In short
- One Carbon Reduction Plan, valid for twelve months, covers every in-scope bid you make in that year.
- The deadline to run on is not the twelve months. It is six months after your financial year end, which is what the Technical Standard asks for.
- Board approval, not the calculation, is usually the step that decides whether you make the date, because the board's approval date has to appear on the plan.
A PPN 006 Carbon Reduction Plan is valid for twelve months, and one plan covers every in-scope bid you make in that period. At any particular tender, the buyer checks that the plan was signed off and published either since the tender notice or in the twelve months before it. Underneath that sits a tighter deadline most suppliers have never read: the Technical Standard asks you to review and update the plan within six months of your financial year end. Finish the refresh inside those six months every year, and never later in the year than the time before, and your plan is never more than twelve months old at a tender. Run on the twelve month rule and you will eventually meet a tender notice you cannot answer.
What is the twelve month clock actually counting?
The PPN 006 FAQ states the twelve months in two places, meaning two different things, and conflating them is how suppliers get caught.
The first is a property of the plan. The Cabinet Office FAQ says suppliers "will only require one CRP (valid for 12 months), which can be used for all procurements where the measure is applied". That is mostly good news: you do not write a plan per bid, you write one a year and it answers every in-scope procurement you enter.
The second is the test a buyer actually applies. In-scope organisations are told to satisfy themselves that the plan "has been signed off at an appropriate level and published since the publication of the tender notice, or in the preceding 12 month period". That window runs backwards from the tender notice, not forwards from your publication date, and it has two consequences.
Both events have to fall inside it. Sign-off and publication, not one or the other, so the binding date is the earlier of the two.
There is also no general state of being lapsed. The question is only ever asked against a particular tender notice, so a plan too old for a competition opening this week would have been fine for one that opened a month ago. Your plan does not expire on a date. It stops covering new notices.
The measure itself reaches central government departments, their executive agencies and non-departmental public bodies, on contracts above GBP 5 million per year including VAT. Including, not excluding, which much secondary material gets wrong and which moves the real trigger by about a fifth.
What is the deadline you should actually run on?
Six months after your financial year end. This is the sentence that changes how you plan, and it sits in the Technical Standard rather than the PPN, which is why most suppliers have never seen it: plans "should be reviewed and updated annually", and "to this end your Carbon Reduction Plan should be reviewed and updated within 6 months of your organisation's financial year-end".
That anchors the refresh to your reporting calendar instead of to whenever last year's document happened to go live. Finish the refresh inside those six months every year, and no later in the year than the time before, and your plan is always under twelve months old at a tender, so the buyer's check is always met. Follow the twelve month rule instead and you are managing a deadline that moves every year with the date you published.
In practice it is a four month routine. Months one and two after year end, close the activity data and pull the same sources in the same order as last time. Month three, recalculate on an unchanged boundary and compare against the baseline. Month four, draft, take it to the board, publish, and record the publication date somewhere that is not one person's inbox. That leaves two months of margin against the six month rule.
One honest note: the two rules can disagree. A plan published eleven months ago passes the buyer's check but can fall outside the Technical Standard's six month window. No published guidance reconciles them, and the twelve months is what a buyer is told to check. Running on six months makes the question academic.
How does a plan lapse without anyone noticing?
Lapsing is rarely a decision. It is a gap between two calendars.
The reporting calendar and the publication calendar drift apart. Your emissions cover a financial year. Your plan went live whenever the document was finished, perhaps four months after that year closed. The next one slips a little further, and the gap between publication dates quietly grows past twelve months while the reporting years still look tidy. The six month rule exists to stop exactly this.
Nobody owns the date. The plan was produced for a bid, by whoever was closest to the bid. Bids end. The obligation does not.
The refresh is treated as a document edit. A plan reports a baseline year and a current reporting year, and the template carries a publication date on its face. Changing the date on the cover and leaving last year's figures underneath produces an old plan with a new date on it.
Why is board approval the binding constraint?
Because it is the only step in the sequence that runs on someone else's schedule, and because its date has to appear on the document.
There are two requirements here and they are easy to merge. The plan "must be signed off by a director (or equivalent) or designated member (for LLPs)", with their name, job title and date. Separately, it "should clearly state that board of directors (or equivalent management body) approval has been given with the date of approval". A director's signature can be obtained in an afternoon. A board approval date cannot be manufactured, and it is the one that has to be printed.
Boards typically meet monthly or quarterly. If your window closes in the third week of a month and the board next sits in the fifth, no amount of effort in the finance team changes the outcome. Every other step in a refresh can be compressed by working harder; this one cannot. So work backwards from a board date rather than forwards from a year end, and put the refresh on the board agenda as a standing annual item before you need it.
What happens if a tender opens while your plan is stale?
You are late, and the only useful question is how late.
You cannot back-date a plan, and there is no provisional status to fall back on. What you can do is compress the recalculation, and how far you can compress it depends on which data you already hold rather than on how much analysis capacity you can throw at it.
| Element | Realistic lead time when you are behind | Why |
|---|---|---|
| Scope 1 and Scope 2 | Days | Meter reads, fuel and energy invoices sit in finance already |
| Business travel and commuting | Days to weeks | Expenses plus a survey, both internal |
| Waste generated in operations | Weeks | Waste transfer notes come from a contractor |
| Upstream and downstream transport and distribution | Weeks to months | Depends on carrier data you do not own |
| Board approval | Whenever the board next sits | Not compressible by effort |
| Publication | Same day | A web page and a document |
Those four emissions rows are not an arbitrary selection. They are the plan: all of scope 1 and scope 2, plus five of the fifteen GHG Protocol scope 3 categories. Purchased goods and services, usually the largest category in any inventory, is not among them, so a supplier fully compliant with PPN 006 may never have calculated it.
The pattern is consistent. The categories you can move fast on sit inside your own accounting system. The ones that make you miss a deadline sit with third parties, which is why an emergency refresh so often produces weaker scope 3 figures than the plan it replaces.
Will worse numbers cost you the bid?
No, and this is the most useful thing on this page for anyone in the middle of a rushed refresh.
Plans are not scored. The FAQ is explicit that they "should not be 'scored' or compared against each other and assessment takes the form of a check that they meet the requirements of the measure". It is a condition of participation under the Procurement Act 2023, the current term for what PPN 06/21 called a selection criterion, and the Cabinet Office says the substantive obligation is unchanged.
The emissions data itself is out of the assessment. It "is not to be used as a basis for assessment in the procurement process", and "an increase in emissions compared to the baseline year or a previous year does not mean that the CRP fails to meet the conditions of participation". Restating a baseline after an acquisition is suggested rather than penalised.
So what does the buyer check? Five things: that the plan is published on your website; that it was signed off and published inside the window above; that it carries a signed declaration committing you to net zero by 2050 at the latest; that it details your greenhouse gas emissions; and that it details the environmental management measures you will apply on the contract. That is the whole gate, it is binary, and a plan that is present and complete passes it whatever the numbers say.
What breaks a refresh even when the timing works?
Comparability. The plan compares a reporting year against a baseline year. Change the boundary, add an entity, or improve a scope 3 method between years and the comparison stops measuring reduction and starts measuring your own methodology. Not a compliance problem, per the section above, but a credibility problem with the humans reading it, and worth a line of explanation in the plan itself.
Factor updates and a lost method. The plan is calculated with the conversion factors published by the UK Government, and those change, so a published figure can move on its own. Test that deliberately rather than discovering it in year three. And the refresh only stays cheap if next year's calculation repeats this year's: a method that exists only as a spreadsheet built under bid pressure costs full price every time.
One thing that does not break it: assurance. The Technical Standard asks that the footprint adhere to the GHG Protocol Corporate Accounting and Reporting Standard, and says in the same paragraph that "there is no requirement to have your carbon footprint audited".
Where does a tool help, and where does it not?
The Hedgehog platform names PPN 006 as a reporting output alongside the GHG Protocol and the CO2-Prestatieladder, and it exists to make the second and third year cheaper than the first: an AI guide through GHG Protocol setup, inventory building and reporting, human GHG experts reachable in the product, entity management with roles for data owners and auditors, and over 20,000 spend-based and activity-based factors with your own supplier-specific data alongside them. The platform page reports 5,000+ users, and a free account needs no sales call.
One limit before you plan a refresh around it. A mid-market reviewer on G2 in July 2026 said the applied conversion factors and distance calculations are not exposed in the interface, so you cannot always trace how an original input became a platform entry. For a document published on your own homepage, keep your own record of the sources behind each category.
The boundary decisions, the trajectory and the reduction projects are not software questions at all. Those are carbon footprint consulting and Scope 3 work, worth getting right once because every future refresh inherits them. New to the requirement rather than to the refresh? Start with the PPN 006 checklist.
If you sell to the NHS, note that the floor moves. NHS Evergreen sits alongside a separate NHS carbon reduction plan requirement that commences on 1 April 2027 and asks for global emissions and every relevant scope 3 category, so a refresh cycle built only for the PPN subset will need rebuilding anyway. If a deadline is already tight, tell us the date and we will say plainly whether it is reachable.
Sources: the Cabinet Office's PPN 006 for the in-scope bodies, the threshold and the 24 February 2025 date; its Technical Standard for the six month window, the scope 3 subset, sign-off, the UK boundary and the absence of an audit requirement; and its frequently asked questions for the twelve month validity, the tender notice test, the five checks and the treatment of rising emissions. All read on 17 September 2026. NHS England's 2027 carbon reduction plan requirement read on 15 September 2026. Hedgehog platform and Hedgehog on G2, read on 27 August 2026. Verified 17 September 2026.
Facts on this page were last verified on 2026-09-17.
