Carbon Reduction Plans — the PPN 006 requirement
A pass or fail on central government contracts above £5m a year.
A carbon reduction plan is a gate, not a report
A Carbon Reduction Plan is not a sustainability report, and it is not scored. It is a condition of participation — a pass or a fail, taken at the selection stage of a procurement, before anyone reads your bid.
You either have a compliant plan on your website or you do not. There is no partial credit and no better answer.
The requirement comes from PPN 006, “Taking account of Carbon Reduction Plans in the procurement of major government contracts”, published by the Cabinet Office on 17 February 2025 and last updated on 10 July 2025. Its paragraph 10 tells buyers to include, “as a condition of participation, a requirement for bidding suppliers to provide a CRP”.
The accompanying guidance is blunter about what happens next: the questions “should be assessed on a pass/fail basis based on self-declarations”, and a supplier “should only be prevented from being awarded a public contract” where the plan fails those criteria.
Which makes this the cheapest compliance document in UK procurement to get right, and an expensive one to get wrong.
Five million a year, and only central government
Paragraph 2 of the PPN sets the buyers: it “applies to all central government departments, their executive agencies and non-departmental public bodies”. That is the whole list. Local authorities, NHS trusts, schools, universities and police forces are not in it.
Paragraph 3 sets the contracts: goods, services or works, other than special regime contracts, “with an estimated contract value above £5 million per year (including VAT)”.
Read that twice, because two words in it are load-bearing and both are usually reported wrong. Per year, not per contract — a four-year contract is tested on its annual value. And including VAT, which is the opposite of what the predecessor said and is dealt with in the next chapter.
The PPN binds procurements advertised on or after 24 February 2025 — the day the Procurement Act 2023 itself came into force. It is not stated to be mandatory for the devolved administrations; Wales runs its own parallel notice, and Scotland and Northern Ireland operate separate regimes.
If you sell to a council or a hospital trust, this notice does not reach you. If you sell to a department, an agency or an NDPB above the threshold, it decides whether you can bid at all.
Excluding VAT became including VAT
This is the single most consequential difference between the old notice and the new one, and it is almost never reported.
PPN 06/21 set the trigger at “£5 million per annum (excluding VAT)”. PPN 006 sets it at “£5 million per year (including VAT)”.
At the standard rate that is a trigger of roughly £4.17 million excluding VAT. The net got wider, and nobody announced it.
The government’s own frequently asked questions say that “the substantive obligation introduced by PPN 06/21, now PPN 006, remains the same under the Act (but as a condition of participation as opposed to selection criteria)”. That is true of what the plan must contain. It is not true of who has to produce one.
Both statements are primary and both are on the record, so the honest formulation is three-part: the content requirements are materially unchanged, the mechanism was recast from selection criterion to condition of participation, and the threshold’s VAT basis changed. Any page still printing “£5m excluding VAT” for the current regime is wrong.
And one more number to keep separate: the Procurement Act works threshold is £5,193,000. Different figure, different purpose, and it is not this one.
Frameworks are in scope, not carved out
“Frameworks are excluded” is one of the more confident errors in this area. Paragraph 4 of the PPN says the opposite: it “applies to frameworks and dynamic markets but only where it is estimated that the individual value of any contract to be awarded … is greater than £5 million per year (including VAT)”.
Filtered by the value of the individual call-off. Not carved out — sifted.
So a place on a framework does not exempt you, and the test is applied at the call-off rather than at the framework as a whole. A supplier who sits on several frameworks and expects a large call-off from any of them needs a current plan before that call-off is advertised, not after it.
There are genuine exclusions. Special regime contracts are out on the face of paragraph 3. Anything below the threshold is out. And the guidance disapplies the measure where it “would not be relevant to the contract or proportionate to its nature, complexity and cost”, with a further provision for exceptional circumstances — which is a judgement for the buyer, not a door for the bidder.
The practical rule: if you are chasing central government work at any real scale, assume you need one and keep it current.
That is who needs one. Now what goes in it.
Seven sections, and one of them is a signature
The plan itself is short. Annex A of the PPN is a template, and a compliant carbon reduction plan follows it: supplier name and publication date; a commitment to achieving net zero by a stated year; a baseline emissions footprint; current emissions for the reporting year; emissions reduction targets with a projection; carbon reduction projects, completed and planned; and a declaration and sign-off.
The declaration is not decoration. It states that the plan “has been completed in accordance with PPN 006”, and it is the thing a buyer checks first.
Both emissions tables ask for the same four rows — Scope 1, Scope 2, the required Scope 3 subset, and the total — in tonnes of carbon dioxide equivalent. The baseline table also asks for the baseline year and for “additional details relating to the baseline emissions calculations”, which is where the assumptions belong.
It is a document of perhaps four pages. The work is not in the writing; it is in having a defensible number for each row and being able to say where it came from.
A plan that is beautifully written and cannot show its working fails the same way as a plan that was never published.
Five of the fifteen, and not the big one
“Scope 3 is required” is true and almost useless. The technical standard names exactly five of the fifteen Greenhouse Gas Protocol categories, and the one that dominates most suppliers’ footprints is not among them.
Paragraph 9 sets the frame: carbon reduction plans “focus upon the recording and reporting of Scope 1 and 2 emissions” and introduce “additional reporting against a subset of Scope 3 emissions”. Paragraph 15 names the subset: category 4, upstream transportation and distribution; category 5, waste generated in operations; category 6, business travel; category 7, employee commuting; and category 9, downstream transportation and distribution.
Four, five, six, seven and nine. The list is not contiguous — category 8 is absent — and category 1, purchased goods and services, is not required at all.
That matters both ways. It makes a compliant plan achievable for a services business that could not possibly measure its whole supply chain. And it means a Carbon Reduction Plan is not a full Scope 3 inventory and should never be presented as one — if a customer asks for your Scope 3 emissions and you send a CRP, you have answered a different question.
Measurement follows the GHG Protocol Corporate Accounting and Reporting Standard, in tonnes of CO2e, using the conversion factors published by the UK government. The same reporting period must be used throughout the submission.
Where the baseline year actually comes from
A small sourcing point that decides whether a plan is defensible. Search the technical standard for “baseline year” and you will not find it. The standard speaks of a single year’s footprint and requires that “the same reporting period is used throughout the submission”.
The baseline construct lives in the template, not the standard. Annex A asks for a baseline year and for the calculations behind it.
So the two documents divide differently from how commentary describes them: the technical standard governs scope, methodology, publication and sign-off; the template governs the shape of the disclosure, including the baseline. Attributing a baseline requirement to the standard is a citation error, and the kind a buyer’s commercial team will not notice but a challenge might.
Practically: pick a year you have clean data for, state it, keep it, and put the assumptions in the “additional details” field. Restating a baseline later is ordinary and permitted — changing it silently between bids is not.
The baseline is the number every later claim of progress is measured against. It is worth more care than the target.
A director signs it and the homepage carries it
Two requirements in the technical standard are dropped from almost every summary, and both are checkable by a buyer in under a minute.
The plan “must be signed off by a director (or equivalent) or designated member (for LLPs)”, with their name, job title and the date.
The plan should also state that board approval has been given, with the date of that approval. A signature without a date, or a job title that is not a director-equivalent, is the most common way a plan that is substantively fine still fails the check.
Then publication. The standard says suppliers “should publish their latest Carbon Reduction Plan on their UK website” and place the link “in a prominent place on your homepage”. Not a PDF emailed with the bid; not a page three clicks into a sustainability microsite.
The test a buyer applies is: can I find this from your homepage, and does it carry a name, a title and a date?
It is worth being unsentimental about why those two rules exist. A condition of participation assessed on self-declaration needs something that cannot be produced the night before, and a dated director signature on a publicly posted document is exactly that.
Twelve months to bid, six months to refresh
There are two different time limits on a Carbon Reduction Plan and they are constantly merged into one. They do different jobs and they run from different events.
Twelve months decides whether the plan you have is usable in the bid in front of you.
The government’s frequently asked questions put the pass criterion as a plan that has been signed off at an appropriate level and published “since the publication of the tender notice, or in the preceding 12 month period”. The same document confirms that suppliers need only one plan, valid for twelve months, usable across every procurement where the measure applies.
Six months decides when you have to produce a new one.
The technical standard says plans “should be reviewed and updated annually”, and “within 6 months of your organisation’s financial year-end”. That is a refresh cadence tied to your accounts, not to anybody’s tender.
Run them together and you get the wrong answer in both directions: a plan eleven months old is usable even if your year-end was ten months ago, and a plan published seven months after year-end is late even if no tender has appeared. Diarise both.
Ambition earns nothing, and that is deliberate
A supplier targeting net zero by 2030 and a supplier targeting 2050 are treated identically. The frequently asked questions say plans “should not be ‘scored’ or compared against each other”, and that assessment “takes the form of a check that they meet the requirements of the measure”.
The government’s own worked example has both suppliers passing, and says plainly that “neither scores higher or has any other advantage over the other”.
2050 is a backstop, not a target: the technical standard asks suppliers to confirm a commitment to “achieving Net Zero by 2050 at the latest”. Earlier is permitted and earns nothing under this measure.
Two consequences follow, and they point in opposite directions. If you are bidding, do not spend money making a Carbon Reduction Plan more ambitious in the hope of a better score — there is no score. If you are trying to win on sustainability, the lever is the award stage, not this one, which is what makes the next act of this page matter.
This measure asks one question and asks it strictly: is there a compliant plan, or not?
That is the plan. Now the regime around it.
What a buyer does with it, and what failing means
The guidance is the operative document here, and it is more directive than the notice. Where PPN 006 says buyers “should include” the condition, the guidance says in-scope organisations “must include the questions in Annex A within their conditions of participation for in-scope procurements”.
If you need to state the obligation as absolute, cite the guidance’s “must”, not the notice’s “should”.
The mechanics are simple. Two questions, assessed pass/fail on self-declaration. A non-compliant response is marked Fail, and the consequence is exclusion from that procurement — the guidance says a supplier “should only be prevented from being awarded a public contract” where the plan fails the criteria, which is both the limit on the buyer and the consequence for the bidder.
One thing this page will not tell you, because no document found says it: whether a supplier can correct a deficient plan after submission. The guidance contains no provision for curing one. The Act’s general clarification machinery may or may not reach it. As at 10 September 2026 that is not established, and the safe assumption is that it cannot.
Which is an argument for the plan being current, published and signed before a tender notice ever appears.
PPN 06/21 was never actually withdrawn
Search for when PPN 06/21 was withdrawn and you will find dates. None of them is on the document.
The PPN 06/21 page carries no withdrawal banner and no “this publication was withdrawn on” notice. Its change history ends on 17 April 2023. On the procurement policy note index it sits under the heading “Out of date procurement policy notes” — a categorisation, with no deprecation date given.
And PPN 006 itself keeps it alive: “For procurements commenced and contracts awarded before this date, please refer to PPN 06/21.”
So the accurate formulation is that PPN 06/21 was superseded in application from 24 February 2025 for Procurement Act procurements, and remains the operative document for procurements commenced, and contracts awarded, before that date. There is no withdrawal date to cite, and a page that states one is stating something that is not on the record.
The renumbering is worth a similar caution. PPN 06/21 was issued by the Government Commercial Function; PPN 006 by the Cabinet Office. The index is now split between sequentially numbered Procurement Act notices and the old NN/YY format, and the change coincides with the February 2025 refresh — but no primary document announcing a numbering policy was located, so this page describes what the index shows rather than asserting a policy.
Inside the Procurement Act, not beside it
A Carbon Reduction Plan is a policy requirement delivered through a statutory mechanism. The policy is the PPN; the vehicle is the condition of participation, which is a creature of the Procurement Act 2023.
The dates line up exactly: the Act came into force on 24 February 2025, and PPN 006 applies to procurements advertised on or after 24 February 2025.
That commencement date is itself worth pinning, because it moved. S.I. 2024/959, made on 16 September 2024, substituted “24th February 2025” for the “28th October 2024” that an earlier commencement order had set. Anything dated to the original date is describing a regime that never started.
The National Procurement Policy Statement of 13 February 2025, issued under section 13 of the Act, sits alongside. It carries climate content — “accelerating to net zero, reducing greenhouse gas emissions in line with the UK national carbon budget” — and asks that suppliers demonstrate commitment to environmental impact.
But it does not mention PPN 006 or Carbon Reduction Plans by name. The relationship is thematic alignment, not cross-reference.
Three notices, and only one of them is this
Three Cabinet Office notices carry carbon content and are routinely merged. They are not the same instrument and they do not do the same job.
PPN 006 is mandatory, organisation-level, selection-stage, pass/fail, above £5 million a year.
PPN 016, the carbon reduction contract schedule, is optional. It is a contractual mechanism for emissions at the level of a single contract — a contract carbon footprint, reduction plans with annual targets — aimed at high-emission categories, with no financial threshold, applied on proportionality. It succeeded PPN 01/24 on 17 February 2025.
PPN 002, the Social Value Model, is award-stage and scored — and its own threshold is not a pound figure. ¶6 applies it to any covered procurement under the Procurement Act 2023, “that is to say, above-threshold”, at a flat minimum 10% of the total score. The £1 million total contract value test arrives with PPN 026 on 1 January 2027, not before. Its model runs five government missions and eight outcomes, and its carbon content sits in outcome 4, sustainable procurement practices.
And the FAQ forbids the obvious mistake outright: “PPN 006 should not be applied as part of the requirements of the Social Value Model, it is a separate measure.”
Note that the thresholds differ in both level and basis. PPN 006 tests £5 million per year. Social value tests the Act’s own threshold today, and £1 million total contract value from January. A contract can easily be in scope of one and not the other, and the answer changes on 1 January 2027.
That is the regime. Now what January changes.
The new social value model has no environment in it
This is the development that matters most, and it landed five weeks ago with very little noise.
PPN 026, “The Social Value Model”, was published by the Cabinet Office on 5 August 2026. It applies to procurements commenced on or after 1 January 2027, to covered procurements at £1 million total contract value inclusive of VAT or above, with a minimum 10% weighting between £1m and £5m and a minimum 20% at £5m and above. Both of those are new: PPN 002 sets no pound threshold and a flat 10%, so the floor rises and the weighting doubles at the top. The social value model takes both apart in full.
It has two outcomes. Outcome 1 is Good Jobs; outcome 2 is Skills. There is no environmental, net zero, carbon or sustainability outcome.
Set that beside PPN 002, whose model runs eight outcomes and whose outcome 4 carries working towards net zero, clean energy, and measurement in tonnes of CO2e. On the face of the two documents, the award-stage carbon lever in central government social value has no successor from 1 January 2027.
Two cautions, because this is exactly the kind of claim that gets overstated. PPN 026 does not name PPN 002 or PPN 06/20 as superseded — it refers only to “the previous edition”, available during a transition period. And PPN 002 carries no supersession banner as at 10 September 2026. So this page states what each document says rather than asserting a supersession neither of them asserts. The accompanying PPN 026 guidance “will be published in autumn 2026” and had not appeared as at 10 September 2026.
If it lands as drafted, PPN 006’s pass/fail becomes the principal carbon requirement in central government procurement — and a pass/fail cannot reward anybody for doing better.
How to build one that passes
The order that works, for a supplier starting from nothing.
One. Choose a reporting year you have clean data for, and use it consistently throughout the submission.
Two. Measure Scope 1 and Scope 2 in full, then the five required Scope 3 categories — 4, 5, 6, 7 and 9. Use the GHG Protocol Corporate Standard and the UK government conversion factors, and note which factor year you used. Three. Set the baseline in the template, with the assumptions in the additional-details field, and state the current year beside it.
Four. State the net zero commitment — 2050 at the latest — and the reduction targets with a projection. Five. List the carbon reduction projects you have completed and those planned, with the effect of each where you can quantify it. Six. Get a director’s signature with a name, a job title and a date, and state the board approval and its date.
Seven. Publish it on your UK website with a link in a prominent place on your homepage. This is the step that gets skipped.
If you already report under SECR you have most of Scope 1 and 2 and your business travel already, in the right units and on the right basis — the incremental work is waste, commuting and the two transport categories. If you are building a Scope 3 inventory for other reasons, the CRP categories are a strict subset of it. Do the measurement once.
Then diarise the refresh for within six months of your financial year-end, and check the published date before every bid.
Eight things said about these plans that are wrong
Each of these is in circulation, and each is contradicted by a document in the rail beside this card.
“The threshold is £5 million excluding VAT.” That was PPN 06/21. PPN 006 says including VAT.
“PPN 06/21 was withdrawn on…” — there is no withdrawal notice and no date. “Only the numbering changed.” The mechanism changed from selection criterion to condition of participation, and the threshold’s VAT basis changed with it. “Frameworks are excluded.” They are in scope, filtered by the value of the individual call-off.
“A more ambitious net zero date scores better.” Plans are never scored or compared. 2050 is a backstop.
“Scope 3 is required.” Five named categories are — 4, 5, 6, 7 and 9 — and category 1 is not among them. “The baseline year is in the technical standard.” It is in the template. “It applies to the public sector.” It applies to central government departments, their executive agencies and non-departmental public bodies.
The pattern behind most of them is the same: a fact about the 2021 notice, or about a neighbouring notice, restated as a fact about the current one. Three separate documents carry carbon requirements in central government procurement and they have different thresholds, different stages and different consequences.
What is left is the record.
What is still moving, and what is not established
Three things to watch, and two the record does not answer.
PPN 026 guidance. Promised for autumn 2026 and not published as at 10 September 2026. It is what will say how the two-outcome model is applied in practice.
PPN 006 itself has not changed since 10 July 2025. Its landing page shows a 5 August 2026 timestamp with no change note, on the same day the whole notice collection was re-indexed — consistent with a platform refresh rather than an edit, but it is a timestamp without an explanation and is recorded here as one. The same applies to PPN 016.
Whether the environmental outcome returns. PPN 026 as published has none, PPN 002 carries no supersession banner, and nothing located says what happens to outcome 4 after 1 January 2027.
Not established, and stated as such: whether a supplier can correct a deficient plan after submission. No provision for curing one was found.
Also not established: any primary document announcing the move from NN/YY to sequential notice numbering. The change is visible on the index and coincides with the February 2025 Procurement Act refresh; no document explaining it was located, so this page does not cite one.
Two suppliers, one targeting net zero in 2030 and one in 2050, both pass and neither gains anything by it. That is what a condition of participation is for: it sets a floor, and it is not the place to compete.
The bottom line · Photo: Unsplash / name_gravityCarbon Reduction Plans — key facts
Every requirement on this page in one place, each with the document it comes from.
Where the honest answer is that the record does not say, the line says that, and carries the date it was last checked.
Carbon Reduction Plans — frequently asked questions
A Carbon Reduction Plan (CRP) is a short published document setting out an organisation’s carbon footprint and its commitment to reaching net zero. In UK central government procurement it is required by PPN 006 as a condition of participation: bidders for in-scope contracts must provide one, and it is assessed pass/fail at the selection stage rather than scored.
It follows a template at Annex A of the PPN and covers a baseline emissions footprint, current emissions, reduction targets, carbon reduction projects, and a declaration signed by a director.
Suppliers bidding for contracts advertised by central government departments, their executive agencies and non-departmental public bodies, where the estimated contract value is above £5 million per year including VAT, for goods, services or works other than special regime contracts.
It does not apply to the wider public sector — local authorities, NHS trusts, schools, universities and police forces are outside PPN 006 — and it is not stated to be mandatory for the devolved administrations. It does apply to frameworks and dynamic markets, but only where the individual call-off is estimated above the same threshold.
Including VAT, and per year. Paragraph 3 of PPN 006 sets the trigger at an estimated contract value above “£5 million per year (including VAT)”.
This is a change from the predecessor. PPN 06/21 set it at “£5 million per annum (excluding VAT)”. At the standard rate of VAT, a £5m including-VAT trigger catches contracts of roughly £4.17m excluding VAT, so more contracts are in scope than under the old wording. Any guidance still quoting “excluding VAT” for the current regime is out of date.
Five of the fifteen Greenhouse Gas Protocol categories. Paragraph 15 of the technical standard names category 4 (upstream transportation and distribution), category 5 (waste generated in operations), category 6 (business travel), category 7 (employee commuting) and category 9 (downstream transportation and distribution).
Category 8 is absent from that list, and categories 1 to 3 and 10 to 15 are not required — including category 1, purchased goods and services, which is usually the largest element of a supplier’s Scope 3 footprint. Scope 1 and Scope 2 emissions are reported in full.
There are two separate rules and they are often confused. The technical standard says plans should be reviewed and updated annually, and within six months of the organisation’s financial year-end. That is the refresh cadence.
Separately, for a plan to be usable in a bid it must have been signed off and published since the publication of the tender notice or within the preceding 12 months. One plan, valid for twelve months, can be used across every procurement where the measure applies.
Yes. The technical standard says suppliers should publish their latest Carbon Reduction Plan on their UK website, and place the link in a prominent place on the homepage. Supplying it only with the bid does not satisfy the requirement.
The plan must also be signed off by a director (or equivalent), or a designated member for an LLP, giving their name, job title and the date, and should state that board approval was given, with the date of that approval.
No. The government’s frequently asked questions state that supplier plans should not be scored or compared against each other, and that assessment takes the form of a check that they meet the requirements of the measure.
A supplier committing to net zero by 2030 and one committing by 2050 both pass, and neither gains any advantage over the other. The technical standard asks for a commitment to net zero by 2050 at the latest, so 2050 is a backstop rather than a target to beat.
A non-compliant response is marked Fail, and the guidance provides that a supplier should be prevented from being awarded the public contract where the plan fails the specified criteria. In practice that means exclusion from that procurement at the selection stage.
Whether a supplier can correct a deficient plan after submission is not established: no provision permitting a plan to be cured was found in the guidance as at 10 September 2026. The safe course is to have a compliant, published, signed plan in place before a tender notice appears.
Not formally. The PPN 06/21 page carries no withdrawal banner and no withdrawal date, and its change history ends on 17 April 2023. On the procurement policy note index it is listed under “Out of date procurement policy notes”, which is a categorisation rather than a withdrawal.
PPN 006 itself preserves it: for procurements commenced and contracts awarded before 24 February 2025, it directs readers back to PPN 06/21. The accurate statement is that PPN 06/21 was superseded in application from that date and remains operative for earlier procurements. Any specific withdrawal date quoted for it is not on the record.
PPN 006 is mandatory, organisation-level, applied at the selection stage as a pass/fail condition of participation, and triggered above £5 million per year including VAT.
PPN 016, the carbon reduction contract schedule, is optional. It is a contractual mechanism operating at the level of an individual contract, covering a contract carbon footprint and emissions reduction plans with annual targets, aimed at high-emission categories. It has no financial threshold and is applied on proportionality. The two are frequently merged in commentary and do different jobs.
PPN 026, published on 5 August 2026 and applying to procurements commenced on or after 1 January 2027, sets out a Social Value Model with two outcomes: Good Jobs and Skills. There is no environmental, net zero, carbon or sustainability outcome in it. The current model under PPN 002 has eight outcomes, of which outcome 4 carries the carbon content.
Two cautions. PPN 026 does not name PPN 002 as superseded — it refers only to “the previous edition” during a transition period — and PPN 002 carries no supersession banner as at 10 September 2026. The accompanying PPN 026 guidance was promised for autumn 2026 and had not been published as at that date.
Largely, for part of it. SECR reporting already produces Scope 1 and Scope 2 emissions and business travel on a GHG Protocol basis using the UK government conversion factors, which is the same basis a Carbon Reduction Plan requires.
The additional work is the rest of the required Scope 3 subset — waste generated in operations, employee commuting, and upstream and downstream transportation and distribution — plus the baseline year, the targets and projections, the project list and the director sign-off. The measurement is best run once and used for both.
Carbon Reduction Plans — primary sources
Every document below was opened in full on 10 September 2026.
Where this page says the record does not establish something, that is a finding from these documents, not an omission.
PPN 006 and its document set
The predecessor
The neighbouring notices
The statutory frame
The wider statutory frame
The social value lineage, and the government estate
Measurement
Go deeper on measuring and reporting carbon
Scope 3 Emissions
All fifteen categories — five of which a Carbon Reduction Plan needs.
The three scopesScope 1, 2 and 3
Where the boundaries fall, and what each scope actually covers.
The methodThe GHG Protocol
The accounting standard the plan is required to follow.
Energy and carbonSECR Reporting
The annual disclosure that gives you most of Scope 1 and 2 already.
The numbersCarbon Accounting
How the figures behind the tables are actually built.
The toolsCarbon Reporting Software
Seventeen UK platforms compared for the reporting this needs.
ImportsUK CBAM
The carbon tax on imported goods, from 1 January 2027.
Energy auditsESOS
The four-yearly audit obligation for large undertakings.
The calendarUK Regulation Timeline
Every dated UK sustainability obligation in one place.