What suppliers said:

• Respondents agreed that the NHS should continue with a flexible approach and allow either the bidding entity or the parent company to report, as this strikes a balance between standardisation and practicality.
• Feedback highlights the need for clear guidance to ensure suppliers understand the flexible approach.

Quote from detailed market sounding:

“We agree that this position should be adopted, as it recognises the diversity of company structures within the supply chain while ensuring alignment with internationally recognised frameworks.

“This approach provides both flexibility for suppliers and consistency with best practice in emissions reporting.”

NHS response:

The policy position has been confirmed with additional guidance and examples on which entities can report and how this relates to the geographical boundary.

What suppliers said:

• There was strong support for all emissions to be reported irrespective of where they are happening (‘global geographical boundaries’) rather than emissions happening in the UK only to ensure comprehensive emissions reporting that drives accountability and aligns with global standards such as the Greenhouse Gas (GHG) Protocol.
• This approach is seen as critical for consistency and transparency.
• Responses to this question indicated confusion between what must be reported (geographical boundary) and who must report them (reporting entity).
• Responses indicated a misunderstanding that the NHS will exclusively require the global parent company to report upon and make net zero commitments, which is not the case (refer to Reporting Entity above).
• This highlights the need for clarity on these concepts in the policy guidance.

Quote from detailed market sounding:

“We support this position. A global reporting boundary is essential to reflect true emissions’ impact across international operations.

“This aligns well with GHG Protocol principles and reinforces credibility in supplier disclosures.”

NHS response:

The policy position has been confirmed with additional guidance and examples distinguishing between reporting entity and geographical boundary, aligning with the Greenhouse Gas Protocol.

This will also be covered in detail in the supporting resources, including internal trainings and external webinars.

What suppliers said:

• Suppliers were supportive of the NHS’s 2045 net zero target for scope 1, 2 and 3 emissions, viewing it as demonstrating leadership.
• Concerns were raised about the feasibility of a 2045 target for suppliers from 2027, as many have set their targets in line with the UK’s national target of 2050.
• Respondents also highlighted potential risks of greenwashing and lack of robustness with earlier targets without external validation.
• Costs to suppliers to obtain validation was also raised.

Quote from detailed market sounding:

“While a 2045 commitment aligns with NHS ambition, the current proposal risks encouraging suppliers to make bold but unvalidated claims simply to meet the earlier date.

“Achieving independent validation is resource-intensive, yet requiring it only for later targets places a disproportionate burden on companies who may be taking a more cautious, realistic approach.

“A fairer model would be to encourage validation for all net zero commitments, with a more realistic deadline of 2050. NHS could also remove this requirement for all suppliers, but it should be consistent.

“This would avoid creating an incentive for unverified commitments and ensure consistency and credibility across the supply chain.”

NHS response:

The policy position has been reviewed; whilst suppliers are encouraged to set a net zero target of 2045, a target of 2050 will still meet the minimum requirements for the April 2027 Net zero supplier roadmap policy.

The section on 5. Net zero target validation provides further information on changes to the validation policy position.

What suppliers said:

• Suppliers supported the position that all relevant Scope 3 emissions should be reported as they viewed this as essential for transparency and accountability whilst minimising reporting burden.
• Feedback highlighted the specific need for support of smaller suppliers to report on all 15 Scope 3 categories and the need for simple, government-backed tools to support consistency.
• There were also mixed perceptions around annual reporting with some respondents suggesting it may be too frequent.

Quote from detailed market sounding:

“Most organisations required to disclose emissions will need to explain why certain categories are excluded. This promotes transparency, consistency, and accountability across the supply chain, while also helping to identify priority areas for carbon reduction.

“By encouraging the use of estimation methods and requiring justification for omissions, the proposed policy achieves a practical balance between thoroughness and feasibility – particularly for suppliers still developing their emissions reporting capabilities.”

NHS response:

The policy position has been confirmed, and is aligned with wider reporting requirements including PPN 006 and CSRD, with additional guidance on emissions reporting resources.

A proportionate approach to application, particularly in frameworks, is emphasised in the guidance.

This area will be a point of focus for supporting resources, including internal training and external webinars.

What suppliers said:

• Agreement from suppliers that 3rd-party validation, particularly through recognised standards like the Science Based Targets Initiative (SBTi), adds scientific rigor and trust to net zero commitments.
• Feedback advocated for a flexible approach that encourages rather than mandates validation for all targets.
• mandating validation received mixed views, reflecting the feedback set out in the section Year by which the reporting entity commits to net zero, with some stating it is required for meaningful target setting irrespective of target year and others saying it may be too burdensome and costly as a mandatory requirement from 2027.

Quote from detailed market sounding:

“While the aim should be for all net zero targets to be 3rd party validated, we appreciate that a whole range of companies supply to the NHS and therefore flexibility is required.

“However, as it is best practice and the only way to ensure credible and robust targets, we do think that validation must continue to be encouraged through the Evergreen supplier assessment.”

NHS response:

The policy position has been revised to reduce cost burden on suppliers, especially SMEs, aligning with the changes in the Year by which the reporting entity commits to net zero position.

Irrespective of the target date, validation will continue to be encouraged as best practice, but not mandated.

What suppliers said:

• Support for emissions verification to enhance credibility and transparency.
• Consensus was that verification should be voluntary at this stage.
• Requests for clear guidance on acceptable verification levels, including distinctions between ‘reasonable’ and ‘limited’ assurance*.
• Some confusion between validation and verification and differing interpretations of assurance levels.
• Concerns over practicality and cost-effectiveness of limited assurance were also raised.

[*Reasonable assurance provides a high level of confidence that reported emissions are accurate and free from material misstatement, while limited assurance offers a lower level of confidence based on less extensive verification procedures.]

Quote from detailed market sounding:

“Encouraging, but not requiring, emissions verification strikes a practical balance, allowing organisations flexibility while promoting progress.

“At the same time, requiring emissions calculations and reporting to follow the Greenhouse Gas Protocol’s Corporate Accounting and Reporting Standard, with a reasonable level of assurance, ensures consistency, reliability, and credibility in the data reported.”

NHS response:

The policy position has been confirmed, with emissions verification remaining voluntary.

What suppliers said:

• Support to focus the majority of efforts on emissions reductions rather than offsetting residual emissions.
• Concerns arose about the risk of overemphasising offsetting, doubts about the reliability and transparency of offsetting schemes, and the difficulty in estimating realistic offsetting needs 20 years ahead.

Quote from detailed market sounding:

“Industry agrees that offsetting emissions should be for residual emissions, but estimating how many carbon offsets will be required at this stage is incredibly challenging.

“Suppliers are reliant on their complex supply chains reducing their own emissions over the coming years. Technological advances will heavily influence offsets required, and therefore estimations are likely to be significantly inaccurate.”

NHS response:

The policy position has been reviewed; suppliers will not be required to disclose their offsetting expectations in their net zero target.

The change reflects CSRD updates and focuses on emissions reduction.

What suppliers said:

• Agreement that the GHG Protocol should remain the emissions reporting standard for Scope 1, 2, and 3 emissions.
• The GHG protocol was valued for its role in ensuring consistency, comparability, and credibility.
• Feedback also highlighted the complexity and potential burden linked to the existence of multiple frameworks and platforms (CSRD, TCFD, GHG Protocol), and suggested that clarification on reporting standards vs platforms and frameworks should be provided.

Quote from detailed market sounding:

“We strongly support the NHS’s alignment with the Greenhouse Gas Protocol’s Corporate Accounting and Reporting Standard.

“This is a globally recognised framework that ensures consistency, credibility, and transparency in emissions reporting.

“We also welcome NHS England’s ongoing consideration of aligning with complementary standards such as the CSRD and CSDDD.

“Clear, harmonised standards improve consistency and reduce duplication.”

NHS response:

The policy position has been confirmed, aligning to wider international reporting requirements.

What suppliers said:

• Support for tiered implementation to ensure fairness and feasibility, particularly for SMEs and microbusinesses.
• Emphasised the need for clear thresholds, consistent application, and practical guidance to avoid confusion, unnecessary burden and misinterpretation for both suppliers and NHS stakeholders.

Quote from detailed market sounding:

“We agree that a tiered, proportionate and phased approach to policy implementation is appropriate to recognise that suppliers to the NHS are at different places on their Net Zero journey.”

NHS response:

The policy will be tiered to support a proportionate and flexible approach to policy implementation with clear guidance on early engagement and consideration of vulnerable markets and those serving disadvantaged groups.