A PPN 006 Carbon Reduction Plan is a pass-or-fail condition of participation for relevant major central government procurements.
You need Scope 1, Scope 2 and five specified Scope 3 categories, a commitment to net zero by 2050 at the latest, reduction targets and measures, publication, board approval and director-level sign-off.
You do not need an externally audited footprint simply to meet PPN 006. A 2030 net zero target does not score more highly than 2050. Rising emissions do not automatically fail the plan.
We checked the current Procurement Policy Note, technical standard and Government FAQs because quite a few commercial guides add requirements the Government does not.
If I had a live tender, I would check three things first: the bidding entity, the five required Scope 3 categories and the dates. A polished document will not rescue the wrong company, missing emissions or stale data.
PPN 006 Carbon Reduction Plan requirements at a glance
| Requirement | What PPN 006 expects |
|---|---|
| Procurement scope | Relevant procurements by central government departments, executive agencies and non-departmental public bodies |
| Contract value | In excess of £5 million per year including VAT, where relevant and proportionate |
| Assessment | Condition of participation, assessed pass or fail |
| Net zero commitment | UK operations committed to net zero by 2050 at the latest |
| Emissions | Scope 1, Scope 2 and five specified Scope 3 categories |
| Footprint | Baseline and current emissions in tCO2e |
| Method | GHG Protocol Corporate Standard and applicable Government guidance |
| Conversion factors | Appropriate UK Government company-reporting factors |
| Reduction plan | Targets plus environmental management measures and projects |
| Approval | Board or equivalent management body |
| Sign-off | Director or equivalent, or designated member for an LLP |
| Publication | Published on the supplier’s UK website and clearly signposted |
| Updating | At least annually, normally within six months of financial year-end |
| External audit | Not required by PPN 006 itself |
What changed from PPN 06/21 to PPN 006?
PPN 006 is the current Procurement Policy Note for relevant procurements commenced under the Procurement Act 2023 regime on or after 24 February 2025.
PPN 06/21 applies to the earlier procurement regime.
The Government says the move to PPN 006 did not create a new carbon policy or a new call for action. It updated the policy to fit the Procurement Act 2023 and Procurement Regulations 2024.
One important procurement term did change. The Carbon Reduction Plan is now applied as a condition of participation.
I would be wary of any current guide that uses “PPN 006” and “PPN 06/21” as interchangeable names. They are closely related, but which one applies depends on when the procurement commenced.
Read the current PPN 006 notice on GOV.UK.
Does your business need a PPN 006 Carbon Reduction Plan?
The formal PPN applies to central government departments, their executive agencies and non-departmental public bodies.
For a supplier, the requirement can apply where the relevant procurement is valued at more than £5 million per year including VAT, unless applying it would not be relevant or proportionate.
That is not the same as saying every UK public-sector contract over £5 million requires a PPN 006 plan.
It does not.
Other public bodies can set related requirements of their own. The NHS already does, and its requirements broaden from April 2027.
If you are bidding now, the tender documents are the final authority.
How is the £5 million threshold calculated?
The value is averaged over the life of the contract.
The Government’s own example is a four-year contract worth £21 million.
That is £5.25 million a year, so it is above the threshold even if the first year’s value is below £5 million.
It is a simple calculation, but it is also exactly the sort of thing that gets missed if somebody checks year one and stops.
What about frameworks and dynamic markets?
PPN 006 can also apply to frameworks and dynamic markets.
For these, the Government looks at the estimated value of an individual contract awarded under the framework or by reference to the dynamic market.
Do not infer the requirement from the framework headline. Check the procurement you are actually entering.
What must a Carbon Reduction Plan contain?
The Government publishes an official template. I would use it.
The required structure covers:
- supplier name and publication date;
- commitment to net zero by 2050 at the latest;
- baseline emissions footprint;
- current emissions reporting;
- emissions reduction targets;
- completed carbon reduction initiatives and environmental management measures;
- future carbon reduction initiatives;
- declaration, board approval and sign-off.
The baseline and current footprint report Scope 1, Scope 2 and the required Scope 3 categories in tonnes of carbon dioxide equivalent, or tCO2e.
If you have never calculated a footprint before, your first reporting period can become the baseline. A Carbon Reduction Plan is not the same duty as SECR, and the two are constantly confused. I have set out what SECR requires a qualifying company to report, and where the two overlap.
The Government technical standard is clear that the CRP is a summary document. It does not replace the underlying organisational carbon footprint.
That is why I would not pay anyone simply to fill in the Government template. The value is in getting the calculation underneath it right.
Which five Scope 3 categories does PPN 006 require?
PPN 006 does not require all 15 GHG Protocol Scope 3 categories for the standard central-government plan.
It requires these five:
| GHG Protocol category | Required source |
|---|---|
| Category 4 | Upstream transportation and distribution |
| Category 5 | Waste generated in operations |
| Category 6 | Business travel |
| Category 7 | Employee commuting |
| Category 9 | Downstream transportation and distribution |
Scope 1 and Scope 2 are required as well.
The detail around Categories 4 and 9 is worth checking. “Upstream freight” and “downstream freight” are not simply labels for everything that moves before and after your business. The classification depends on who purchases the transport service and where the activity sits in the value chain.
What if you cannot calculate one of the categories?
Do not put in zero unless the emissions are genuinely zero.
The Government assessment guidance allows a plan to pass where a required scope cannot be reported and the supplier gives an acceptable explanation.
A missing figure and a zero are not the same thing.
After 25 years around carbon accounting, this is one habit I would avoid completely: making a table look tidier by turning uncertainty into certainty.
If the data are not there, explain what is missing and why.
How to prepare a PPN 006 Carbon Reduction Plan
1. Confirm the bidding entity
Start with the legal entity that will sign the contract.
PPN 006 normally wants the Carbon Reduction Plan for the bidding supplier, not whichever parent company publishes the group’s sustainability report.
A parent-company CRP can be used in specified circumstances, but there are conditions. Do not assume group ownership settles it.
2. Set the organisational boundary
The footprint needs a defined boundary.
Under the GHG Protocol, organisations can use recognised approaches including financial control, operational control and equity share.
The important point is consistency. Your baseline and current footprint need to describe the same organisation on the same basis, unless you have a defensible reason to re-baseline.
I would decide the boundary before doing any calculation. Otherwise it is perfectly possible to produce a precise total for the wrong organisation.
3. Calculate baseline and current emissions
Both footprints need:
- Scope 1;
- Scope 2;
- the five required Scope 3 categories.
Use activity data where it is available and record where estimates have been necessary.
If the company has materially changed through an acquisition, disposal or restructuring, explain it. The Government guidance allows re-baselining where appropriate.
A rising footprint is not automatically bad and a falling footprint is not automatically good. First make sure you are comparing like with like.
4. Record the Government conversion factors used
The Department for Energy Security and Net Zero publishes company-reporting conversion factors each year.
The 2026 factors were published on 11 June 2026.
The flat file intended for automated processing was then republished on 31 July 2026 because some unavailable values had been shown as zero instead of blank.
That sounds minor. It is not if software has treated the zero as an emissions factor.
This is why we record the factor set and source. A carbon calculation is quite capable of producing a very precise wrong answer if the input is wrong.
See the current UK Government greenhouse gas conversion factors.
5. Set reduction targets and name the measures
The CRP asks for reduction targets and environmental management measures.
Be specific.
If vehicles are being electrified, say what is changing.
If travel policy has changed, say how.
If the next step is obtaining better freight data before setting a meaningful logistics target, say that.
A domestic flight replaced by a shared car journey is a measure you can evidence, and our figures for the emissions from flying and driving show by how much.
I would rather read one operational measure than a paragraph about “embedding sustainability throughout the business”.
6. Use the official template
The Government template is free and familiar to procurement teams.
Use it unless you have a good reason not to.
There is no prize for turning a straightforward compliance document into a glossy sustainability brochure.
Download the official PPN 006 template.
7. Get the approval and sign-off right
The plan should state that it has been approved by the board or equivalent management body.
It must be signed off by a director or equivalent. For an LLP, the relevant designated-member rules apply.
A physical signature is not required, but the approval and sign-off need to be clear.
I would sort this before the tender deadline gets close. It is a remarkably avoidable reason to end up with an incomplete document.
8. Publish it and check both dates
The current plan should be published on the supplier’s UK website and clearly signposted.
It should be reviewed at least annually and updated within six months of the organisation’s financial year-end.
There are then two separate tender-related timing tests:
- the CRP should normally have been published since the tender notice or within the preceding 12 months;
- the emissions reporting period should normally fall no more than 18 months before the tender notice.
These are different tests.
The 18-month rule has real consequences. The assessment guidance says an older reporting period without an acceptable explanation can lead to failure.
If your numbers are stale, update the footprint before polishing the wording.
What PPN 006 does not score you on
This is the part of the Government guidance I think more suppliers should read.
A 2030 net zero target does not beat 2050
The Government gives the example directly.
One supplier commits to net zero by 2050. Another commits to 2030.
If both plans meet the PPN 006 requirements, both pass. Neither gets an advantage under this condition of participation.
Choose an earlier target because you intend to deliver it, not because somebody tells you the date wins procurement points.
A lower carbon footprint does not score higher
The emissions figures are not used to rank suppliers under PPN 006.
They establish the footprint and allow progress to be followed.
That is sensible. Otherwise a small office-based business could look “better” than a manufacturer simply because the two companies do completely different things.
Rising emissions do not automatically fail the plan
The Government says this explicitly.
If emissions have increased, explain why.
Growth, acquisitions, better data and changes in organisational boundary can all move the number.
I would rather publish the real increase with a clear explanation than quietly change the calculation until the graph points down.
SBTi and Race to Zero do not replace the CRP
They can be relevant environmental management measures.
They do not replace the PPN 006 Carbon Reduction Plan.
A climate commitment and a procurement document are doing different jobs.
Do you need external verification?
No. PPN 006 itself does not require an externally audited carbon footprint.
The technical standard says the footprint should follow the GHG Protocol Corporate Standard and be conducted to a reasonable level of assurance. It refers to recognised verification standards, including ISO 14064-3 and ISAE 3410.
It then says there is no requirement to have the footprint audited.
External verification may still be valuable. A buyer may require it separately. A larger business may choose it because the footprint appears in public reporting. A complex inventory may benefit from independent review.
But if someone tells you verification is mandatory simply because the tender asks for a PPN 006 plan, I would ask them to show you the requirement.
This is one area where a supplier can spend money it does not need to spend.
A carbon footprint is not a Carbon Reduction Plan
A carbon footprint is the emissions calculation.
A Carbon Reduction Plan takes that calculation and adds the procurement requirements: net zero commitment, reduction targets, environmental measures, publication, approval and sign-off.
If you already have a robust footprint for the correct entity and the required categories, completing the Government template should not be a major exercise.
If you do not, the footprint is the job.
Where C Level can help
This is the part we are useful for.
We can help define the reporting boundary, work through the source data, calculate Scope 1, Scope 2 and the required Scope 3 emissions, document assumptions and build a footprint that can be updated again next year.
We are not going to pretend you need us to download a free Government template.
If you have a live tender and the carbon calculation is the part holding up the CRP, tell us the deadline and what data you already have.
Carbon footprint consultancy for your Carbon Reduction Plan
If you are earlier in the process and simply want a first view of where your operational emissions sit, use our business carbon footprint calculator.
It is a screening tool, not a PPN 006 compliance generator.
Eight PPN 006 details worth checking before submission
1. Is the plan for the bidding legal entity?
Not automatically the parent company or trading brand.
2. Are all five required Scope 3 categories present?
If one cannot be reported, is the explanation included?
3. Are any zeros actually missing data?
A zero is a claim that no emissions occurred.
4. Is the CRP itself current enough?
Check the publication date.
5. Is the emissions reporting period current enough?
That is a separate date.
6. Has the board or equivalent body approved it?
Approval and director-level sign-off are part of the requirement.
7. Can procurement find it on your website?
The plan should be published and clearly signposted.
8. Are you using the correct procurement regime?
For procurements commenced on or after 24 February 2025, check PPN 006 rather than treating an old PPN 06/21 guide as current.
Parent companies, subcontractors and consortium bids
Can a subsidiary use its parent’s Carbon Reduction Plan?
Sometimes.
The Government permits this under specified conditions, including wholly owned status, adoption of the parent’s net zero commitment and applicability of the parent’s environmental measures.
The full requirements still need to be met, and the plan needs to be published appropriately.
If the ownership structure is complicated, I would check the Government FAQ against the actual bidding entity rather than rely on a generic group policy.
Do subcontractors need a plan?
Not simply because they are subcontractors.
The requirement attaches to the supplier contracting with the in-scope authority.
A subcontractor bidding directly for a separate in-scope procurement is a different matter.
What about consortiums?
Each consortium member should complete a CRP.
That is worth establishing early. One consortium-wide sustainability document is not automatically the same thing.
NHS suppliers: what changes from April 2027?
If you sell into the NHS, the five PPN 006 Scope 3 categories are not the end of the story.
From 1 April 2027, NHS England introduces a tiered approach for newly commenced in-scope procurements.
For high-value procurements of £5 million per annum and above including VAT, and all new frameworks where relevant and proportionate, the 2027 NHS tier expands reporting to all relevant Scope 1, Scope 2 and Scope 3 emissions on a global boundary.
Lower-value in-scope procurements remain on the 2024 tier.
NHS England confirmed in June 2026 that:
- 2050 remains the minimum acceptable net zero commitment date, although 2045 is encouraged;
- target validation is encouraged rather than mandatory;
- emissions verification is encouraged rather than mandatory;
- the proposed requirement to estimate future carbon offsetting was removed.
If NHS contracts matter to your business, I would start looking at the wider Scope 3 boundary before April 2027.
A global Scope 3 inventory is a materially bigger job than five selected categories.
Read the NHS England April 2027 requirements.
Download the official Carbon Reduction Plan template and examples
The Cabinet Office publishes the blank PPN 006 template free of charge.
Download the official PPN 006 template and guidance.
The Government Commercial Agency also publishes worked examples for:
- a small technology supplier;
- a medium-sized vehicle supplier;
- a large construction supplier.
See the official Carbon Reduction Plan examples.
Use them for structure.
Do not copy another company’s targets, assumptions or carbon figures simply because its plan looks complete. Those numbers describe somebody else’s business.
FAQs about PPN 006 Carbon Reduction Plans
How often must a Carbon Reduction Plan be updated?
At least annually.
The technical standard says suppliers should review and update it within six months of their financial year-end.
For a live tender, also check the separate 12-month publication test.
How recent must the emissions data be?
The reporting period should normally fall no more than 18 months before the tender notice.
If it is older, an acceptable explanation may determine whether the condition of participation is passed.
Can an SBTi target replace a Carbon Reduction Plan?
No.
SBTi or Race to Zero commitments can be described as environmental management measures, but they do not replace the PPN 006 CRP.
Can a subsidiary use its parent company’s plan?
Sometimes, subject to the Government’s conditions.
Do not assume common ownership is enough.
Do subcontractors need a Carbon Reduction Plan?
Not solely because they are subcontractors.
The contracting supplier is the organisation subject to the PPN 006 requirement. Consortium members should each complete a CRP.
What happens if our emissions have increased?
The plan does not automatically fail.
Explain material changes and continue to show how the organisation intends to reduce emissions.
What if we have been trading for less than a year?
The guidance is designed not to disadvantage new suppliers simply because they do not yet have a full historic reporting period.
Follow the Government provisions for new suppliers and produce the full plan as soon as reasonably possible.
Is PPN 006 the same as SECR?
No.
SECR is a corporate energy and carbon reporting requirement for qualifying UK organisations.
PPN 006 is a procurement measure.
Some underlying emissions information can overlap, but completing one does not automatically complete the other.
Is PPN 006 the same as social value?
No.
PPN 006 is a condition of participation.
The Social Value Model under PPN 002 is used at the award stage.
If the footprint is the part you need help with
The Government has already given you the template.
What it cannot give you is your company’s carbon footprint.
If you need the reporting boundary defined, the required data turned into a defensible calculation and the assumptions documented so the exercise can be repeated next year, that is where C Level can help.
If the tender is live, send us the deadline and tell us what footprint work you have already done.
Talk to C Level about carbon footprint consultancy
Sources and methodology
We checked this article against the current primary guidance rather than relying on commercial summaries. This page was last reviewed on 21 August 2026.
- Cabinet Office, PPN 006: Taking account of Carbon Reduction Plans. View the notice
- Cabinet Office, PPN 006 Technical Standard for Completion of Carbon Reduction Plans. View the technical standard
- Cabinet Office, PPN 006 Frequently Asked Questions. View the questions
- Cabinet Office, PPN 006 Guidance on adopting and applying conditions of participation. This is the assessment guidance referred to above, and the source of the 18-month reporting-period test and the treatment of a scope that cannot be reported. View the assessment guidance
- Department for Energy Security and Net Zero, UK Government greenhouse gas conversion factors 2026. View the 2026 factors
- Greenhouse Gas Protocol, Corporate Accounting and Reporting Standard. View the standard
- NHS England, 2027 NHS Carbon Reduction Plan requirements. View the NHS requirements
- NHS England, market sounding findings for April 2027 supplier requirements. View the findings