If your business bids for central government contracts worth £5 million or more per year, PPN 006 is no longer something you can leave until the tender deadline. It requires a published Carbon Reduction Plan (CRP) as a condition of bidding — and increasingly, the requirement cascades down supply chains to subcontractors who aren't named in the PPN directly.
Here's what PPN 006 actually requires, and a practical, step-by-step approach to getting compliant.
What is PPN 006?
PPN 006 (formerly PPN 06/21) is a UK government Procurement Policy Note that requires suppliers bidding for in-scope central government contracts to publish a Carbon Reduction Plan confirming their commitment to Net Zero by 2050, alongside baseline emissions data. It applies to contracts with an estimated value above £5 million per year (including VAT) awarded by central government departments, their executive agencies, and non-departmental public bodies — though many wider public bodies, NHS trusts, and Tier One contractors apply the same standard down their own supply chains.
In short: if you want to win — or keep — government business at this scale, a credible Carbon Reduction Plan isn't optional.
What a Compliant Carbon Reduction Plan Must Include
Under PPN 006, your CRP needs to:
Confirm a Net Zero by 2050 commitment, in line with the UK's legally binding target
Report Scope 1 and Scope 2 emissions, calculated in line with SECR (Streamlined Energy and Carbon Reporting) methodology
Cover a defined subset of Scope 3 categories — typically business travel, employee commuting, upstream transportation and distribution, downstream transportation and distribution, and waste generated in operations (check the current PPN annex, as the required categories can be refined over time)
Describe the environmental management measures already in place to reduce emissions
Be signed off at board level (or an equivalent level of seniority)
Be publicly available on your company website — a CRP that only exists in a bid document doesn't meet the requirement
This isn't a document you can draft from memory. Every figure in it needs to be traceable back to real data.
Step 1: Confirm Whether You're In Scope
Before building anything, check whether PPN 006 actually applies to you. It's triggered by contract value (currently £5 million per year including VAT), not company size — so an SME bidding for a large enough government contract is just as in scope as a large supplier. If you're a subcontractor to a prime contractor on a qualifying contract, ask directly whether the requirement is being cascaded to you, since many primes now require it regardless of your direct contract value.
Step 2: Establish Your Baseline Year and Boundary
Pick a baseline year — usually your most recently completed financial or reporting year with reliable data — and define your organisational boundary (which entities, sites, and operations the figures cover). This baseline is what future years will be measured against, so get the boundary right the first time rather than having to restate it later.
Step 3: Calculate Scope 1 and Scope 2 Emissions
This is generally the most straightforward part. Scope 1 covers direct emissions from owned or controlled sources (fleet fuel, gas heating, on-site combustion). Scope 2 covers purchased electricity, heat, and steam. Both need to be calculated using a SECR-aligned methodology, using current, sourced emission factors — not estimates pulled from a generic online calculator.
Step 4: Calculate the Required Scope 3 Categories
This is where most delays happen. You don't need all 15 GHG Protocol Scope 3 categories for PPN 006 — just the defined subset (commonly business travel, employee commuting, upstream and downstream transportation, and operational waste). Start by identifying what data you already hold: expense records for business travel, fuel and mileage claims for commuting, waste contractor data, and transport/logistics records. Where primary data isn't available, a well-matched sector-average estimate is an acceptable and expected starting point — PPN 006 doesn't demand perfection, but it does expect a credible, documented methodology.
Step 5: Document Your Environmental Management Measures
Alongside the numbers, your CRP needs to describe what you're actually doing to reduce emissions — energy efficiency measures, fleet electrification plans, supplier engagement, waste reduction initiatives, and so on. This section is where you demonstrate that Net Zero is a plan with actions attached, not a statement of intent.
Step 6: Get Board-Level Sign-Off
A CRP without a named, senior sign-off doesn't meet the requirement. Build this into your timeline early — getting a board member or equivalent to review and approve the figures and commitments shouldn't be a last-minute scramble before a tender deadline.
Step 7: Publish It
The completed CRP needs to be publicly available on your company website, not just submitted as part of a bid. This also means it needs to be kept accurate — a stale CRP with figures from three years ago is a compliance gap waiting to be found by a diligent evaluator.
Step 8: Review and Update Annually
PPN 006 compliance isn't a one-off task. Your CRP should be reviewed at least annually, and updated whenever your organisational footprint, ownership structure, or reduction measures change materially. Building this into your annual reporting calendar — rather than producing a plan reactively for each new bid — saves considerable time and avoids the risk of an outdated plan undermining a live tender.
For a practical checklist, see how to update your Carbon Reduction Plan for 2027 below.
How to Update Your Carbon Reduction Plan for 2027 Under PPN 006
If you published your Carbon Reduction Plan (CRP) in 2026, it will need updating in 2027 to stay compliant with PPN 006. The PPN 006 technical standard says your CRP should be reviewed and updated annually, within six months of your organisation's financial year-end. The easiest way to plan your update is to work backwards from that date.
When Is Your 2027 CRP Update Due?
Your deadline is set by your financial year-end, not by the date you first published your plan. For example:
• Financial year ending 31 December 2026: updated CRP due by 30 June 2027
• Financial year ending 31 March 2027: updated CRP due by 30 September 2027
• Financial year ending 30 June 2027: updated CRP due by 31 December 2027
Put your date in the diary now. Don't wait for the next tender to prompt you: a Carbon Reduction Plan with an out-of-date reporting period is a compliance gap, and it can count against you when you bid.
Your 2027 Carbon Reduction Plan Update Checklist
1. Collect your emissions data throughout the year. Fuel, energy bills, business travel, employee commuting, waste, and upstream and downstream transport records are much easier to gather as you go than to reconstruct after year-end. Together they cover your Scope 1 and 2 emissions and the five Scope 3 categories PPN 006 requires. If your Scope 3 figures relied heavily on estimates last time, this is a good moment to improve your Scope 3 accuracy.
2. Keep your methodology consistent. Use the same organisational boundary and approach as your baseline, use the same reporting period throughout the plan, and record any changes. That keeps your year-on-year figures comparable and means you can explain them if a buyer asks. Our guide to the GHG Protocol explains the standard behind this.
3. Use the latest UK Government conversion factors. Recalculate with the current UK Government GHG conversion factors rather than reusing last year's. If you use carbon accounting software, check it is applying the latest factors before you run your update.
4. Review your carbon reduction measures. Move completed actions out of "planned", add new ones, and make sure the plan shows real progress towards Net Zero by 2050. Need help describing them? Our free Tender Response Template Pack includes a Reduction Measures Pack you can adapt.
5. Check for organisational changes. Acquisitions, new sites, or changes to your fleet or ownership may mean your boundary or baseline needs revisiting. PPN 006 expects your CRP to reflect changes in organisational structure, so document what changed and why.
6. Plan board approval and director sign-off early. Your updated CRP needs a statement that it has been approved by the board, with the date, and must be signed off by a director (or equivalent) with their name, job title and the date. These are easy to leave until last, so build them into your timeline.
7. Publish your updated CRP on your website. The new version should be live on your UK website and linked from a prominent place on your homepage, not just attached to a bid. Keep previous versions available too, so buyers can see your progress over time.
Get these basics in place early and updating your Carbon Reduction Plan becomes a routine annual task rather than a rebuild against a bid deadline.
PPN 006 Carbon Reduction Plan Updates: FAQs
How often do I need to update my Carbon Reduction Plan under PPN 006?
At least once a year. The PPN 006 technical standard says your CRP should be reviewed and updated within six months of your financial year-end, and it should reflect any changes to your organisational structure.
Should I remove my old Carbon Reduction Plan when I publish the new one?
No. Publish your latest CRP on your website and link to it from your homepage, but keep earlier versions available. They show buyers how your emissions and reduction measures have progressed.
Do I need to change my baseline year when I update my CRP?
Usually not. Your baseline is the benchmark you measure progress against, so keeping it stable makes your figures comparable. If a significant structural change, such as an acquisition or divestment, would distort the comparison, the GHG Protocol recommends recalculating your baseline and explaining why.
Which emission factors should I use for my 2027 update?
The latest UK Government GHG conversion factors for company reporting, which are updated every year. Using last year's factors is one of the most common reasons figures don't hold up to scrutiny.
Need Help With Your 2027 Update?
Combatting Carbon helps SMEs keep their PPN 006 Carbon Reduction Plans up to date with accurate, auditable data, so your annual update is quick and your numbers hold up when a contracting authority asks how you got them. Book a demo to see how it works.