Yes, if your bid is for a UK central government contract worth more than £5 million a year including VAT, you need a Carbon Reduction Plan under PPN 006, formerly known as PPN 06/21. Three things matter most: a published plan on your UK website, director or board sign-off dated within the last 12 months, and emissions figures covering Scope 1, Scope 2 and a specific subset of Scope 3 categories.
TL;DR:
- Suppliers must update and sign off a comprehensive Carbon Reduction Plan every 12 months to ensure compliance for contracts exceeding £5 million annually.
- The plan must include Scope 1 and Scope 2 emissions, five specific Scope 3 categories, and a Net Zero target of 2050 or earlier, with supporting data from recent periods.
- Failure to cover all required emission categories or to meet the official template structure often results in plan rejection during assessment.
- Accurate emission figures depend on consistent methodology using UK government conversion factors and verified reporting periods within 18 months.
- Building a system to continuously collect, validate, and refresh emissions data is more effective than relying on a one-time plan for multiple tenders.
Table of Contents
- 2. Who has to comply and when it applies
- 3. What a compliant Carbon Reduction Plan must include
- 4. How assessors check compliance and why plans get rejected
- 5. Getting the numbers right: standards and conversion factors
- 6. Which guidance applies: PPN 06/21 or PPN 006
- 7. Building your submission checklist
- 8. Why treating the CRP as a checkbox is a mistake
- 9. How EnerlyticsAI supports your Carbon Reduction Plan
- 10. Official documents to download
- Sources
- FAQ
2. Who has to comply and when it applies
The threshold is precise: contracts estimated to exceed the relevant high-value threshold per year, including VAT, fall in scope of PPN 006. That figure applies to the annualized value of the contract, not necessarily the total contract sum, so a multiyear deal with an annual value above the relevant threshold could still trigger the requirement.
Frameworks and dynamic purchasing systems are treated the same way once an individual call-off exceeds the relevant value threshold. A supplier winning a place on a framework might not need a CRP at award stage, but a specific high-value call-off will require one. Some special regime contracts are excluded, and contracting authorities can decide the measure is not relevant or proportionate for a particular procurement in some cases, though this is the exception rather than the norm.
Overseas suppliers and businesses without UK-based operations are included in scope. They can still meet the requirement by committing to Net Zero and describing their environmental management measures, even without UK-specific emissions data.
Before assuming your bid is out of scope, check the tender documents for these signals:
- A stated annual contract value above £5 million including VAT.
- A reference to PPN 006 or PPN 06/21 in the selection questionnaire.
- A request for Annex A or a Carbon Reduction Plan as part of the qualification stage.
3. What a compliant Carbon Reduction Plan must include
A CRP that passes review follows the official template structure closely, since deviating from it is a common cause of technical failure. The plan should cover these elements in order:
- A Net Zero commitment, stating the target year of 2050 or earlier.
- Baseline and reporting year figures, showing emissions data for a defined 12-month period.
- Scope 1 and Scope 2 emissions, covering all direct and energy-related indirect sources.
- Five mandatory Scope 3 categories, described briefly with supporting data where available.
- Environmental management measures, outlining actions taken to reduce emissions.
- A signed declaration, with the signatory's name, title, and date at director or board level.
Publication happens on the supplier's own UK website. According to PPN 006 guidance, a business without a website can instead provide a written copy within 30 days of a request. Sign-off must be from the 12 months preceding the tender submission, and an electronic signature is acceptable as long as the name, title and date appear clearly on the declaration page.
Parent company CRPs can sometimes stand in for a subsidiary's own plan, but only when the parent's emissions figures genuinely reflect the bidding entity's operations and the relationship is explained clearly in the submission.
4. How assessors check compliance and why plans get rejected
Assessment is a pass/fail condition of participation, not a competitive scoring criterion. Procurement teams use Annex A conditions to check whether a CRP meets the prescribed requirements, and a technically compliant but modest plan passes just as well as an ambitious one. There is no ranking between suppliers on carbon performance at this stage.
Timing rules matter as much as content. The CRP should be published since the tender notice or within the preceding 12 months, and guidance points to an 18-month limit on how stale the reporting period can be before the plan is considered out of date.
The most common fail reasons include:
- Missing Scope 1, Scope 2, or required Scope 3 categories.
- No director or board-level sign-off, or a sign-off dated outside the 12-month window.
- A plan that ignores the official template structure entirely.
- An outdated reporting period that no longer reflects current operations.
- No description of environmental management measures.
Pro Tip: Before submission, run your CRP against the Annex A checklist line by line rather than relying on a general read-through, since assessors check each condition individually.
5. Getting the numbers right: standards and conversion factors
Emissions figures need a consistent, defensible methodology behind them. Scope 1 and Scope 2 should follow the GHG Protocol Corporate Accounting and Reporting Standard, and every activity figure should be converted using the UK Government's greenhouse gas conversion factors, reported in tonnes of CO2 equivalent covering the Kyoto Protocol gases.
The five mandatory Scope 3 categories are set out in PPN 006 guidance and cover the emissions sources most bidders can reasonably measure:
- Upstream transport and distribution.
- Downstream transport and distribution.
- Business travel.
- Employee commuting.
- Waste generated in operations.
For verification, assurance frameworks such as ISO 14064-3 or ISAE 3410 give a recognized structure for checking figures, and keeping reporting periods consistent year to year makes any progress claims easier to defend under scrutiny.
6. Which guidance applies: PPN 06/21 or PPN 006
The Procurement Act 2023 and the accompanying Procurement Regulations 2024 apply to procurements commenced on or after 24 February 2025. Procurements that started before that date continue to reference the older PPN 06/21 guidance, while anything commenced after it falls under PPN 006 and the new Act's terminology.
Tender documents usually state which regime applies, so check the selection questionnaire or contract notice rather than assuming based on the contract's start date. For frameworks, the rules that applied when the framework was established generally continue to govern call-offs made under it, which can mean two suppliers on the same framework work under different guidance depending on timing.
7. Building your submission checklist
A workable submission maps each template field to a piece of evidence: the CRP link itself, the signed declaration, Scope 1 and Scope 2 figures backed by energy bills or meter readings, and entries for each of the five Scope 3 categories with supporting documentation such as fleet logs, travel expense summaries or supplier questionnaires.
- Attach or reference energy invoices and meter data behind every Scope 1 and Scope 2 figure.
- Keep fleet mileage logs and travel expense summaries ready for the transport and business travel categories.
- Request emissions or waste data from key suppliers well before the submission deadline.
Pro Tip: Gathering half-hourly consumption data and validating bills ahead of a tender saves considerable time when a submission deadline lands with little notice.
8. Why treating the CRP as a checkbox is a mistake
Most guidance on PPN 006 treats the Carbon Reduction Plan as a compliance hurdle to clear once and forget. That reading misses the point. Because sign-off expires after 12 months and reporting periods run stale within roughly 18 months, a CRP built once for a single bid becomes a liability on the next one if nobody updates it.
The bigger error is bidders underestimating how much of the plan's failure risk sits in data, not intent. Suppliers rarely fail because they lack a Net Zero ambition. They fail because Scope 3 figures for business travel or waste were never collected, or because the sign-off date quietly expired between one tender and the next.
If you are preparing to bid on contracts above £5 million with any regularity, the priority is not writing a better plan. It is building a repeatable way to pull Scope 1 and Scope 2 data and refresh sign-off before every submission, so the CRP is always current rather than assembled under deadline pressure.
— Chris
9. How EnerlyticsAI supports your Carbon Reduction Plan
Collecting Scope 1 and Scope 2 figures usually means chasing energy bills across sites and hoping the numbers reconcile. EnerlyticsAI pulls half-hourly consumption data and validates bills automatically, which turns that chase into a dashboard you can check before every tender deadline rather than during one.
- Automated bill validation helps identify billing errors to improve the accuracy of your emissions baseline.
- Multi-site management keeps consumption data organized across every location your CRP needs to cover.
- The Emissions page shows how consumption data maps into Scope 1, 2 and 3 reporting inputs.
You can start on the Free forever plan and manage multiple sites without any upfront charge, which matters most when you are preparing evidence for a bid on a fixed timeline.
10. Official documents to download
- PPN 006 guidance on carbon reduction plans, the main policy text and conditions of participation.
- UK Government greenhouse gas conversion factors, required for converting activity data to CO2e.
Sources
FAQ
What are the requirements for carbon reduction plans in PPN 06/21?
A compliant plan must be published on the supplier's UK website, signed off at director or board level within the preceding 12 months, and include Scope 1 and Scope 2 emissions plus five specific Scope 3 categories. It also needs a stated Net Zero commitment and a description of environmental management measures.
What is PPN 06?
PPN 06/21 is the procurement policy note that introduced the Carbon Reduction Plan requirement for major UK government contracts, now updated and reissued as PPN 006 under the Procurement Act 2023. It applies to contracts valued above £5 million a year including VAT.
What are the requirements for a carbon reduction plan?
The plan needs a Net Zero commitment, baseline and reporting year emissions data, full Scope 1 and Scope 2 coverage, the five mandated Scope 3 categories, environmental management measures and a signed declaration. It should follow the official Annex A template structure closely to avoid a technical fail.
What are the requirements for carbon reporting in the UK?
For PPN 006 purposes, emissions are reported in tonnes of CO2 equivalent using the UK Government's conversion factors, following the GHG Protocol Corporate Accounting and Reporting Standard for Scope 1 and Scope 2. Reporting periods should stay current, since guidance treats a plan as outdated after roughly 18 months.