April 2027 NHS Carbon Reduction Plan Requirements

From 1 April 2027, the NHS is changing its Carbon Reduction Plan requirements for suppliers.

If your first thought is, ‘I’ve only just got to grips with the current requirements’, I understand. Let’s take this one step at a time and work out what actually applies to you.

There has already been quite a lot of chat around the changes, particularly the worrying idea that every NHS supplier will suddenly need to report every Scope 3 emission globally.

That is not quite what the final NHS England guidance says.

The new requirements are being introduced proportionately.

That word matters. The starting point is understanding which requirements apply to your procurement.

Some procurements will require the expanded 2027 NHS Carbon Reduction Plan, while lower-value procurements will continue to use the existing 2024 Carbon Reduction Plan requirements.

For all suppliers, though, the direction of travel is clear.

Carbon reporting is moving beyond a UK-focused Scope 1, Scope 2 and limited Scope 3 exercise towards a much fuller understanding of emissions across the organisation and its value chain.

As it should do really.

It’s a continued drive to get a clearer understanding of your business and how well aligned you are to their decarbonisation goals.

If you supply the NHS, now is a good time to understand the gap between what you have today and what you might need from April 2027.

Check your NHS Carbon Reduction Plan readiness

What changes on 1 April 2027?

NHS England’s Net Zero Supplier Roadmap has been gradually increasing the carbon requirements placed on suppliers.

The next milestone comes on 1 April 2027.

For procurements beginning on or after that date, NHS England introduces two types of Carbon Reduction Plan requirement:

The 2027 NHS CRP requirement applies to higher-value contracts and, generally, new NHS frameworks and dynamic markets.

The 2024 CRP requirement continues for relevant lower-value procurements.

Procurements which began before 1 April 2027 continue to follow the requirements that applied previously.

This distinction matters. If somebody tells you that every NHS supplier needs exactly the same expanded global Carbon Reduction Plan from April 2027, that is an oversimplification that can cause unnecessary worry.

Which procurements require a 2027 NHS Carbon Reduction Plan?

The expanded 2027 NHS CRP is expected to apply to:

• contracts worth £5 million per annum or more, including VAT
• all new NHS frameworks and framework agreements operated by in-scope organisations, irrespective of contract value, unless the expanded requirement is considered disproportionate
• new dynamic markets operated by in-scope organisations, irrespective of value, again subject to proportionality For contracts below £5 million per annum but above the relevant procurement thresholds, the 2024 CRP requirements generally continue to apply.

The requirements apply to NHS purchasing and commissioning of goods, services and works, including pharma and healthcare services.

There are additional details to consider under the Provider Selection Regime and for direct awards, so suppliers should always check the requirements of the particular procurement rather than relying solely on contract value.

What is different about a 2027 NHS Carbon Reduction Plan?

This is where the substantive change happens.

The current 2024-style CRP is broadly aligned with central government PPN 006 requirements. It covers Scope 1 and Scope 2 emissions plus a defined subset of five Scope 3 categories, with a UK geographical boundary as the minimum.

The five categories are 4 (upstream transportation and distribution), 5 (waste generated in operations), 6 (business travel), 7 (employee commuting) and 9 (downstream transportation and distribution). See the PPN 006 technical standard for their reporting boundaries.

The 2027 NHS CRP goes that bit further.

A compliant 2027 NHS CRP must include baseline and current emissions for:

Scope 1 — Direct greenhouse gas emissions from sources owned or controlled by the organisation.

Scope 2 — Indirect emissions associated with purchased energy.

All relevant Scope 3 categories — Rather than reporting only the five Scope 3 categories included in the current CRP standard, suppliers must consider the full set of Scope 3 categories defined by the Greenhouse Gas Protocol and report those that are relevant to their organisation.

This is likely to be the biggest practical change for many suppliers.

Does that mean I have to calculate all 15 Scope 3 categories?

Not necessarily.

The requirement is to report all relevant Scope 3 categories.

The Greenhouse Gas Protocol identifies 15 Scope 3 categories. Suppliers should consider which categories apply to their organisation.

Where a category is considered not relevant, the 2027 guidance says the supplier must explain why.

This is an important distinction. The requirement is not simply to put a number against 15 boxes regardless of whether they make sense for your business. Give narrative if you don’t provide a number, if a category is not relevant.

For some organisations, purchased goods and services may represent a very significant part of the carbon footprint. For others, business travel, freight, employee commuting, leased assets, product use or other categories may be more important.

The starting point is understanding your organisation and its value chain properly.

What if I do not have perfect Scope 3 data?

This is one of the biggest concerns for SMEs, and understandably so. Gathering the data can feel like a job in itself.

Scope 3 accounting can involve information held outside your own business, including suppliers, logistics providers and other organisations in your value chain.

NHS England recognises this. Gathering reliable information across a supply chain takes time.

The guidance specifically allows estimation methods to be used where appropriate, including spend-based calculations using carbon conversion factors. It also acknowledges that suppliers may not yet have comprehensive data throughout their supply chains.

There are also provisions for exceptional circumstances.

Where a supplier has an acceptable reason for gaps in its emissions information, it may be able to provide the data that is available, explain what is missing and set out the steps it will take to improve the information.

NHS England gives a specific example for 2027/28 tenders where there are gaps in the additional Scope 3 information. An acceptable explanation and a plan to build reporting capability may allow the supplier to meet the requirement, although this will be considered by the contracting authority.

My advice is to start early. These provisions give you a way to explain genuine gaps, but you will still need to show what you have done and how you plan to improve.

What does a global boundary mean?

The geographical boundary is another important change.

For a 2027 NHS CRP, the chosen reporting entity must apply a global geographical boundary to its net zero commitment and emissions reporting.

But that does not necessarily mean every UK NHS supplier which belongs to an international group has to produce the carbon footprint for its entire global parent company.

NHS England distinguishes between the reporting entity and the geographical boundary.

A UK company can report for the UK entity that is supplying the NHS, but the emissions associated with that entity must not simply stop at the UK border. For example, overseas goods purchased for the UK business or international freight associated with its activities can still be part of its footprint.

Alternatively, in appropriate circumstances, a parent organisation can report on behalf of a wholly owned supplier, provided the NHS conditions around ownership, commitment and applicability of environmental measures are met.

This is an area where suppliers should establish their reporting boundary before beginning the calculations. Otherwise, it is very easy to spend time measuring the wrong organisation.

Do I need to change my net zero target to 2045?

No. Not as a minimum requirement for a 2027 NHS Carbon Reduction Plan.

The published NHS England requirements say that the CRP must confirm a commitment to achieve net zero by 2050 or earlier. The procurement assessment questions also test for a public commitment to net zero by 2050.

The NHS aims to reach net zero by 2045 for the emissions it can influence through its supply chain. Suppliers aiming for higher Evergreen maturity may therefore choose to move further and faster, but a 2045 target is not the minimum test for the 2027 NHS CRP itself.

Do I need independent verification or an SBTi-validated target?

Again, no. Not for the basic 2027 NHS CRP requirement.

The minimum CRP requirements published by NHS England focus on the net zero commitment, emissions reporting, environmental management measures, appropriate approval and publication.

This becomes clearer when you look at Evergreen.

Evergreen Level 2 requires Scope 1, Scope 2 and all relevant Scope 3 emissions, a global boundary and a net zero target of 2050 or earlier. Independent validation is not required at Level 2.

At Level 3, the maturity criteria increase to a 2045 net zero target and independent validation.

So there is a difference between meeting the minimum 2027 procurement requirement and demonstrating a higher level of sustainability maturity.

How does the 2027 Carbon Reduction Plan relate to Evergreen?

Your Carbon Reduction Plan is one of the core pieces of evidence behind your Evergreen assessment.

Under the April 2026 Evergreen criteria, Evergreen Level 1 reflects a PPN-aligned CRP with a UK boundary, Scope 1 and Scope 2 reporting and the defined subset of Scope 3 emissions, while Evergreen Level 2 moves to a global boundary with Scope 1, Scope 2 and all relevant Scope 3 emissions.

NHS England describes Level 2 specifically as aligning with the April 2027 Net Zero Supplier Roadmap requirements.

If your organisation is currently at Level 1, the gap between Evergreen Level 1 and Level 2 gives you a useful indication of some of the work likely to be required to prepare for the expanded 2027 carbon requirements.

The Ultimate Guide to the NHS Evergreen Assessment · Evergreen evidence management

Will my existing Carbon Reduction Plan still be valid?

If the procurement applies the 2024 CRP requirement, an existing, current Carbon Reduction Plan produced in accordance with PPN 006 can continue to meet the NHS requirement.

If you need to meet the 2027 NHS CRP requirement, however, an existing CRP based only on the current UK boundary and five Scope 3 categories is unlikely to contain everything required.

You may need to expand your reporting boundary, your Scope 3 assessment, your emissions calculations, your explanation of Scope 3 relevance, and potentially the way information from a parent organisation or wider group is incorporated.

This is why I would recommend reviewing an existing CRP rather than assuming you need to throw it away and start again.

Carbon Reduction Plans for NHS Suppliers

Does the CRP have to be published?

Yes. It needs to be easy for a buyer to find.

The 2027 NHS CRP must be approved at board level, or by a company director where there is no board, and it must be clearly signposted and published on the supplier’s website.

During procurement, suppliers can be asked to provide a link to their most recently published CRP.

A good Carbon Reduction Plan should be easy for an NHS buyer to find, clearly identify the organisation it relates to, contain the required information and be kept current.

Where CRP requirements form part of contract conditions, NHS England’s guidance also envisages annual updates during the contract term.

Is the Carbon Reduction Plan scored?

Not exactly.

The CRP assessment is designed to establish whether the supplier meets the minimum requirement. It is not a competition to see which bidder has the lowest carbon footprint.

Where the requirement is being applied as a pass-fail condition, a supplier which fails to meet the minimum CRP standard may be unable to proceed to the next stage of the procurement, except where an accepted exceptional circumstance applies.

What should NHS suppliers do now?

The practical starting point is to take your existing Carbon Reduction Plan, imagine an Auditor is sat opposite you, and ask five questions:

Which entity does our CRP actually cover? Is that the entity bidding for NHS work, and is the reporting boundary clear?

Are we reporting only the current five Scope 3 categories? If so, which of the other GHG Protocol Scope 3 categories could be relevant?

Do we understand our global emissions boundary? Particularly if we buy products or services internationally or form part of a wider group.

Can we explain data gaps? And do we have a sensible plan for improving the underlying information?

Does our Carbon Reduction Plan align with our Evergreen answers? Conflicting boundaries, figures or targets across different documents create unnecessary problems.

What not to do

Avoid three reactions to the 2027 changes. Well, four; let’s start by not panicking.

Second, do not assume they do not apply to you simply because your individual contracts are worth much less than £5 million. If you access NHS work through frameworks or dynamic markets, the expanded requirements may still become relevant.

Third, do not start calculating every possible Scope 3 category without first defining your organisational boundary and deciding which categories are actually relevant.

Fourth, do not assume that an existing PPN 006 Carbon Reduction Plan automatically makes you 2027-ready. It may be an excellent starting point, but the expanded NHS requirement goes further on global and Scope 3 reporting.

A practical route to 2027 readiness

• Check your current CRP. Confirm that your existing document meets today’s requirements.
• Map the 2027 gap. Review entity, geographical boundary and Scope 3 coverage.
• Improve the emissions evidence. Gather better activity data where possible and use appropriate estimation approaches where necessary.
• Align Evergreen and CRP evidence. Make sure the information being submitted through Evergreen tells the same story as your published documentation.
• Update before you need it. Do not discover a problem once a procurement deadline has started counting down.

Review my Carbon Reduction Plan for 2027 readiness

Frequently asked questions about NHS Carbon Reduction Plans in 2027

Will every NHS supplier need a 2027 NHS CRP from April 2027?

No. The final NHS England policy uses a two-tier approach. The expanded 2027 NHS CRP applies particularly to contracts of £5 million per annum or more and new NHS frameworks and dynamic markets. Relevant lower-value contracts generally continue to use the 2024 CRP requirements.

Does the 2027 NHS CRP include Scope 3?

Yes. A 2027 NHS CRP must report all Scope 3 categories that are relevant to the reporting entity, alongside Scope 1 and Scope 2 emissions. Categories considered not relevant need an explanation.

Do I need perfect supplier-specific Scope 3 data?

Not necessarily. NHS England recognises that complete value-chain data may not always be available and permits appropriate estimation methods. There are also provisions for acceptable data gaps in exceptional circumstances, but suppliers should explain those gaps and how they intend to improve the data.

Does my net zero target have to be 2045?

The minimum 2027 NHS CRP requirement is a public commitment to reach net zero by 2050 or earlier. A 2045 target is associated with higher NHS sustainability ambition and Evergreen Levels 3 and 4 rather than being the minimum 2027 CRP requirement.

Is Evergreen Level 2 the same as being ready for 2027?

Evergreen Level 2 is expressly designed to align with the April 2027 Net Zero Supplier Roadmap requirements, so it is a strong indication of readiness. Suppliers should still check the requirements of each procurement and ensure their published CRP itself complies.

Can I use my existing PPN 006 Carbon Reduction Plan?

Yes for procurements applying the 2024 CRP requirement, provided it is current and compliant. For the expanded 2027 NHS CRP, you will need to check whether it has the necessary global boundary and all relevant Scope 3 reporting.

Related reading and support

• Discuss your 2027 Carbon Reduction Plan
• Prepare your evidence for annual updates