In short
- The trigger is the contract, not the company. Above GBP 5 million a year including VAT with an in-scope central government buyer, expect to need a published plan.
- The NHS runs its own requirement, and it reaches contracts below GBP 5 million. Do not read the central government threshold across to it.
- A director signs the plan. The board's approval and its date have to be stated on it, which is the part that takes a calendar.
The Carbon Reduction Plan requirement is triggered by the contract you are bidding for, not by how large your company is. If you are the bidding entity for an in-scope UK central government contract worth more than GBP 5 million a year including VAT, expect to need a compliant plan published before you bid. The NHS runs its own version of the requirement with a different reach, and that is the distinction suppliers get wrong most often. Turnover, headcount and sector make no difference to either. A thirty person specialist and a multinational face an identical gate on the same tender.
Which contracts trigger the central government requirement?
Three things have to be true, and it is worth checking them separately because suppliers usually get one right and assume the rest.
The buyer. PPN 006 applies to central government departments, their executive agencies and non-departmental public bodies. That is a narrower field than "the public sector" in ordinary speech. Local authorities, universities and the devolved administrations are not in-scope organisations under this PPN, although many adopt equivalent wording of their own accord.
The value. Above GBP 5 million per year including VAT. Two things about that figure. It is an annual value, so a four year contract at GBP 2 million a year is below the line even though the whole thing is worth GBP 8 million. And it is including VAT, where a great deal of secondary material says excluding, which puts the real trigger about a fifth too high.
Your role. The obligation attaches to the bidding entity. It is the organisation putting its name on the tender that needs the published plan.
One qualification that matters and is usually left out: being above the threshold makes the requirement expected, not automatic. The PPN tells in-scope organisations to assess applicability case by case, and says provision of a plan must be relevant and proportionate to the contract. So the tender documents remain the thing that decides, and the threshold tells you what to prepare for.
Does the size of your company change the answer?
No, and this is the single most common misreading.
There is no small business exemption and no turnover floor. The threshold is a property of the contract. The practical effect is that the requirement lands hardest on smaller suppliers, who are the ones least likely to have ever calculated a footprint and most likely to be bidding for their largest contract to date when they first meet it.
That asymmetry is worth planning around rather than resenting. A large supplier absorbing a first Carbon Reduction Plan has a finance function, an energy manager and probably an existing reporting obligation to lean on. A small one has whoever is writing the bid. The work is the same size. The team is not.
Is the NHS the same requirement?
No, and reading the central government rule across to NHS work is the mistake that costs suppliers a bid.
The NHS runs its own carbon reduction plan requirement. From 1 April 2027 suppliers must publicly report targets and emissions and publish a plan covering all of their relevant global scope 1, 2 and 3 emissions, which is wider than PPN 006 on both limbs: global rather than UK operations, and every scope 3 category deemed relevant under the GHG Protocol Corporate Value Chain (Scope 3) Standard, with a reasoned explanation aligned to the standard for each category deemed not relevant. That is not the same as all fifteen categories being required, and it is not the fixed subset of five that PPN 006 asks for either.
The reach is different too, in the direction that catches people out. Contracts at or above GBP 5 million per annum including VAT get the 2027 requirement. New contracts below GBP 5 million and above the relevant published procurement threshold get the earlier NHS requirements. And all new NHS frameworks get the 2027 requirements irrespective of the framework's value, unless deemed not proportionate. So an NHS supplier well under the central government threshold can still owe a published plan.
The trigger is when the procurement commenced, not when the contract is signed. For in-scope procurements that commenced before 1 April 2027 the previous requirements apply. The wider picture is in NHS Evergreen.
Who counts as the bidding entity in a group?
The requirement applies to the bidding entity. That settles the easy cases: if UK Subsidiary Limited signs the tender, UK Subsidiary Limited is the party the requirement is about.
Two harder cases are settled too. Consortium bids: a plan should be completed by each consortium member, not one for the consortium. Relying on a parent: a plan covering the bidding entity and its parent is permissible only where the full requirements are met, including that the bidding entity is wholly owned by the parent, that the parent's net zero commitment is stated to apply to the bidding entity, and that the plan is published on the bidding entity's own website. Even then it is framed as temporary, and bidding entities are told to get their own plan as soon as reasonably practical.
What the published requirement does not settle, at least not in the material we work from, is the rest: joint ventures, special purpose vehicles created for a single contract, and groups where the bidding entity has no operations of its own. Those are real and common structures, and we are not going to guess at them here. If your bid runs through any of them, put the question to the contracting authority in writing during the clarification window and keep the answer.
Where do people think they are caught and are not?
The table below is not legal advice and it does not replace reading the tender documents. It is the shape of the conversation we have most often.
| Your situation | Does a published plan apply to you | What to do |
|---|---|---|
| Bidding directly for a central government contract above GBP 5 million a year | Expect yes, subject to the buyer's own assessment | Publish a compliant plan before you bid |
| Bidding on a new NHS procurement above the threshold | Yes, under the NHS requirement, not PPN 006 | Build for the April 2027 specification, not the PPN one |
| Bidding on a new NHS procurement below GBP 5 million a year | Possibly yes, under the earlier NHS requirements | Do not assume the central government threshold protects you |
| Subcontracting to a supplier who holds such a contract | Not as the bidding entity | Your customer may still ask contractually. Read their terms, not the PPN |
| Bidding for a central government contract worth GBP 2 million a year | No | If the buyer asks anyway, that is a contract term, not this gate |
| Selling to a local authority or a devolved buyer | Not under PPN 006 | Many run equivalent requirements of their own. Ask which policy applies |
| Bidding for nothing public, but a private customer asks for a plan | No | That is a supply chain request. Different exercise, no prescribed format |
Two of those rows deserve a sentence each.
Subcontractors. There is no requirement for subcontractors to produce a plan under this policy, except where the subcontracted organisation is also bidding on a procurement in its own right. Your customer may well pass the expectation down, and increasingly does, but it will arrive as a contractual term you can read and negotiate rather than as a pass or fail gate. Requests of that kind are covered in value chain and ESG questions.
Private buyers. A customer asking for your emissions is not asking for a PPN 006 plan even when they use the phrase. Producing the prescribed document for them is usually more work than the question needs.
What do you have to publish if you are caught?
A short public document with prescribed contents: a stated commitment to net zero by 2050 at the latest for your UK operations, current emissions for the reporting year covering scope 1 and scope 2 in full plus a defined subset of scope 3, a baseline year on the same basis, reduction targets against that baseline, the carbon reduction projects implemented and planned, and confirmation that the GHG Protocol Corporate Standard was used, published on your website in an accessible location.
The scope 3 subset is upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution. Five of the fifteen categories. Purchased goods and services is not among them, which for most product suppliers is the largest category in the inventory, so a supplier fully compliant with PPN 006 may never have calculated the number that dominates its own footprint. The full detail sits in the PPN 006 checklist.
Who signs it is two requirements, not one. A director or equivalent must sign the plan, with their name, job title and the date; a physical signature is not needed but the plan must clearly state that it has been signed. Separately, the plan should state that board approval has been given, with the date of that approval. The director's signature can be arranged in a day. The board's approval date cannot, because boards sit on their own calendar, and it is the board date that has to appear on the document. That is the part to work backwards from.
Two things that are not required, and both save money. There is no requirement to have your carbon footprint audited. And plans are not scored or compared against each other; assessment takes the form of a check that the requirements are met. An increase in emissions against your baseline or a previous year does not mean the plan fails. If you restate a baseline or improve a scope 3 method and the comparison looks worse, that is not a procurement risk.
How long does a published plan last?
Two rules, and they are not the same test.
What the buyer checks is that sign-off and publication both fall since the publication of the tender notice or in the preceding twelve months. That window is measured backwards from each tender notice, so there is no general state of having lapsed. A plan too old for a tender opening today would have been fine for one that opened last month, and the binding date is the earlier of your sign-off and your publication.
What the Technical Standard tells you to do is tighter: review and update the plan within six months of your organisation's financial year-end. Run on that one and the twelve month test never binds, because you are always inside six months of a year-end. One plan, valid for twelve months, serves every in-scope procurement in that period. You do not write a plan per bid.
What should you do if you are still not sure?
Read the tender documents first. They tell you what this buyer is asking on this procurement, which is the question you actually need answered. Then check the annual value against the threshold rather than the headline contract value. Then confirm which legal entity is bidding. If any of those three leave you uncertain, ask the contracting authority during clarifications, in writing.
Then be honest about the timetable. If you turn out to be caught, the constraint is not the analysis. It is how long it takes to get carrier data, waste transfer notes and travel records into a shape you can calculate from, and then to get a board approval date on the document. If you have never done this, start from carbon accounting from scratch rather than from a template.
You can build a first inventory on the Hedgehog platform, which names PPN 006 as a reporting output, on a free account with no sales call. One honest caveat, from a Small Business reviewer on G2 in August 2026: loading the data takes a lot of manual effort, and it works well once it is in. That first load is the part to budget for, whichever tool you use. If you would rather have someone tell you plainly whether you are in scope and what it will take, book a call.
Sources: UK Cabinet Office Procurement Policy Note 006 and its Technical Standard for the Completion of Carbon Reduction Plans, including the published FAQs; NHS England's carbon reduction plan requirements for the procurement of NHS goods, services and works, current and from April 2027; the GHG Protocol Corporate Accounting and Reporting Standard; Hedgehog platform and Hedgehog on G2, both read on 27 August 2026. Page verified 17 September 2026.
Facts on this page were last verified on 2026-09-17.
