In short
- April 2027 is the only published date in this sequence. Everything else here is a recommended schedule, not a deadline.
- Supplier data for purchased goods and services sets the critical path, because it cannot be compressed by working harder.
- Get a complete rough number early, then improve the two or three categories that matter, rather than waiting for good data.
From April 2027, NHS suppliers must publicly report their targets and emissions and publish a Carbon Reduction Plan covering all of their relevant global Scope 1, 2 and 3 emissions. Every Scope 3 category deemed relevant must be reported in adherence with the GHG Protocol Corporate Value Chain (Scope 3) Standard, and every category deemed not relevant needs a reasoned explanation. The plan must be published on your own website and board approved, or director approved if you have no board. Working backwards from that date is the only sensible way to plan it, because one step in the sequence runs on other companies' calendars rather than yours. Getting emissions data out of your own suppliers takes months and cannot be accelerated by putting more effort in at your end.
What are you actually working towards?
Two deliverables and one number.
The deliverables are a published, board-approved Carbon Reduction Plan on your own website, and publicly reported targets and emissions, both at the wider 2027 specification. The number is your Evergreen maturity level, which comes out of an online self-assessment and places you on one of four levels, Level 1 at entry and Level 4 at the highest maturity.
Be clear about what that level is and is not, because it is the thing suppliers most often misread. NHS England states that the Evergreen assessment has not been designed to be included as a scored or evaluated requirement in procurement. It is largely voluntary, with the exception that it is mandatory for NHS Supply Chain Frameworks and NHS England Medicines tenders. So a higher level does not beat a competitor's lower one in a bid evaluation. What it buys you is readiness, and a relationship with a customer who can see you are moving. NHS England recommends completing it annually and the score is valid for twelve months. The requirement itself is set out in NHS Evergreen: what suppliers must provide from April 2027.
One more thing to settle before the sequence: whether it lands on you at all. The 2027 requirement attaches to NHS contracts at or above GBP 5 million a year including VAT, and to all new NHS frameworks irrespective of the framework's value, unless deemed not proportionate. Below that, and above the relevant published procurement threshold, the earlier 2024 requirements apply. The trigger is when the procurement commenced, not when the contract is signed: for in-scope procurements commenced before 1 April 2027 the previous requirements still apply. If you sell through a framework, assume you are in.
One thing to be clear about before reading the sequence below. April 2027 is the published date. The month by month milestones that follow are our recommended schedule based on how long each step takes in practice, not obligations. Check the NHS England guidance for anything that looks like a deadline.
What does the sequence look like, working backwards?
Read this table from the bottom up if you want to see the logic, and from the top down if you want to work.
| Window | What you do | Why it sits here |
|---|---|---|
| April 2027 | Published plan live, targets and emissions publicly reported | The published requirement |
| February to March 2027 | Board approves the plan and the public targets, then publish on your website | Board approval is required by the specification, and board dates cannot be compressed |
| December 2026 to January 2027 | Draft the plan, write the trajectory, run internal review | Needs a final number to write against |
| September to November 2026 | Replace spend estimates with primary supplier data in the largest categories | The long pole. Depends on other companies |
| July to August 2026 | Materiality assessment. Decide which Scope 3 categories are worth the effort | You cannot prioritise supplier engagement before you know what dominates |
| May to June 2026 | First complete global inventory, spend-based where necessary | A rough complete number beats a precise partial one |
| March to April 2026 | Define the global boundary. Entities, sites, activities, worldwide | Everything downstream inherits this. Getting it wrong means restating |
The shape is deliberate. The first half of the sequence is decisions, the second half is data collection, and the last third is other people's calendars. That is the opposite of the order most suppliers attempt, which is to start collecting data and decide the boundary once the data turns out to be confusing.
Why does supplier data set the critical path?
Because it is the only step whose duration is not a function of your own effort.
Scope 1 and Scope 2 come out of invoices you already hold. Business travel comes out of expenses. Waste comes from a contractor who bills you. All of those can be pulled forward by assigning more people. Primary data from your own suppliers cannot. You send a request, and then you wait on a company with no obligation to help you, who may not have calculated their own footprint, and who is receiving similar requests from their other customers.
Purchased goods and services is where this bites. PPN 006 asks for scope 1, scope 2 and a defined subset of five of the fifteen scope 3 categories: upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution. Purchased goods and services is not among them, and for a product supplier it is usually the largest category by a distance. So the category with the longest lead time is also the one you have never touched. Starting it in early 2027 means using spend-based estimates, which are defensible and quick but produce a less flattering figure and a weaker position than primary data would.
What should you actually do in each window?
Boundary first. Write down which legal entities, sites and activities are in scope worldwide, and why. This is a day of work and it is the input to everything else. A boundary changed later is a restatement in a published document.
Complete before precise. Build the first global inventory with whatever data exists, using spend-based factors where activity data is missing. The purpose of this pass is not accuracy. It is to find out which two or three categories decide your footprint, because effort spent anywhere else is wasted. If you have never built one, start from carbon accounting from scratch.
Then engage a short list of suppliers. Not all of them. The ones inside the categories that dominate. This is a relationship exercise rather than a procurement one, and it goes better if you ask for what you need rather than sending a generic questionnaire. The receiving end of that experience is described in value chain ESG questions, and it is worth reading before you write yours.
Set the trajectory late. Targets should follow the number, not precede it. A public commitment made before you know your Scope 3 profile is a commitment you may have to walk back, in public. If you want the trajectory to stand up rather than sound good, that is science-based target territory.
Book the board slot early. Board approval is not a courtesy here, it is part of the specification: the plan must be board approved, or director approved if there is no board. Put the item in the calendar in 2026 for a 2027 meeting, because the alternative is discovering in March that the next board date is in May.
What if you are starting late?
You are not out of the running, but you have to give something up, and it should be precision rather than completeness.
Run the boundary and the complete spend-based inventory back to back, accept that purchased goods and services will be an estimate for the first cycle, and say so openly in the plan. A documented, honest estimate with a stated plan to improve it reads better than a gap. Then treat the following year as the improvement cycle. The Evergreen score is valid for twelve months and NHS England recommends reassessing annually, so there is a built-in second attempt.
What you should not do is delay the whole exercise waiting for supplier responses that may not arrive. A complete rough number that improves is a stronger position than a precise partial one that stalls.
What tends to go wrong in this sequence?
The boundary widens quietly. An overseas entity gets added halfway through and the earlier work has to be redone.
Materiality is skipped. Without it, teams spend three months on a category worth two percent of the footprint and run out of time on the one worth sixty.
The method changes between years. Evergreen recurs and improvement only reads as improvement if the basis stayed the same. Improving a Scope 3 method and calling the resulting drop a reduction is the most common self-inflicted wound in this whole exercise.
The plan and the assessment are treated as one task. They are not. The plan is a published document. The assessment is a self-assessment covering more than carbon.
Where does Hedgehog fit?
The platform is built for exactly the repeat cycle this roadmap describes: GHG Protocol setup with an AI guide, human GHG experts reachable in the product, entity management across locations and sites with roles for data owners, auditors and managers, and over 20,000 spend-based and activity-based factors, with your own organisation-specific or supplier-specific data alongside them. That last combination is what makes the spend-to-primary transition in the middle of the sequence practical rather than a rebuild. The platform page reports 5,000+ users, and a free account needs no sales call.
Two limits, stated because you should plan around them. A small business reviewer on G2 in August 2026 said forecasting is missing and that Hedgehog has told them it is on the development list, so the trajectory modelling in your plan is currently your own work. A mid-market reviewer in June 2026 asked for more integrations with other software, which matters if you were hoping to pull supplier data in automatically rather than by hand.
The judgement-heavy parts, the global boundary, the materiality assessment and the supplier engagement design, are Scope 3 consulting and carbon footprint consulting work. If you want to know where you realistically land by April 2027, book a call and we will map it against your year end.
Sources: NHS England's 2027 carbon reduction plan requirements (last updated 21 July 2026), the Evergreen sustainable supplier assessment, the NHS Net Zero Supplier Roadmap, PPN 006 and its technical standard, and the GHG Protocol Corporate Value Chain (Scope 3) Standard. NHS and PPN 006 facts verified 15 September 2026; Hedgehog platform, Hedgehog on G2. Verified 27 August 2026.
Facts on this page were last verified on 2026-09-15.
