How to Comply with PPN 006: A Step-by-Step Guide for UK Businesses

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 prime 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.

A Common Mistake to Avoid

The most frequent issue we see is businesses treating the CRP as a one-time bid document rather than a maintained, auditable record. A plan built in a rush, with unsourced estimates and no methodology behind them, can unravel quickly if a contracting authority asks a follow-up question or requests supporting evidence during due diligence. Getting the underlying data and documentation right the first time is far less costly than rebuilding it under deadline pressure later.

Combatting Carbon helps SMEs build PPN 006-compliant Carbon Reduction Plans backed by accurate, auditable data — so the numbers hold up when a contracting authority asks how you got them.