The NHS has committed to reach net zero by 2045 for the emissions it can influence, and most of those sit with its suppliers. To get there, NHS England has set out a supplier roadmap with fixed dates. If you supply goods, services or works to the NHS, directly or through a framework, the carbon part of the tender is already pass or fail. The next step comes in April 2027, and it asks for much more than a short plan.
What every new NHS contract asks for today
Since April 2024 the carbon requirement has applied to all new NHS procurements, not only the large ones. Which document you need depends on the value of the contract. Since 24 February 2025 the threshold is measured including VAT, to match the Procurement Act 2023.
- Contract
- £5 million a year or more, including VAT
- What you must provide
- A Carbon Reduction Plan
- Contract
- Any new framework or dynamic market, whatever its value
- What you must provide
- A Carbon Reduction Plan, unless the framework owner decides a Net Zero Commitment is more proportionate
- Contract
- Below £5 million a year and above the published procurement threshold
- What you must provide
- A Net Zero Commitment
| Contract | What you must provide |
|---|---|
| £5 million a year or more, including VAT | A Carbon Reduction Plan |
| Any new framework or dynamic market, whatever its value | A Carbon Reduction Plan, unless the framework owner decides a Net Zero Commitment is more proportionate |
| Below £5 million a year and above the published procurement threshold | A Net Zero Commitment |
For frameworks the check is made once, when you bid to join the framework, rather than at each call-off. Subcontractors are not in scope of the NHS requirement itself, although a main contractor may still ask its own suppliers for figures.
Both documents are marked pass or fail. They are not scored or compared with other bidders, but a supplier whose document falls short cannot go on to the next stage of the tender, except in exceptional circumstances.
What a Net Zero Commitment and a Carbon Reduction Plan must contain
A Net Zero Commitment is the lighter of the two. It must confirm that your business will reach net zero by 2050 or earlier for at least its UK operations, covering Scope 1, Scope 2 and the defined Scope 3 categories, and it must be published on your website where a buyer can find it. NHS England gives example wording in its guidance.
A Carbon Reduction Plan must also:
- Report your current emissions in tonnes of CO2e, following the GHG Protocol, for Scope 1, Scope 2 and five Scope 3 categories: upstream transport and distribution, waste from operations, business travel, employee commuting, and downstream transport and distribution.
- Use a reporting period that ends no more than 12 months before the tender starts.
- Describe the environmental management measures you already have in place.
- Be approved by the board, or by a company director if there is no board.
- Be published on your website and updated at least once a year.
The NHS points suppliers to the central government Carbon Reduction Plan template and technical standard published with PPN 006. Our guide to writing a Carbon Reduction Plan walks through that template step by step.
If some data is missing
What changes from April 2027
The roadmap says that from April 2027 all suppliers will be required to publicly report targets and emissions, and to publish a Carbon Reduction Plan, for all of their relevant global Scope 1, 2 and 3 emissions. Three things change compared with today:
- All suppliers, not only larger contracts. The lighter Net Zero Commitment is no longer the end point.
- Global, not UK only. If you have sites or operations outside the UK, they come into the figures.
- All relevant Scope 3, not five categories. For a manufacturer that usually brings in purchased materials, which are often the largest source of all.
Two further milestones follow. From April 2028 the roadmap introduces requirements for carbon footprints of individual products supplied to the NHS. From 2030, suppliers will only qualify for NHS contracts if they can show progress through published progress reports and continued emissions reporting.
At the time of writing, the detailed guidance for April 2027 is still to come. Check NHS England's supplier pages before you finalise anything, and treat any summary, including this one, as a starting point.
Why six months is less time than it sounds
A plan for April 2027 needs a full year of figures behind it. If your financial year runs April to March, the year you report is likely to be the one you are in now. Gas, electricity and fuel bills can usually be pulled together in a few weeks. Scope 3 takes longer, because the data sits with suppliers, hauliers and waste contractors who need time to answer.
Targets also need a base year. A target set against a year you never measured properly is hard to defend when a buyer asks how you got the number.
Five things to do before April 2027
- List your NHS contracts and renewalsNote which ones run past April 2027, which frameworks you sit on, and when each is due to be re-tendered.
- Measure Scope 1 and 2 from your billsCollect twelve months of gas, electricity, fuel and refrigerant records for every site, and convert them with the UK government conversion factors for the same year.
- Find your largest Scope 3 sourcesStart with purchased materials, transport and waste. Rank suppliers by spend so you know whose data matters most.
- Choose a base year and a targetPick a year you can measure well, set a net zero date of 2050 or earlier, and write down how you treat renewable electricity tariffs.
- Get sign-off and publishHave a director approve the plan, put it on your website with a clear link, and set a date to update it each year.
NHS England also offers the Evergreen Sustainable Supplier Assessment, a tool that shows suppliers how their sustainability work lines up with the NHS net zero ambition.
How ESGen helps NHS suppliers
In the ESGen platform you record Scope 1 and 2 from your own bills, site by site and meter by meter, converted with UK government factors. The upstream energy share of Scope 3 is added automatically. Each figure keeps its source document, factor and calculation log, and the year is locked once it is signed off, so you can show a buyer where a number came from.
The rest of Scope 3 is not calculated in the platform today. Our team works those figures out with you and writes the Carbon Reduction Plan itself, ready for board or director approval. ESGen does not bid for contracts, assess tenders or verify emissions, and a plan on its own does not win a contract.
If you hold or bid for NHS contracts, talk to our team with a year of energy bills to hand.
Sources
- NHS England, Carbon reduction plan and net zero commitment requirements for the procurement of NHS goods, services and works, version 3, updated 11 December 2025
- NHS England, Greener NHS: suppliers and the NHS net zero supplier roadmap, on england.nhs.uk
- NHS England, Delivering a net zero National Health Service, October 2020, updated July 2022
- Cabinet Office, PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts, published 17 February 2025, updated 10 July 2025
This article is general information, not legal or financial advice. Rules change, so check the current guidance before you rely on a threshold or a date.
