Carbon reduction plans · PPN 006
Carbon reduction plan: what a bid team has to produce
A carbon reduction plan is the document central government buyers ask bidders for on contracts worth more than £5 million a year.
For procurements from 24 February 2025 the rules are in PPN 006; for earlier ones, PPN 06/21 still applies.
This page tests whether a contract triggers a plan, then goes through what the plan must contain and which emissions it counts.
What PPN 006 is
A condition of participation, not a law on companies
Procurement Policy Note 006 is Cabinet Office policy that binds in-scope contracting authorities.
It tells them to include a carbon reduction plan as a condition of participation in relevant procurements.
It puts no duty on any company to hold a plan in the abstract.
“Companies are legally required to have a carbon reduction plan” is therefore wrong; the accurate version is that bidders for in-scope contracts above the threshold are asked for one.
The buyers in scope are “all central government departments, their executive agencies and non-departmental public bodies”.
That list does not reach the NHS, which runs its own requirement, covered below.
Where it does apply, the plan is a condition of participation in that one procurement, and the next tender is tested afresh.
A plan is needed only when all five hold
- You are bidding for a specific contract.
- The buyer is a central government department, executive agency or non-departmental public body.
- The procurement commenced on or after 24 February 2025 (otherwise PPN 06/21).
- The buyer has applied PPN 006 to it.
- Its estimated value is above £5 million a year including VAT.
Source: PPN 006 ¶¶6–9 and footnote 5
The value test
Above £5 million a year, averaged and including VAT
PPN 006 applies to contracts with “an estimated contract value above £5 million per year (including VAT)”.
Footnote 5 says the figure is the advertised contract value averaged over the life of the contract.
Its own example is a four-year contract worth £21 million, which is in scope even if the first year is under £5 million, because £21 million over four years is £5.25 million a year.
Two consequences follow from the wording.
First, it is strictly “above”, so a contract averaging exactly £5 million a year is not caught.
Second, the PPN 006 FAQ confirms the test is per contract and VAT-inclusive, never a total of a supplier’s government work.
The old note drew the line differently: the PPN 06/21 FAQ set it at £5 million per annum excluding VAT.
A contract near the line can therefore fall on different sides of it depending on which note governs.
PPN 006 — does the value trigger a plan?
Use the advertised contract value, including VAT, and the full contract term.
Enter both figures to see the result.
PPN 006: “above £5 million per year (including VAT)”, averaged over the life of the contract (footnote 5). Tests one contract, never a supplier’s total government work.
The document
Six headings, and a board sign-off
The Cabinet Office publishes a template with PPN 006, and its section 7 fixes the structure.
Deviating from the template is risky, because the buyer checks the plan against it.
| Section | What goes in it | Practical note |
|---|---|---|
| 7.1 Commitment to achieving net zero | A commitment to net zero by 2050 in the UK | An earlier target date is allowed; a later one does not meet the requirement |
| 7.2 Baseline emissions footprint | The baseline year and its Scope 1, 2 and required Scope 3 emissions | An organisation with no prior footprint uses its first reporting period as the baseline |
| 7.3 Current emissions reporting | The latest reporting year, on the same basis | Keep the boundary the same as the baseline |
| 7.4 Emissions reduction targets | Targets on the path to net zero | Targets are the organisation’s own |
| 7.5 Carbon reduction projects | Measures completed and planned, including those that can apply in the contract | Buyers look for measures the bidder can actually apply |
| 7.6 Declaration and sign-off | Reviewed and signed off by the board of directors or equivalent management body | No physical signature needed, but it must say it has been signed |
The net zero date in 7.1 tracks the UK’s own 2050 target; the old PPN 06/21 FAQ told buyers not to demand a date earlier than 2050.
Targets that sit behind 7.4 are often set with the SBTi, which our page on science-based targets explains; a validated target is not required by PPN 006.
What is counted
Scope 1 and 2 in full, and five Scope 3 categories
The Technical Standard requires Scope 1 and Scope 2 in full, and five Scope 3 categories only.
Purchased goods and services, category 1, is not among them, so a plan does not “cover Scope 3” in the sense of the full value chain.
The footprint covers emissions from sources in the United Kingdom.
The organisational boundary may be set by financial control, operational control or equity share, following the GHG Protocol Corporate Standard.
Report in CO₂e for seven greenhouse gases, including nitrogen trifluoride.
PPN 006’s own ¶11 says “six”, but its footnote and the Technical Standard name seven, and the note says plans must meet the supporting guidance, so seven governs.
The footprint “should be conducted to a reasonable level of assurance”, yet “there is no requirement to have your carbon footprint audited”.
Activity data becomes CO₂e through the DESNZ conversion factors; our guide to the current UK emission factors sets out which year’s set to use.
For what sits inside each scope, see Scope 1, 2 and 3 emissions, and for the wider value chain, Scope 3 emissions reporting.
| Scope 3 category | In the plan? |
|---|---|
| 4 Upstream transportation and distribution | Required |
| 5 Waste generated in operations | Required |
| 6 Business travel | Required |
| 7 Employee commuting | Required |
| 9 Downstream transportation and distribution | Required |
| 1 Purchased goods and services, 2 Capital goods, 3 Fuel- and energy-related activities | Not required |
| 8, 10–15 Leased assets, processing, use and end-of-life of sold products, franchises, investments | Not required |
After the bid
Publish it, update it yearly, and use a parent’s plan only briefly
The Technical Standard asks for review and update within six months of the organisation’s financial year-end.
The plan is published on the organisation’s website.
An organisation without a website must provide a copy in writing to anyone who requests one within 30 days.
A subsidiary may rely on its parent’s plan only if every condition in PPN 006 ¶10 is met.
The plan must meet the Technical Standard in full, and the bidder must be wholly owned by the parent.
The parent’s net zero commitment must be adopted by the bidder in a statement in the plan, the measures must be stated to be applicable by the bidder, and the plan must be on the bidder’s own website.
The note adds that relying on a parent’s plan “may only be a temporary measure”.
For a company already reporting under SECR, the energy and Scope 1 and 2 work overlaps, which our page on SECR requirements sets out; the Scope 3 categories are the extra work.
Which rules apply
PPN 06/21, PPN 006, and the NHS
| PPN 06/21 | PPN 006 | NHS England (v3) | |
|---|---|---|---|
| Applies to | Procurements from 30 Sep 2021 under the Public Contracts Regulations 2015 | Procurements commenced on or after 24 Feb 2025 | NHS procurement of goods, services and works |
| Value line | £5m per annum, excluding VAT | Above £5m a year, including VAT, averaged | Full plan at £5m a year; Net Zero Commitment below |
| Buyers | Central government departments, executive agencies, NDPBs | The same | NHS bodies, under a separate instrument |
| Plan accepted | PPN 06/21 template | PPN 006 template and Technical Standard | A plan built to PPN 006 |
PPN 006 does not retrospectively replace the old note: for procurements commenced and contracts awarded before 24 February 2025, it tells buyers to refer to PPN 06/21.
PPN 006 ties that date to the Procurement Act 2023 in one paragraph and speaks of procurements “advertised” from it in another, so check the tender notice date.
Under the old note, the selection guidance made the check pass or fail rather than scored, and required the reporting period to fall no more than 12 months before the procurement commenced.
The NHS England requirement is its own document, version 3 of 11 December 2025, and accepts a plan built to PPN 006.
Carbon does not come back in through social value: the PPN 026 model that applies from 1 January 2027 has no environmental outcome or award criterion.
The body formerly called Crown Commercial Service has been the Government Commercial Agency since 1 April 2026.
Some consultancy pages describe PPN 006 as “formerly PPN 06/21”.
No Cabinet Office document uses that phrase: the two notes coexist, each for its own procurements.
A plan is one of several carbon duties a supplier can face, set out in our guide to carbon compliance consultancy; what a net zero adviser delivers is on our net zero consultancy page.
To talk through a specific tender, you can book a free 15-minute call.
Frequently asked
Questions people ask
Do I need a carbon reduction plan to bid for a government contract?
Only for some contracts. Under PPN 006 a central government department, executive agency or non-departmental public body should include a carbon reduction plan as a condition of participation in procurements with an estimated value above £5 million a year including VAT, averaged over the life of the contract. It is procurement policy applied contract by contract, not a legal duty on companies to hold a plan.
Is PPN 06/21 still in force?
For older procurements only. PPN 006 applies to procurements commenced on or after 24 February 2025, the date the Procurement Act 2023 regime began, and says that for procurements commenced and contracts awarded before that date buyers should refer to PPN 06/21. A contract let under PPN 06/21 keeps that basis.
Is the £5 million carbon reduction plan threshold per year or in total?
Per year, averaged over the life of the contract, and including VAT. PPN 006’s own example is a four-year contract worth £21 million in total, which is in scope even if the first year is under £5 million. The test is per contract, never a total of a supplier’s government work. Under PPN 06/21 the figure was £5 million per annum excluding VAT.
Which Scope 3 categories must a carbon reduction plan include?
Five: upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution. Scope 1 and Scope 2 are reported in full. Purchased goods and services, capital goods and the other Scope 3 categories are not required.
Who signs off a carbon reduction plan?
The template’s declaration states that the plan has been reviewed and signed off by the board of directors or equivalent management body. The Technical Standard says a physical signature is not needed, but the plan should clearly state that it has been signed.
Does the carbon footprint in a carbon reduction plan have to be audited?
No. The Technical Standard says the footprint should be conducted to a reasonable level of assurance, but also that there is no requirement to have it audited.
How often must a carbon reduction plan be updated?
The Technical Standard asks for review and update within six months of the organisation’s financial year-end, so in practice once a year.
Can a subsidiary use its parent company’s carbon reduction plan?
Only under conditions, and only as a temporary measure. PPN 006 allows it where the plan meets the Technical Standard in full, the bidder is wholly owned by the parent, the parent’s net zero commitment is adopted by the bidder in a statement in the plan, the measures can be applied by the bidder, and the plan is published on the bidder’s own website.
Does the NHS ask for a carbon reduction plan?
Yes, under its own instrument rather than PPN 006, whose scope does not reach the NHS. NHS England’s requirements (version 3, 11 December 2025) accept a plan built to PPN 006 at the same £5 million a year threshold, and ask for a lighter Net Zero Commitment below it.
Is there an official carbon reduction plan template?
Yes. The Cabinet Office publishes one with PPN 006. Its headings are commitment to achieving net zero, baseline emissions footprint, current emissions reporting, emissions reduction targets, carbon reduction projects, and declaration and sign-off.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- Cabinet OfficePPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts (updated February 2025)
Scope of buyers, the £5m a year threshold and footnote 5, ¶¶7, 9 and 10, and the template.
- Cabinet OfficePPN 006 Technical Standard for Completion of Carbon Reduction Plans
The five Scope 3 categories, seven gases, UK sources, boundary, ¶11 update, ¶18 assurance, ¶25 signature.
- Cabinet OfficePPN 006: Frequently asked questions (issued June 2025, published 10 July 2025)
The threshold is per contract and VAT-inclusive.
- Cabinet OfficePPN 06/21: Taking account of Carbon Reduction Plans (June 2021, updated April 2023)
The note that still governs procurements commenced before 24 February 2025.
- Cabinet OfficePPN 06/21: Frequently asked questions
In effect from 30 September 2021; £5m per annum excluding VAT; frameworks.
- Cabinet OfficeGuidance on adopting and applying PPN 06/21: selection criteria
Pass/fail assessment and the 12-month reporting-period rule under the old note.
- NHS EnglandCarbon reduction plan and net zero commitment requirements for the procurement of NHS goods, services and works (v3, 11 December 2025)
The separate NHS requirement, and the Net Zero Commitment below £5m a year.
- Cabinet OfficePPN 026: The Social Value Model, Annex A
The social value model from 1 January 2027 has no environmental outcome or criterion.
- GHG ProtocolCorporate Accounting and Reporting Standard (revised edition, 2004)
The Scope 1 and 2 accounting the Technical Standard relies on.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard (2011)
Where the five Scope 3 categories are defined.
- Department for Energy Security and Net ZeroGreenhouse gas reporting: conversion factors (collection)
The UK factor sets used to turn activity data into CO₂e.
- Government Commercial AgencyAbout GCA
"Crown Commercial Service became Government Commercial Agency on 1 April 2026."