If your business bids for NHS contracts, the Carbon Reduction Plan you need is about to get broader. From 1 April 2027, suppliers on larger NHS procurements will have to publish a plan covering all of their global Scope 1, 2 and 3 emissions. Today the requirement is narrower. It covers UK-based emissions, Scope 1 and 2 in full, and only a defined subset of Scope 3.
The change comes from NHS England's Net Zero Supplier Roadmap, the timetable it set in November 2023 for what it expects from the companies it buys from. Around 60% of the NHS carbon footprint sits in that supply chain, so suppliers are central to the target. NHS England has since published detailed guidance on the April 2027 milestone, the next big step up.
What the NHS asks for now
Since April 2024, new NHS contracts have carried carbon conditions. For contracts worth £5m a year or more including VAT, the winning supplier has to publish a Carbon Reduction Plan: Scope 1 and 2 in full, a defined subset of Scope 3, reported on a UK basis. Smaller contracts get a lighter net zero commitment instead. Every NHS procurement also applies a minimum 10% weighting for net zero and social value combined. The current rules sit in NHS England's supplier guidance.
That baseline holds until the 2027 milestone takes over.
What changes in April 2027
From 1 April 2027, one set of requirements replaces both the current Carbon Reduction Plan and the net zero commitment. The NHS calls it the 2027 NHS CRP. The fuller version applies to new procurements worth £5m a year or more including VAT, and to all new NHS frameworks, irrespective of value, unless the buyer judges it not proportionate or relevant. The plan then has to cover:
- all relevant Scope 3 categories, not just a subset
- emissions on a global basis, not only UK operations
- public reporting of the supplier's targets and its measured emissions
Lower-value procurements stay in scope on a lighter, proportionate basis. Buyers are also expected to ask for annual updates through the life of the contract.
The plan has to commit to net zero by 2050 at the latest. An earlier date of 2045 is NHS-recommended, not a hard requirement. Independent validation of the plan, and disclosing how much of the target you expect to hit through offsetting, are recommended too, not mandatory. The reporting boundary is the real change here, and for most suppliers it means a lot more work.
How this sits next to PPN 006 and PPN 026
These rules are separate from PPN 006, the Cabinet Office policy that makes a Carbon Reduction Plan a condition of bidding for central government contracts above £5m a year. PPN 006 still stands. Sell to both central departments and the NHS and you can end up meeting two overlapping but different carbon asks, with different boundaries and formats.
There's also been noise about PPN 026, the new social value model. The headlines said net zero was being dropped from procurement. What changed is how the social value section is scored, with the weight moving towards jobs and skills. The Carbon Reduction Plan conditions under PPN 006 and the NHS roadmap weren't touched. If anything, the NHS is going the other way.
What to do before 2027
Work out which regime applies to the work you chase. If the NHS is a real target, widen your carbon accounting now instead of leaving it to 2027. Bring in the Scope 3 categories you've been skipping. Measure on a global basis if you operate outside the UK. A CRP built to the PPN 006 standard is a good start, but check it against the NHS boundary before you lean on it in a health service bid. And if you bid through new NHS frameworks, expect the 2027 NHS CRP to apply whatever the contract is worth, unless the buyer judges it not proportionate or relevant.
CarbonVerified turns your energy and activity data into a Carbon Reduction Plan in the format buyers expect. Whatever you use to build it, the direction for public sector bids is set: more carbon detail over the next few years, not less.
