR, however relevant authorities are expected to implement the milestones set out in the NHS Net Zero Supplier Roadmap, which includes 2027 NHS CRP requirements set out in guidance.

Reporting and assessment mechanism

The PSR sets out discrete provider selection processes that relevant authorities use when commissioning healthcare services.

How the 2027 NHS CRP requirements are applied under the PSR will depend on the provider selection processes used.

Annex 4 provides a decision flow diagram to help in-scope organisations understand how the 2027 NHS CRP requirements should be applied for each process.

DA process A and B under the PSR

Due to the nature of process A and B under the PSR, the 2027 NHS CRP requirements should be applied – where possible – as due diligence questions within the procurement process, but not assessed as a pass-fail requirement.

Evidence that these requirements have been met is provided by the supplier for informational purposes only.

DA process C, most suitable provider, competitive process under the PSR

In-scope organisations should apply the 2027 NHS CRP requirements on a pass-fail basis, as per the CRP assessment methodology in this guidance.

Application of requirements to framework agreements under the PSR

All new NHS framework agreements, including those arranged under the PSR, irrespective of contract value, are required to apply the 2027 NHS CRP Requirements.

Where NHS framework agreement owners determine the 2027 NHS CRP requirements not to be proportionate and relevant to the nature of the framework, the owner should apply the 2024 CRP requirements.

Relevant authorities should engage the market early to ensure understanding of supplier progress and to ensure application of the requirements will not cause undue burden or create barriers to entry.

Where the basic criteria for a framework agreement does not include the 2027 NHS CRP requirement, framework providers should consider actions to support suppliers during the term of the contract to them in developing a 2027 NHS CRP as a supplier to the NHS.

The 2027 NHS CRP requirements should be applied at framework agreement level, rather than to individual call-offs.

Contract management

Where the requirements were included as conditions of the procurement, to ensure suppliers regularly update their 2027 NHS CRP or 2024 CRP during the term of the contract, relevant authorities should include the requirement for annual updates within the terms and conditions of any contract arranged under PSR.

Framework agreement host organisations should include the requirement within the terms and conditions of the framework agreement, and this requirement should not be applied within call-off contracts.

Framework agreement host organisations are expected to manage supplier due diligence to ensure annual updates to the 2027 NHS CRP or 2024 CRP are received.

Carbon reduction plan assessment methodology

The assessment confirms whether a supplier’s 2027 NHS CRP and/or 2024 CRP meets the minimum requirements.

Suppliers whose 2027 NHS CRP or 2024 CRP does not meet the minimum requirements will not be able to proceed to the next stage of the procurement process, except in exceptional circumstances as set out in Annex 5. CRPs will not be scored or compared against each other.

Annex 5 sets out example scenarios and whether these meet the minimum requirements of the 2027 NHS CRP and 2024 CRP.

The assessment questions are set out in the section below and are consistent across procurement regimes.

The stage of the procurement process at which assessment and reporting will take place will depend on the regime being used and the specific procedure or process.

Details of when this will be conducted under each regime is set out in the relevant sections of this guidance under Applying the 2027 Requirements under current procurement regimes in England.

Assessment questions

In-scope organisations should use the questions set out in table 2 to assess the requirements.

Whether in-scope organisations are applying the 2027 NHS CRP requirements or the 2024 CRP requirements, the organisation should apply all the questions in table 2 and assess them to relevant minimum requirement.

These are aligned to the assessment questions set out in PPN 006, which can be found in Annex A of the guidance on adopting and applying PPN 006.

The contracting authority must clearly specify within Part 3 of the Procurement specific questionnaire (PSQ), or within the basic criteria where applicable, which CRP requirement is being applied as part of the procurement.

Table 2: assessment questions

Supplier emissions declaration

For procurement teams using the Atamis e-commerce system (Atamis), standard templates have been configured to make this process as user-friendly as possible.

The PSQ issued by the Cabinet Office, includes these questions and should be used during procurement activity to ensure alignment.

Further information

NHS-to-NHS contracts

Where trusts (including both NHS trusts and NHS foundation trusts), integrated care boards (ICBs) and primary care organisations are bidding for contracts being procured by other NHS organisations in England, a current and published NHS trust or ICB Green Plan is considered equivalent to a 2027 NHS CRP, given the NHS England Public Board-approved commitment to net zero and the annual emissions updates published by NHS England.

Eligible NHS organisations under this section should provide a link to their published Green Plan and complete the relevant required reporting questions, questions 1 and 2 of the assessment questions in the CRP assessment methodology section of this guidance.

NHS organisations do not need to complete the emissions reporting questions (3 and 4) of the assessment, as NHS organisations report emissions via central reporting processes.

Public bodies

Where other public bodies are bidding for NHS contracts, the public body will need a compliant CRP. Public bodies should provide a link to the published CRP.

In exceptional circumstances, compliance through an equivalent requirement can be used.

Where an equivalent requirement is provided, the contracting authority should review it to ensure it offers sufficient assurance that it aligns with the CRP requirements set out in this guidance.

Sub-contractors

Sub-contractors are not in scope of the CRP requirements, and do not need to provide evidence of either.

However, in order to reach net zero emissions, suppliers should engage with their subcontractors to ensure they are taking actions to reduce their emissions.

SMEs and VCSEs

SMEs and VCSEs can find support and advice on how to take climate action on The UK Business Climate Hub.

The hub is a collaboration between the UK government, businesses and business groups across the UK to empower SMEs and VCSEs to take climate action.

The NHS England Sustainable supplier accelerator also provides free webinars, activities and supporting resources that support suppliers on their sustainability journey.

The topics and scheduled activities align to the objectives of the NHS Sustainable Procurement programme and the NHS Net Zero Supplier Roadmap.

In exceptional circumstances, for procurements where a 2027 NHS CRP or 2024 CRP is required and where suppliers have an acceptable reason for being unable to gather emissions data, they can provide a 2027 NHS CRP or 2024 CRP with the carbon emissions they have available and include the explanation why, if applicable, any data is not available.

For example, to reduce barriers for the SMEs and VCSEs to bid for NHS contracts, SMEs or VCSEs with acceptable reasons may use this provision. Please see ‘supplier response’ 7 of Annex 5 of this guidance for more information.

A supplier’s explanation will be assessed on a case-by-case basis by the contracting authority or relevant authority. Suppliers are also required to provide the steps they will take to improve the data.

If you are an SME or VCSE supplier to the NHS and require further support or guidance, please contact the NHS England Net Zero and Sustainable Procurement team via email at england.ccf-sustainability@nhs.net.

Useful resources

1. NHS England’s Sustainable Supplier Accelerator
2. Procurement Policy Note 006
3. Carbon Reduction Plan Template
4. Guidance on adopting and applying PPN 006: Selection criteria
5. Technical standard for completion of Carbon Reduction Plans
6. UK Business Climate Hub – find advice on energy saving and net zero for SMEs and VCSEs

Getting help

Further support for in-scope organisations

In-scope organisations applying the policy can refer to Annex 1 in conjunction with PPN 006 for technical questions on the content of CRPs.

For any other questions, NHS England’s Net Zero and Sustainable Procurement team can provide additional support to in-scope organisations to understand and meet the CRP requirements. Please contact england.ccf-sustainability@nhs.net.

Further support for suppliers

NHS England is offering support for suppliers to help them fulfil the requirements, including regular webinars. Suppliers can access support via the Sustainable Supplier Accelerator on the NHS England sustainable procurement webpage.

Stay up to date on NHS-specific webinars by registering on the NHS England events website. You can also follow NHS England’s Commercial Function on LinkedIn.

Crown Commercial Service runs regular Q&A sessions for suppliers on PPN 006 and CRP requirements. Please visit their website for more information.

Annex 1: 2027 NHS CRP additional technical standard specifics

The following provides further information on 2027 NHS CRP additional technical requirements.

Expansion to all relevant scope 3 reporting

Suppliers must report emissions for all Scope 3 categories deemed relevant in adherence with the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Standard.

For scope 3 categories deemed not relevant, an explanation, aligned to the standard, must be provided.

In line with the Greenhouse Gas Protocol, estimation methods can be used to calculate scope 3 emissions; for example, through spend-based methods using carbon conversion factors.

NHS England recognises that suppliers may not have access to comprehensive data throughout their supply chains, and encourages suppliers to take initial steps to understand their scope 3 emissions in accordance with the Greenhouse Gas Protocol.

Global geographical boundary for net zero commitment and emissions

For the chosen reporting entity, a global geographical boundary must be applied for the net zero commitment and emissions reporting.

This approach aligns to the Greenhouse Gas Protocol standard that requires organisations to define their organisational and operational boundary and then report all associated emissions.

This requirement should not be confused with the flexibility regarding the choice of reporting entity: suppliers may report either at the level of the supplier engaging with the NHS or, where appropriate, the parent entity may report on its behalf, provided the global geographical boundary is still consistently applied.

Examples are provided below:

Supplier to the NHS example: XYZ Medical Supplies Ltd

• UK-registered company bidding directly for NHS contracts. XYZ Medical Supplies Ltd is a UK subsidiary of a wider global group.
• Reports emissions for its UK organisational boundary which includes all related global emissions (for example, overseas product purchasing of goods and services or freight linked to UK activity), in line with the GHG Protocol; therefore, not limited to UK territorial emissions.

Global Parent Entity example: ABC Healthcare Global

• Multinational parent of ABC Healthcare UK Ltd (the supplier engaging with the NHS).
• Reports on behalf of the UK entity, applying a global boundary covering all operations and emissions worldwide, including those of the supplier engaging with the NHS.

Annex 2: Summary of the 2027 NHS CRP and 2024 CRP requirements

To aid suppliers and in-scope organisations, table 4 provides an overview of the minimum requirements for key technical requirements of both CRP types as well as the best practice that the NHS encourages suppliers to adopt.

By meeting the 2027 NHS CRP Requirements, suppliers ensure they meet all of the CRP requirements set out in this guidance and best prepares them for future NHS procurements.

Table 4: Summary of 2027 NHS CRP and 2024 CRP requirements

*Further guidance on these requirements areas are provided in Annex 1: 2027 NHS CRP Additional Technical Standard specifics and Global geographical boundary for net zero commitment and emissions.

Annex 3: Decision flow of CRP reporting mechanisms

The below diagram has been designed to aid contracting authorities understand which CRP reporting mechanism should be applied for their procurement.

Annex 4: Decision flow of CRP reporting mechanisms under the PSR

The below diagram has been designed to aid relevant authorities understand how to apply the CRP requirements when selecting providers for health care services under the PSR.

Annex 5: Examples of supplier response scenarios and exceptional circumstances

The supplier responses numbered 1 to 14 in the table below, and the exceptional circumstance section in this annex, are taken from the central government document Guidance on adopting and applying the PPN 006 – selection criteria.

*If there are gaps in the scope 3 reporting in 2027/28 tenders, and the supplier commits to report on emissions, contracting authorities and relevant authorities should ensure contract terms and conditions reflect this commitment and reporting expectation.

Exceptional circumstances

It may not be relevant or proportionate to apply these CRP requirements in the following exceptional circumstances (which may often be temporary):

• Where the market for a contract of this type is distorted/narrowed/struggling to such a significant extent that delivery of public services (for example, patient care, access to disadvantaged groups) is likely put at risk, or value for money is likely to be severely compromised.
• Where a light touch contract, framework or dynamic market is set up in accordance with PA23 to support SMEs or VCSEs to access public contracts, and the request to implement a CRP could be a barrier to entry. Market engagement is required to understand whether requesting a CRP is a barrier and this should be evidenced with market intelligence for this exceptional circumstance to apply.
• Where there is a civil emergency.

The scenarios outlined above are not an exhaustive list and in-scope organisations should ensure they apply the requirements in a relevant and proportionate manner.

Reasons for not applying the measure should be documented by the in-scope organisation.

Publication reference: PRN02316_ii