If your business sells to the NHS, the rules on reporting your carbon emissions are about to change. From 1 April 2027, bigger NHS contracts will require suppliers to measure and publish much more of their carbon footprint than before.
This guide explains what is changing, who it affects and what you need to do, without the jargon.
The short version
• From 1 April 2027, NHS buyers will ask suppliers for a published carbon reduction plan (often shortened to CRP).
• There are two levels. Contracts worth £5 million a year or more need the new, more detailed version. Smaller contracts need a simpler version.
• The detailed version means measuring emissions from your whole supply chain, not just your own sites, and covering your business worldwide, not only in the UK.
• It is a pass or fail check. If your plan doesn't meet the minimum standard, you can't move on to the next stage of the tender.
What is a carbon reduction plan?
A carbon reduction plan is a public document. It shows how much carbon your business produces today, and how you plan to reach net zero by 2050 or sooner. Net zero means cutting your emissions as far as you can and balancing out only what is left.
Emissions are split into three groups, called scopes:
• Scope 1: emissions from things you own or run directly, such as company vehicles and gas heating.
• Scope 2: emissions from the energy you buy, such as electricity.
• Scope 3: everything else linked to your business, such as the goods you buy, deliveries, business travel, staff commuting, waste and how customers use your products. For most companies, this is the biggest and hardest part to measure.
What is changing?
The NHS already asks suppliers for a carbon reduction plan. The new rules, which replace the old ones for any procurement starting on or after 1 April 2027, go further. Contracts that started being procured before that date follow the old rules.
For bigger contracts, the main changes are:
• All of your relevant Scope 3 emissions must be included. At the moment, suppliers only need to report five Scope 3 areas (aligning to PPN 006)
• Your plan must cover your business worldwide. Until now, covering the UK was enough.
• Your net zero promise must cover the whole organisation, not just the UK part.
Some things stay the same. Plans are still pass or fail, with no points for having a better plan than a rival. NHS tenders also still need to give at least 10% of the marks to net zero and social value.
The two levels, and which one applies to you:
Detailed plan (2027 NHS CRP)
Who needs it: Contracts worth £5 million a year or more (including VAT), plus all new supplier frameworks and similar lists, whatever their value.
Net zero promise: By 2050 or earlier, for the whole organisation.
Area covered: Global geographical boundary.
Emissions to report: Scope 1, Scope 2 and all relevant Scope 3.
Simpler plan (2024 CRP)
Who needs it: Smaller contracts, under £5 million a year, that are above the usual public procurement thresholds.
Net zero promise: By 2050 or earlier, for UK operations as a minimum.
Area covered: UK as a minimum (global is also accepted).
Emissions to report: Scope 1, Scope 2 and five Scope 3 areas.
The five Scope 3 areas needed for the simpler plan are:
Category 4: Upstream transportation and distribution (getting goods and materials to your business
Category 5: Waste generated in operations (waste your business produces)
Category 6: Business travel (staff travelling for work in vehicles you don’t own or run)
Category 7: Employee commuting (staff travelling to and from work)
Category 9: Downstream transportation and distribution (getting your products to customers).
Three things worth knowing:
Approved supplier lists. Some NHS buyers set up a list of approved suppliers, and other NHS organisations then buy from it. These lists are called frameworks or dynamic markets. To get onto a new list, you will normally need the detailed plan, even if the list is worth less than £5 million. The NHS body running the list can choose the simpler plan instead if it thinks the detailed one would put suppliers off. You are checked once, when you apply to join. You are not checked again each time you win work from the list.
Healthcare services. Services such as community or hospital care are bought under their own set of rules, called the Provider Selection Regime. These rules don't set spending limits. So NHS buyers use the standard public procurement thresholds as a guide to which contracts need a plan, and decide what is reasonable for each one.
Direct awards. Sometimes the NHS gives a contract to a supplier without running a competition. In these cases, your plan may be a pass or fail check, or it may just be requested for information. It depends on how the contract is being awarded.
What must the detailed plan include?
Promise net zero by 2050 or earlier for your whole organisation. At the very least, this must cover the part of the business supplying the NHS.
Show your emissions for a baseline year and a recent year, covering Scope 1, Scope 2 and all Scope 3 areas that are relevant to you. The standard method for this is the Greenhouse Gas Protocol, which lists 15 Scope 3 areas to consider.
Be measured in CO2e, a standard unit that combines all the main greenhouse gases into one number.
Cover your business global boundary, for both your net zero promise and your emissions figures.
Explain what you are doing to cut emissions, including any certifications or actions you can apply while delivering the NHS contract.
Be signed off by your Board, or by a Company Director if you don't have a Board.
Be published on your website, where it is easy to find.
If you think a Scope 3 area doesn't apply to your business, you need to say so and explain why. You don't need perfect data. Estimates are allowed, including calculations based on how much you spend and standard carbon figures. If you need help on what calculation methodologies you should be using, use our Free Tool.
The NHS also says what it would like to see beyond the minimum: a net zero date of 2045 or earlier, a promise covering the whole parent company, and targets checked by an independent third party.
How will the NHS check your plan?
You should expect four standard questions, along the lines of:
Have you published a carbon reduction plan? (Please share the link.)
Are you publicly committed to net zero by 2050, and what is your target date?
What were your emissions in your baseline year, by scope?
What were your emissions in your latest reporting year, by scope?
If you don't meet the minimum standard, you can't go forward in the tender, apart from in a few special cases. Common reasons for failing are:
No plan submitted, or no net zero promise
Missing emissions figures with no explanation
Figures from more than 18 months before the tender was advertised, with no explanation
No description of the actions you will take, or no signed declaration.
For healthcare services bought under the Provider Selection Regime, contracts will also require you to update your plan every year. So it isn't a one-off job.
Who does this affect?
Directly: any business bidding for NHS work in goods, services or building and maintenance work, including medicines and healthcare services. This applies whether the NHS organisation is buying directly or through someone acting for it.
In other ways:
UK arms of international groups. Either the UK company or its parent can publish the plan, but it must cover the whole business worldwide, not just UK emissions.
Subcontractors. They don't need their own plan. But you are expected to work with them to cut emissions, and you will probably need their data for your own Scope 3 figures.
NHS organisations and other public bodies bidding for NHS work. NHS trusts and integrated care boards can use their published Green Plan. Other public bodies need a proper plan.
Small businesses and voluntary or community groups. There is some flexibility. If you have a good reason you can't get certain data, you can submit what you have, explain the gaps and say how you'll fix them. For NHS tenders in the 2027/28 financial year, businesses with gaps in their first-year Scope 3 data can still pass if they explain why and have a plan to report it from the following year.
This flexibility is a short-term help, not a way out. Businesses that start early will be in a much stronger position than those relying on explanations for missing data.
Why Scope 3 is the hard part
Most businesses can work out their Scope 1 and 2 emissions fairly easily, because the information is on their own energy and fuel bills. Scope 3 is harder. It covers your whole supply chain, and the data is spread across many suppliers, systems and spreadsheets.
The NHS accepts estimates, so you don't need perfect data on day one. But you do need a method that makes sense, is written down and can be explained. That means choosing the right way to calculate each Scope 3 area, being clear about what you've left out and why, and using the same approach each year. Getting this wrong could mean failing at the assessment stage.
How can Combatting Carbon help?
By April 2027, anyone bidding for larger NHS contracts needs a published, board-approved plan with a full Scope 3 baseline. If you haven't started, there is still time. But measuring, calculating, setting targets, writing the plan and getting sign-off all take a while, so it's not something to leave until a tender lands on your desk.
This is where we come in. At Combatting Carbon, we help organisations to:
Work out which Scope 3 areas matter to your business, and explain the reasons for any you leave out
Choose the right way to calculate each area, so your numbers stand up to questions
Pull together your baseline and latest emissions figures in the format NHS buyers ask for
Make sure your plan meets the 2027 NHS rules, including worldwide coverage, board sign-off and publishing it on your website
Plan your yearly updates, so your plan stays up to date for the life of your contracts
Not sure where to begin with Scope 3? Our free tool helps you find the right calculation method for each of your Scope 3 areas. It's a good first step before you start collecting data.
Want your NHS carbon reduction plan ready before 1 April 2027? Get in touch with our team for a no-obligation chat about where you stand.
Quick checklist
Check whether your NHS contracts are over or under £5 million a year, or are on a framework
Check that your emissions reporting covers your business worldwide
Start looking at all 15 Scope 3 areas to see which apply to you
Agree a net zero promise with your board
Write your plan using the government's template and technical guidance
Publish it on your website and put a yearly update in the diary
Source: NHS England, 2027 NHS carbon reduction plan requirements for the procurement of NHS goods, services and works. Requirements may change, so always check the latest guidance.