The NHS has published updated Carbon Reduction Plan (CRP) requirements as part of its Net Zero Supplier Roadmap, introducing expanded reporting obligations for certain procurement activities from April 2027.
While existing CRP requirements will continue to apply across many NHS procurements, suppliers bidding for higher-value contracts and framework agreements must provide more comprehensive greenhouse gas emissions reporting, including disclosure of all relevant global Scope 1, Scope 2 and Scope 3 emissions.
The changes reflect the NHS’s ongoing commitment to reducing supply chain emissions while providing suppliers with a clearer pathway towards more robust carbon reporting.
Businesses supplying goods, services or works to the NHS should review how the updated requirements apply to their organisation and consider taking steps now to strengthen their emissions reporting capabilities.
What is the new NHS 2027 Carbon Reduction Plan requirements?
From April 2027, NHS procurement requirements will continue to vary depending on contract value and procurement route.
For contracts valued at £5 million or more per annum (including VAT), as well as all new framework agreements and dynamic markets operated by in-scope organisations, suppliers will be required to publish a Carbon Reduction Plan covering all relevant global Scope 1, Scope 2 and Scope 3 emissions. These suppliers will also be expected to publicly disclose emissions data and reduction targets.
For other contracts above the relevant procurement thresholds but below £5 million per annum, suppliers will continue to report a reduced-scope Carbon Reduction Plan aligned with PPN 006 requirements. This includes Scope 1 and Scope 2 emissions alongside five specified Scope 3 categories.
The updated guidance therefore expands reporting requirements for some NHS procurements, rather than introducing a single reporting standard across all suppliers.
The NHS also recommends that suppliers should report all relevant Scope 1, Scope 2 and Scope 3 emissions on a global basis where possible. For the suppliers that do not reach the expanded scope thresholds, we recommend reporting on these emissions anyway to align more closely with the NHS goals and to prepare for any future compliance changes.
Organisations that adopt this approach may be better positioned to support NHS net zero ambitions and prepare for potential future reporting developments.
Why is the NHS introducing these changes?
The NHS has committed to achieving net zero emissions across the emissions it directly controls by 2040 and those it can influence by 2045. As a significant proportion of healthcare emissions originate within the supply chain, supplier engagement is essential to achieving these objectives.
The 2027 milestone is designed to improve transparency across supply chains and encourage suppliers to move beyond carbon measurement towards meaningful emissions reduction. By requiring full Scope 3 reporting for in-scope procurements, the NHS aims to gain greater visibility of indirect emissions generated through procurement, logistics, travel, waste management and other supply chain activities.
What challenges will suppliers face?
For many organisations, Scope 3 emissions reporting will be the most significant challenge. This is because unlike Scope 1 and Scope 2 emissions, which are generally easier to measure using operational data, Scope 3 emissions often require information from external sources, like suppliers, contractors, and other external stakeholders. Gathering accurate data across complex supply chains can both be resource-intensive and time-consuming.
How should businesses prepare for the new NHS Carbon Reduction Plan?
Although implementation seems some time away, suppliers should begin preparing for the new regulation now.
We suggest looking into:
– Reviewing existing Carbon Reduction Plans
– Establishing a comprehensive emissions baseline
– Identifying and quantifying relevant Scope 3 categories
– Engaging suppliers to improve data collection processes
– Setting measurable emissions reduction targets
– Developing governance structures to support ongoing reporting and compliance
Early preparation can help reduce compliance risks and avoid last-minute challenges as reporting expectations increase.
Looking ahead
The 2027 Carbon Reduction Plan requirements are not the final stage of the NHS Net Zero Supplier Roadmap. From April 2028, additional requirements relating to product-level carbon footprinting are expected to be introduced, further embedding sustainability within NHS procurement processes.
For NHS suppliers, the direction of travel is clear. Carbon reporting and reduction are becoming increasingly important procurement considerations, and organisations that establish robust reporting frameworks now will be best placed to meet future requirements and secure opportunities within the healthcare sector.
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