Public procurement · PPN 006 · Requirements
Carbon reduction plan reporting requirements in the UK: what PPN 006 asks a bidder to publish
The carbon reduction plan reporting requirements in the UK come from PPN 006, a Cabinet Office procurement policy note, not from a statute that binds companies.
A bidder for a central government contract worth more than £5 million a year including VAT must publish a plan reporting Scope 1, Scope 2 and five Scope 3 categories, committed to net zero by 2050.
The plan is checked pass or fail as a condition of participation under the Procurement Act 2023.
In brief
The carbon reduction plan reporting requirements, in brief
The carbon reduction plan reporting requirements in the UK apply to suppliers bidding for major central government contracts, and they reach a supplier only through a specific procurement.
PPN 006 tells central government departments, their executive agencies and non-departmental public bodies to include a plan as a condition of participation on contracts above £5 million a year including VAT.
The plan’s content is fixed by the Technical Standard and the template, and the Cabinet Office’s FAQ settles how buyers check it.
No fine applies; a bid without a compliant plan fails the condition, and section 22(7) of the Procurement Act 2023 lets the buyer exclude the supplier from the procedure.
To check whether a particular contract needs a plan, and to draft one, use the PPN 006 guide; this page lists each requirement against its source.
Every other UK duty is mapped on the sustainability reporting requirements hub.
In one table
Every requirement, with its source
| Requirement | Detail | Source |
|---|---|---|
| Commit to net zero | By 2050 at the latest, for UK operations | PPN 006 ¶¶10–11; TS ¶8; template 7.1 |
| Baseline footprint | Baseline year, Scope 1, 2 and included Scope 3, with assumptions; first reporting period if none earlier | Template 7.2; Annex note 1 |
| Current emissions | Reporting year, Scope 1, 2 and included Scope 3, tCO2e | Template 7.3 |
| Scope 1 and 2 | In full, UK sources, per the environmental reporting guidelines | TS ¶¶10, 14, 16 |
| Scope 3 | Categories 4, 5, 6, 7 and 9 only | TS ¶15; FAQ Q15 |
| Gases and factors | Seven Kyoto gases, tCO2e, UK government conversion factors | TS ¶¶20–21 |
| Boundary | Financial control, operational control or equity share | TS ¶22 |
| Targets | Reduction targets and a five-year projection | Template 7.4 |
| Projects | Completed and planned carbon reduction measures that will apply on the contract | Template 7.5; PPN 006 ¶11 |
| Approval | Board (or members for an LLP) approval stated, with the date | TS ¶24; template 7.6 |
| Sign-off | A director (or designated member), name, job title and date; no physical signature needed | TS ¶25 |
| Publication | Supplier’s UK website, prominent homepage link; copy within 30 days if no website | TS ¶¶12–13, 23 |
| Currency | Reviewed within six months of year end; published in the 12 months before the bid or since the tender notice | TS ¶11; FAQ Q8 |
Which contracts
Which contracts need a plan: every condition must hold
A supplier needs a plan only when every link in that chain holds; remove one and no requirement arises from PPN 006.
The threshold is per contract, not per supplier, and it is averaged: footnote 5 of PPN 006 puts a four-year, £21 million contract in scope even if its first year is under £5 million.
Frameworks and dynamic markets are caught only where the individual contract awarded under them is estimated above £5 million a year, under ¶4.
The plan is required from the organisation the buyer will contract with; subcontractors need not produce one unless they bid in their own right, and each consortium member provides one (FAQ Q19).
Overseas suppliers bidding for in-scope contracts must produce one too, but a supplier with no UK operations can comply without UK emissions data (FAQ Q13).
PPN 006 is not stated to be mandatory for the devolved administrations (FAQ Q3), and NHS bodies apply NHS England’s own requirement, which accepts a PPN 006 plan.
- 1
An in-scope buyer
A central government department, executive agency or non-departmental public body — PPN 006 ¶2.
- 2
A Procurement Act contract
Goods, services or works, other than special regime contracts, commenced from 24 February 2025 — ¶¶3, 6.
- 3
Above £5m a year, including VAT
Advertised value averaged over the contract’s life; call-offs judged individually — ¶¶3–4, fn 5.
- 4
Relevant and proportionate
The buyer decides case by case, and expects it in most contracts — ¶¶12–13.
- 5
Condition of participation
Pass or fail; without a compliant plan the buyer may exclude the bid — ¶10; FAQ Q6–Q7; PA 2023 s.22(7).
What it reports
Scope 1, Scope 2 and five Scope 3 categories
| GHG Protocol category | What it covers | In a plan? |
|---|---|---|
| Scope 1 | Direct emissions from owned or controlled sources | Yes, in full |
| Scope 2 | Purchased electricity, heat, steam and cooling | Yes, in full |
| 3.4 Upstream transportation and distribution | Inbound and purchased logistics in vehicles and facilities you do not control | Yes |
| 3.5 Waste generated in operations | Third-party disposal and treatment of your waste | Yes |
| 3.6 Business travel | Employee travel in vehicles you do not own or operate | Yes |
| 3.7 Employee commuting | Travel between home and work | Yes |
| 3.9 Downstream transportation and distribution | Moving sold products to the end consumer, if you did not pay for it | Yes |
| 3.1 Purchased goods and services, and the other nine categories | Supply chain, capital goods, use of sold products and so on | No |
The footprint covers emissions from sources in the United Kingdom, under ¶16 of the Technical Standard, and follows the GHG Protocol Corporate Standard.
It reports the seven Kyoto gases in tonnes of CO2e using the UK government conversion factors, under ¶¶20–21.
PPN 006 ¶11 says “six” gases while its own footnote 2 and the Technical Standard list seven including nitrogen trifluoride, and the PPN defers to the supporting guidance, so seven is the safe reading.
Scope 1 and 2 follow the environmental reporting guidelines, so a company already reporting under SECR has most of the numbers.
The full fifteen-category picture, and where else in UK law it is asked for, is on Scope 3 reporting requirements.
The template
The template, heading by heading
The plan follows the template in section 7 of PPN 006, under the supplier’s name and the publication date.
Heading 7.1 is the commitment to net zero, and the Technical Standard at ¶8 requires the year to be 2050 at the latest, matching the target in section 1 of the Climate Change Act 2008.
Heading 7.2 gives the baseline year and baseline emissions; a supplier that has never measured uses its first reporting period as the baseline, under Annex note 1.
Heading 7.3 gives the current reporting year’s emissions, and 7.4 the reduction targets with a projection over the next five years.
The projects heading lists completed and future carbon reduction measures, which PPN 006 ¶11 requires to be ones the supplier can apply when performing the contract.
Heading 7.6 is the declaration that the plan meets PPN 006 and its reporting standard and has been signed off by the board, followed by the signature block at 7.7.
The FAQ says a corporate social responsibility statement, a Science Based Targets commitment or Race to Zero membership cannot replace the template, though each can be cited inside it (Q9–Q10).
The editable template file was added to the PPN page on 17 April 2025.
Approval and publication
Board approval, a director’s sign-off and the homepage link
The plan should state that the board of directors, or equivalent management body, has approved it, and give the date, under ¶24 of the Technical Standard.
For a limited liability partnership the members approve it instead.
It must be signed off by a director, or a designated member for an LLP, giving name, job title and date; a physical signature is not needed, but the plan should state clearly that it has been signed, under ¶25.
The latest plan goes on the supplier’s UK website with a link in a prominent place on the homepage, under ¶¶12–13 and 23.
A supplier without a website must provide a copy in writing to anyone who asks, within 30 days.
Keeping earlier plans online is described as good practice, so progress can be followed.
The same board-approval and homepage-link pattern runs through the modern slavery statement requirements, which many of the same bidders also meet.
How current
Two clocks: the annual review and the 12-month rule
The Technical Standard asks for the plan to be reviewed and updated annually, within six months of the supplier’s financial year end, under ¶11.
Separately, for a plan to support a bid it must have been signed off and published since the tender notice or in the preceding 12 months, under FAQ Q8.
One plan valid for 12 months can be used for every procurement where the measure is applied, under FAQ Q9.
A rise in emissions does not fail the check, because the data is not a basis for assessment, under FAQ Q21.
Groups
Relying on a parent’s plan: four conditions, and only for now
A plan should be specific to the bidding entity, under ¶10 of PPN 006.
A plan covering the bidder and its parent is accepted only if it meets the Technical Standard in full and all four conditions hold.
The bidder is wholly owned by the parent.
The parent’s 2050 commitment for UK operations is stated in the plan to apply to the bidder.
The environmental measures are stated to be able to be applied by the bidder on the contract.
The plan is published on the bidder’s own website.
Bidders must take steps to have their own plan as soon as reasonably practicable, because reliance on a parent’s plan may only be temporary.
PPN 006 and PPN 06/21
What changed between PPN 06/21 and PPN 006
| PPN 06/21 | PPN 006 | |
|---|---|---|
| Published | 5 June 2021 | 17 February 2025 (dated February 2025) |
| Applies to | Procurements from 30 September 2021 under the Public Contracts Regulations 2015 | Procurements commenced from 24 February 2025 under the Procurement Act 2023 |
| Threshold | £5m per annum and above, excluding VAT | Above £5m per year, including VAT, averaged over the life |
| Mechanism | Selection criterion, pass or fail | Condition of participation, pass or fail |
| Substance | Net zero by 2050, Scope 1, 2 and five Scope 3 categories | The same — the FAQ says the substantive obligation remains |
| Still used? | Yes, for procurements commenced and contracts awarded before 24 February 2025 | Yes, for everything since |
PPN 006 describes itself as previously issued in June 2021 and updated in February 2025, and says the update does not constitute a change in policy, under ¶8.
The VAT basis did change, so a contract worth between about £4.17 million and £5 million a year excluding VAT can be caught under PPN 006 when it was not under PPN 06/21.
The PPN 006 page was last updated on 10 July 2025, when the FAQ was added, and showed no later change when read on 11 October 2026.
The legal mechanism
The Procurement Act 2023: a condition of participation
The Procurement Act 2023 applies to procurements commenced on or after 24 February 2025, and PPN 006 was rewritten in its terms.
A plan is a condition of participation under section 22, which allows conditions a supplier must satisfy to be awarded the contract, where they are a proportionate means of ensuring legal and financial capacity or technical ability.
PPN 006 places the plan under technical ability, at ¶10, and section 22(7) lets the buyer exclude a supplier that does not satisfy the condition.
The Act’s own thresholds, £135,018 for a central government contract from 1 January 2026 under PPN 023, decide whether a procurement is covered at all; they are not the plan threshold.
Contract value is estimated under section 4 of the Act, and the Cabinet Office’s conditions of participation guidance explains how such conditions are assessed.
Social value is a separate measure applied at award: PPN 002 now, and PPN 026 for procurements commenced from 1 January 2027, which has no environmental outcome; see the social value model.
Myths
What a carbon reduction plan does not require
It does not require an audit or third-party verification of the footprint, under ¶18 of the Technical Standard.
It does not require the full Scope 3 inventory, and it does not require purchased goods and services.
It does not require a science-based target, and it does not score ambition.
It does not apply to companies that are not bidding, whatever their size.
“Companies are legally required to have a Carbon Reduction Plan” — PPN 006 binds buyers; it is a condition on specific bids.
“The threshold is £5m excluding VAT” — that was PPN 06/21.
“PPN 026 replaces PPN 006” — PPN 026 is the social value model and leaves carbon reduction plans alone.
“Crown Commercial Service runs the webinars” — it became the Government Commercial Agency on 1 April 2026.
Other regimes
How a plan fits the other UK carbon reporting requirements
SECR already requires quoted and large companies to report energy use and Scope 1 and 2 emissions in their directors’ report, and PPN 006 ¶18 notes the plan needs no change to that data; see SECR reporting requirements.
The plan’s five-category Scope 3 subset is far narrower than UK SRS S2, which asks for Scope 3 across all relevant categories, on a comply-or-explain basis for listed companies for periods beginning on or after 1 January 2027, with a one-year Scope 3 relief; see UK SRS S2 reporting requirements.
The GHG accounting choices a plan makes — boundary, factors, gases — are the same ones explained on GHG reporting requirements and carbon reporting requirements.
Energy audits under ESOS are a separate legal duty with their own deadlines; see ESOS reporting requirements.
Check yourself
Six statements about carbon reduction plans
Each answer names the paragraph it turns on.
The VAT and 12-month items catch the most bids out.
The accounting behind the numbers is set out on the GHG Protocol page.
Carbon reduction plans: true or false?
Every UK company with more than 250 employees must publish a Carbon Reduction Plan.
The PPN 006 threshold includes VAT.
A plan must report all fifteen Scope 3 categories.
A plan published 18 months ago can support a bid today.
A plan does not need a handwritten signature.
Buyers score a 2030 net zero date above a 2050 one.
0 of 6 answered.
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Frequently asked
Carbon reduction plan reporting requirements, answered
What are the carbon reduction plan reporting requirements in the UK?
Where a central government buyer applies PPN 006, a bidder must provide a Carbon Reduction Plan on the template: a commitment to net zero by 2050 at the latest, baseline and current emissions for Scope 1, Scope 2 and five Scope 3 categories, reduction targets, carbon reduction projects, and a declaration signed off by a director after board approval.
It must be published on the supplier’s UK website with a prominent homepage link.
Is a carbon reduction plan a legal requirement for UK companies?
No general legal duty requires one.
PPN 006 is procurement policy that tells central government departments, executive agencies and non-departmental public bodies to make a plan a condition of participation on contracts above £5 million a year including VAT.
A supplier needs one only to bid for such a contract.
Which contracts need a carbon reduction plan?
Contracts for goods, services or works (other than special regime contracts) awarded under the Procurement Act 2023 by central government departments, their executive agencies and non-departmental public bodies, with an estimated value above £5 million a year including VAT averaged over the life of the contract, where the plan is relevant and proportionate.
Framework and dynamic market call-offs count where the individual contract exceeds the same figure.
Is the £5 million threshold per year or in total?
Per year, averaged over the contract’s life.
PPN 006 footnote 5 gives the example of a four-year contract worth £21 million in total, which is in scope even if the first year is under £5 million.
Is the £5 million figure including or excluding VAT?
Including VAT under PPN 006.
PPN 06/21, its predecessor, used £5 million per annum and above excluding VAT, so the two notices are not on the same basis.
Which Scope 3 categories must a carbon reduction plan report?
Five of the fifteen GHG Protocol categories: 4 upstream transportation and distribution, 5 waste generated in operations, 6 business travel, 7 employee commuting and 9 downstream transportation and distribution.
Purchased goods and services, capital goods and the other categories are not required.
Which greenhouse gases does a carbon reduction plan cover?
The Technical Standard names the seven Kyoto gases: carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulphur hexafluoride and nitrogen trifluoride, reported in tonnes of CO2e using UK government conversion factors.
The PPN’s own text says six in one paragraph and lists seven in its footnote, so report seven.
Does the net zero date have to be 2050?
2050 at the latest.
A supplier may commit to an earlier date, but plans are not scored, so an earlier date gives no advantage; FAQ Q18 also tells buyers not to require a date earlier than 2050.
Who must sign a carbon reduction plan?
The plan should state that the board of directors (or equivalent management body) approved it and the date, and it must be signed off by a director (or equivalent), or by a designated member for an LLP, with name, job title and date.
No physical signature is needed, but the plan should say clearly that it has been signed.
Where must a carbon reduction plan be published?
On the supplier’s UK website, with a link in a prominent place on the homepage.
A supplier with no website must provide a written copy to anyone who asks within 30 days.
Keeping previous plans online is described as good practice.
How often must a carbon reduction plan be updated?
At least annually: the Technical Standard asks for review and update within six months of the financial year end.
For a bid, the plan must have been published since the tender notice or in the preceding 12 months.
Does a carbon reduction plan need to be audited?
No. The Technical Standard says the footprint should be conducted to a reasonable level of assurance and names ISO 14064-3 and ISAE 3410 as widely used verification standards, but states there is no requirement to have the footprint audited.
Can a subsidiary use its parent company’s carbon reduction plan?
Only temporarily, and only if the bidder is wholly owned by the parent, the parent’s plan states that its 2050 commitment applies to the bidder, the environmental measures are stated to be able to be applied by the bidder on the contract, and the plan is published on the bidder’s website.
Do subcontractors need a carbon reduction plan?
No, unless they bid in their own right.
The plan is required from the organisation the buyer will contract with; in a consortium bid, each consortium member completes one, according to FAQ Q19.
Will my plan fail if our emissions went up?
No. FAQ Q21 says emissions data is not a basis for assessment and an increase against the baseline or a previous year does not mean the plan fails the condition of participation.
Does PPN 006 apply to NHS contracts?
Not directly: PPN 006’s buyers are central government departments, executive agencies and non-departmental public bodies.
NHS England applies its own carbon reduction plan requirement, which accepts a plan built to PPN 006.
What is the difference between PPN 006 and PPN 06/21?
PPN 006 is the February 2025 version for procurements under the Procurement Act 2023 commenced from 24 February 2025; the plan is a condition of participation and the threshold includes VAT.
PPN 06/21, from June 2021, still governs earlier procurements under the Public Contracts Regulations 2015, with a selection criterion and a threshold excluding VAT.
Does PPN 026 change carbon reduction plans?
No. PPN 026 replaces the social value model for procurements commenced from 1 January 2027 and contains no environmental outcome.
It does not amend PPN 006, which is a separate condition of participation.
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 Office (GOV.UK)PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts
Published 17 February 2025; last updated 10 July 2025.
- Cabinet Office (GOV.UK)PPN 006 — the notice (HTML)
¶¶2–4 scope, ¶¶6–9 dates, ¶¶10–11 the condition, §7 the template.
- Cabinet Office (GOV.UK)PPN 006 Technical Standard for Completion of Carbon Reduction Plans
¶8 2050; ¶11 review; ¶¶12–13, 23 publication; ¶15 five categories; ¶18 assurance; ¶¶24–25 sign-off.
- Cabinet Office (GOV.UK)PPN 006: frequently asked questions
Issued June 2025: not scored; 12-month rule; subcontractors; overseas suppliers.
- Cabinet OfficePPN 006 guidance: adopting and applying conditions of participation (PDF)
How buyers apply and check the condition.
- Cabinet OfficeCarbon Reduction Plan template (ODT)
Added to the PPN page on 17 April 2025.
- Cabinet Office (GOV.UK)PPN 06/21 — the predecessor
Published 5 June 2021; still governs procurements commenced before 24 February 2025.
- Cabinet Office (GOV.UK)PPN 06/21 frequently asked questions
£5m per annum excluding VAT, from 30 September 2021.
- legislation.gov.ukProcurement Act 2023
Applies to procurements commenced on or after 24 February 2025.
- legislation.gov.ukProcurement Act 2023, section 22 — conditions of participation
The mechanism a plan sits inside.
- legislation.gov.ukProcurement Act 2023, section 4 — valuation of contracts
How estimated contract value is worked out.
- Cabinet Office (GOV.UK)Procurement Act 2023 guidance: conditions of participation
How conditions of participation work.
- Cabinet Office (GOV.UK)PPN 023: 2026 threshold amounts
The Act’s own thresholds — not PPN 006’s.
- Cabinet Office (GOV.UK)PPN 002: Taking account of social value in the award of contracts
Award stage; a separate measure.
- Cabinet Office (GOV.UK)PPN 026: The Social Value Model (HTML)
Published 5 August 2026; procurements commenced from 1 January 2027.
- NHS EnglandCarbon reduction plan and net zero commitment requirements for NHS procurement
A separate NHS instrument (v3, 11 December 2025) that accepts a PPN 006 plan.
- Government Commercial AgencyAbout GCA
Crown Commercial Service became the Government Commercial Agency on 1 April 2026.
- GHG ProtocolCorporate Accounting and Reporting Standard
The standard a plan’s footprint follows.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The fifteen categories the five are drawn from.
- DESNZ (GOV.UK)Government conversion factors for company reporting
The factors the template requires.
- DESNZ / Defra (GOV.UK)Environmental reporting guidelines, including SECR
The basis for Scope 1 and 2 in a plan.
- legislation.gov.ukClimate Change Act 2008, section 1
The 2050 net zero target a plan commits to.
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