2027 NHS Carbon Reduction Plan Requirements: What Changes for Suppliers on 1 April 2027

NHS England has published its guidance for the next step of the NHS Net Zero Supplier Roadmap: “2027 NHS carbon reduction plan requirements for the procurement of NHS goods, services and works” (publication reference PRN02316_ii, published 9 June 2026, last updated 21 July 2026). It changes what NHS suppliers must publish, and it affects small suppliers as well as large ones. This guide sets out what changes, what stays the same, and what to do before your next NHS tender. It is checked against the NHS England guidance itself, not a summary of it.

What changes on 1 April 2027

Three things change for procurements that start on or after 1 April 2027. First, the Net Zero Commitment, the short statement that smaller contracts could accept until now, disappears: the guidance says no new procurements will be in scope of the NZC requirements. Second, every in-scope procurement now asks for a Carbon Reduction Plan, in one of two tiers. Third, the higher tier asks for much more: all relevant Scope 3 emissions, not five categories, and a global boundary, not just UK operations.

Procurements that started before 1 April 2027 keep following the current rules, which have applied since April 2024: a CRP for contracts of £5 million a year or more, and a CRP or Net Zero Commitment below that. The new requirements apply under both the Procurement Act 2023 and the Provider Selection Regime for healthcare services, and to all NHS organisations that buy goods, services or works, including pharmaceuticals and healthcare services.

The two tiers at a glance

If a framework owner decides the 2027 NHS CRP is not proportionate for a particular framework or dynamic market, it can apply the 2024 CRP instead, for example in markets with many small suppliers. The requirement is set at framework level, not for each call-off.

The big change: all relevant Scope 3 emissions

Under the current rules, and under PPN 006, a plan reports five Scope 3 categories that a supplier can measure from its own records. The 2027 NHS CRP asks for all Scope 3 categories that are relevant to your business, following the GHG Protocol Corporate Value Chain (Scope 3) Standard. For most suppliers that brings in the biggest categories of all: purchased goods and services (what you buy), capital goods, and often the use of the products you sell. For any category you decide is not relevant, you must explain why, in line with the standard.

This does not mean collecting data from every supplier on day one. The guidance says estimation methods can be used, for example spend-based methods using carbon conversion factors, and it recognises that suppliers may not have full supply-chain data. For tenders in the NHS financial year 2027/28, a supplier with gaps in its first-year Scope 3 data can still pass if it gives an acceptable explanation and a plan to report those emissions from the following year. For a plain-English list of the fifteen categories, see Scope 3 emissions explained.

A global boundary, not just the UK

A 2027 NHS CRP must use a global boundary for both the net zero commitment and the emissions. That does not mean a UK company must report on its whole international group. You can report for the company that bids to the NHS, but its figures must include all emissions linked to its activity, wherever they happen, such as goods bought from overseas or freight. Alternatively, a parent company can report on behalf of a wholly owned subsidiary, if its plan covers the subsidiary, the measures can be applied by the subsidiary, and the plan is published on the subsidiary’s website.

How the plan is assessed

Plans are assessed pass or fail; they are not scored or compared with other bidders. A plan that does not meet the minimum requirements cannot go through to the next stage, except in the exceptional circumstances the guidance lists. Common reasons for a fail: no plan submitted, no net zero commitment, missing scopes with no explanation, no environmental measures you can apply on the contract, and no signed declaration. A reporting period that ends more than 18 months before the tender notice is also a fail, unless you explain why. Where the requirement is part of the procurement, contracts should also require you to update the plan every year.

Beyond the minimum, NHS England lists what it encourages as best practice: net zero by 2045 or earlier, a plan covering the parent entity, targets validated by an independent third party, and disclosure of how much of the net zero target is expected to rely on offsetting. None of these is required, but they help prepare for future NHS procurements.

What it means for smaller suppliers

If your NHS contracts are below £5 million a year, the main change is that a Net Zero Commitment will no longer be enough for new procurements from April 2027: you will need a full 2024 CRP, with Scope 1, Scope 2 and the five Scope 3 categories. If you already have a current plan written to the PPN 006 template, the NHS will accept it. If you supply through a new NHS framework or dynamic market, check the tender documents: those are expected to ask for the 2027 NHS CRP, unless the owner decides it is not proportionate.

There is some help for small suppliers. An SME or VCSE with an acceptable reason for being unable to gather some emissions data can submit a plan with the data it has, an explanation, and the steps it will take to improve. Subcontractors are not in scope at all, although main suppliers are expected to work with them on emissions. NHS England’s Sustainable Supplier Accelerator runs free webinars, and the UK Business Climate Hub has guidance for small firms.

Two tiers, one date. If you sell £5 million a year or more to the NHS, or bid onto a new framework, your plan needs every relevant Scope 3 category. Below that, a Net Zero Commitment will no longer be enough.

What to do before your next NHS tender

Step 1: work out which tier your next NHS procurements will fall into: the value per year including VAT, and whether it is a new framework or dynamic market. Step 2: check your current plan. Is it signed, dated and easy to find on your website? Does its reporting period end within 18 months of the tender date? Does it use the seven Kyoto gases and the PPN 006 headings? Step 3: if you are in the 2027 tier, screen all fifteen Scope 3 categories. Estimate the relevant ones from spend data first, and write a short reason for each category you leave out. Step 4: set your net zero commitment for the whole organisation, with a global boundary. Step 5: have a director approve the plan, publish it in a clearly labelled place, and put a date in the calendar to update it every year.

For a quick first estimate of Scope 1 and 2, try the free business carbon footprint calculator; the free GHG inventory template includes a 15-category Scope 3 screening. To write the plan yourself, our Carbon Reduction Plan template follows the PPN 006 headings. For the current PPN 006 rules, read Carbon Reduction Plans under PPN 006. If you would rather hand it over, we prepare and update Carbon Reduction Plans for NHS suppliers, including the full Scope 3 screening the 2027 tier asks for.