NHS suppliers – how to prepare for the 2027 carbon reduction plan requirements
NHS suppliers bidding from April 2027 may need an expanded carbon reduction plan – find out which tenders are in scope and how to get ready.
From 1 April 2027, suppliers bidding for NHS contracts worth £5 million or more a year will need a carbon reduction plan that meets a new, expanded standard.
Assessment is on a pass/fail basis, so suppliers whose plans only meet the current requirements risk losing tenders.
Below, we set out what is changing, why scope 3 emissions reporting is the biggest shift and how to prepare.
2027 NHS carbon reduction plan vs PPN 006 – what is new?
The 2027 NHS carbon reduction plan (CRP) builds on the requirements set out in Procurement Policy Notes (PPN) 006, which will continue to apply to NHS contracts below £5 million a year.
The new standard keeps the same foundations but goes further in five key areas:
- Scope 3 emissions: all relevant scope 3 categories must be reported, rather than the five categories PPN 006 requires.
- Reporting boundary: emissions must be reported on a global basis, not just for UK operations.
- Parent entity: the commitment to reach net zero by 2050 or earlier applies to the parent entity, including the supplier bidding for NHS work.
- Target validation: emission reduction targets require independent third-party validation.
- Offsetting: plans now need to state how much of the net zero target is expected to be met through offsetting.
Plans still need board approval and must be published on the supplier’s website, and the minimum 10% weighting on net zero and social value in NHS procurements remains in place.
Scope 3 emissions – the biggest shift for NHS suppliers
Under PPN 006, suppliers only need to report five scope 3 categories, which leaves out purchased goods and services – arguably the largest source of scope 3 emissions for many organisations.
For suppliers whose plans cover only those five categories, the new standard means expanding both emissions reporting and reduction targets to include all relevant scope 3 emissions.
Where detailed data is not available, estimation methods such as spend-based calculations are accepted, and any categories considered not relevant can be excluded with a supporting explanation.
Which NHS suppliers need to meet the 2027 requirements?
The 2027 NHS CRP applies to contracts worth £5 million or more a year, including VAT.
New frameworks and dynamic markets also fall under the new requirements regardless of value, unless the framework owner decides otherwise.
Below £5 million a year, PPN 006 continues to apply. Procurements that begin before 1 April 2027 are not affected.
Before bidding, check the annual value of each NHS tender and whether it is a new framework or dynamic market.
Where the new standard applies, the next step is to review your current plan against the five changes above.
Why NHS suppliers should start preparing now
Expanding a carbon reduction plan to cover all relevant scope 3 emissions takes time, particularly for suppliers starting from the five categories in PPN 006.
For 2027/28 tenders, suppliers with gaps in their first-year scope 3 data can still pass if an acceptable explanation and a plan to report from the following year are provided.
Every other part of the new standard still applies in full, including third-party validated targets and the offsetting disclosure.
How can Inspired help?
Meeting the 2027 NHS CRP means bringing together a full emissions footprint, credible targets and a clear plan to reach net zero, all signed off at board level – a significant step up if your current plan is built around PPN 006.
A scope 3 emissions inventory is the natural starting point, identifying the relevant categories and calculating emissions in line with the Greenhouse Gas Protocol.
The process typically takes six months from kick-off to delivery, so early preparation is key.
If you need targets in place, Inspired’s net zero strategy service models near and long-term targets aligned with both the latest Science Based Targets initiative (SBTi) criteria and NHS England reduction targets, and maps out a decarbonisation roadmap, including how any offsetting fits in.
SBTi is one recognised route to the independent validation the 2027 NHS CRP requires, and Inspired can support you through the SBTi validation process, from completing the submission forms to responding to SBTi queries.
ESG assurance can also verify the emissions data behind your plan, giving you confidence in the figures you submit.
Each service is available as a standalone option or combined, depending on what you already have in place.
Want to know where your current plan stands against the 2027 requirements? Contact our ESG team at [email protected]
