On this page 7 sections
Key takeaways
- PPN 006 replaced PPN 06/21 for central government procurements advertised from 24 February 2025; the policy is the same, but it is now a condition of participation.
- It applies to central government contracts worth more than £5 million a year including VAT, and a subcontractor is not required to have a plan unless it bids in its own right.
- A plan needs a net zero by 2050 commitment, Scope 1 and 2 emissions, five named Scope 3 categories, reduction measures, board sign-off and a prominent link on your website.
- Plans are checked pass or fail, not scored, and a rise in emissions does not fail one, so an honest first plan from fuel, energy and mileage records is enough to start.
- Review it within six months of your financial year-end, keep previous versions online, and use the government's conversion factors for the year you are reporting.
More groundworks, drainage and civils subcontractors are being asked the same question on supplier portals and tender questionnaires: please provide a link to your Carbon Reduction Plan. Small manufacturers supplying contractors and utilities are seeing it too. For a firm of 20 or 50 people, it often lands without explanation, and searching for the rules turns up references to PPN 06/21, a note that no longer applies to new procurements.
This guide sets out where the rules stand at the time of writing (October 2026), what a plan must contain, why tier 1s ask for one below the threshold, and how to write and publish yours. It explains the guidance and is not legal advice; check anything that turns on your own contracts with an adviser.
PPN 06/21 and PPN 006: what changed and when
A Procurement Policy Note (PPN) tells central government buyers how to apply a policy. PPN 06/21 was published in June 2021 and applied to procurements advertised on or after 30 September 2021, under the Public Contracts Regulations 2015.1 It asked bidders for a Carbon Reduction Plan as a selection criterion on contracts with an anticipated value above £5 million a year, excluding VAT.1
When the Procurement Act 2023 took effect, the Cabinet Office reissued the note as PPN 006, first published on 17 February 2025.2 Buyers must apply it to relevant procurements advertised on or after 24 February 2025.3 It sits in the Procurement Act 2023 section of the government's list of policy notes, and PPN 06/21 sits in the section for procurements under the 2015 Regulations.4
| PPN 06/21 | PPN 006 | |
|---|---|---|
| Applies to | Procurements under the Public Contracts Regulations 2015, advertised from 30 September 2021 | Procurements under the Procurement Act 2023, advertised from 24 February 2025 |
| Threshold | Above £5 million a year, excluding VAT | Above £5 million a year, including VAT |
| How it is assessed | Selection criterion | Condition of participation |
| Still used for | Procurements started and contracts awarded before 24 February 2025, including old frameworks | Everything in scope since then |
The government is clear that the reissue does not constitute a change in policy.3 The FAQ puts it the same way: the substantive obligation introduced by PPN 06/21 remains the same under the Act, but as a condition of participation rather than a selection criterion.5 So a plan written to the 06/21 template is not wasted, but it should now say it was completed in accordance with PPN 006, which is the wording in the current template.3
Who the note applies to
PPN 006 applies to central government departments, their executive agencies and non-departmental public bodies.3 They should apply it to contracts for goods, services or works with an estimated value above £5 million a year including VAT, unless it would not be relevant or proportionate.3 The value is averaged over the life of the contract, so a four-year contract worth £21 million in total is in scope even if the first year is under £5 million.3 Frameworks are covered only where an individual contract awarded under them is expected to exceed £5 million a year.3 The note is not stated to be mandatory for the devolved administrations.5
Local authorities and private clients are outside the note, though some ask for a plan anyway, so read each tender's own documents.
Do subcontractors need a Carbon Reduction Plan?
Under the policy itself, no. The government's FAQ says there is no requirement for subcontractors to produce a plan, except where a subcontractor is also bidding for a procurement in its own right.5 If you bid as part of a consortium, each member needs one.5
The same answer goes on to note that some suppliers are setting their own policies that may ask for emissions data or a net zero commitment from their supply chain, and that these are separate from PPN 006.5 That is the request most subcontractors are actually receiving. In our experience it comes for three reasons:
- Tier 1s have their own targets. A main contractor's footprint includes what it buys, and the technical standard notes that Scope 3 emissions can represent up to 80% of an organisation's emissions.6 Subcontracted plant, haulage and labour sit in that number, so they want data from you.
- Contract carbon reporting. PPN 016 gives central government an optional contract schedule with contract-specific emissions reporting, reduction targets and monitoring through the supplier's plan over the life of the contract.7 Where a client uses it, the tier 1 needs figures from the people doing the work.
- Standard questionnaires. Supply chain teams ask every firm the same questions. A plan you can link to clears this one quickly.
If you ever bid in your own name for a central government contract over the threshold, the plan becomes a pass or fail condition, and having one published already removes that risk. Our tier 1 supply chain guide covers the other evidence those teams check.
What a Carbon Reduction Plan must contain
PPN 006 sets out the minimum content.3 The technical standard and the template published with it fill in the detail.6
- A net zero commitment. Confirmation that you are committed to achieving net zero by 2050 at the latest for your UK operations.6
- Baseline and current emissions. Scope 1 and Scope 2 in full, plus a defined subset of Scope 3, reported in tonnes of carbon dioxide equivalent (tCO2e).3
- Reduction targets. Where you expect emissions to be in five years and the percentage reduction that represents.3
- Reduction measures. The environmental management measures you have in place and will apply when performing the contract, such as certification schemes or specific carbon reduction projects.3
- A signed declaration. Approval by the board of directors or equivalent, with the date, signed off by a named director with their job title.6
- Publication. The plan published on your UK website, with a link in a prominent place on your homepage.6
The scopes, in plain terms
The scopes come from the Greenhouse Gas Protocol. Scope 1 is direct emissions from sources you own or control, such as fuel burnt in boilers, furnaces and vehicles. Scope 2 is the electricity, steam, heat or cooling you buy.5 Scope 3 is everything else in your value chain, split into 15 categories.6 A Carbon Reduction Plan asks for only five of them:5
- Upstream transportation and distribution: haulage and deliveries you pay for, in vehicles you do not own
- Waste generated in operations: skips, muck away and other waste disposed of by third parties
- Business travel: travel in vehicles you do not own or operate, such as trains, flights and staff using their own cars for work
- Employee commuting: staff travelling between home and site or the yard
- Downstream transportation and distribution: delivery of products you sell, where you do not pay for it
For a civils subcontractor, Scope 1 is usually dominated by diesel in plant and vans. For a manufacturer, gas and electricity tend to matter more. The five Scope 3 categories are mostly transport and waste.
How buyers check it
Plans are not scored or compared against each other. The check is whether they meet the requirements, so a firm committed to net zero by 2050 passes on the same footing as one committed to 2030.5 The emissions figures are for information and are not used to assess you, and an increase against your baseline does not fail the plan.5
What does fail a plan is missing content: no net zero commitment, emissions missing for some scopes without an explanation, no reduction measures, or no completed declaration.8 The reporting period should fall no more than 18 months before the tender notice, unless you explain why.8 A corporate social responsibility statement or a Science Based Targets commitment is not accepted in place of a plan, although you can list either as one of your measures.5 A firm trading for less than 12 months can confirm its commitment and publish a full plan as soon as possible.8
How to measure your emissions
Your footprint should follow the GHG Protocol Corporate Accounting and Reporting Standard,6 which covers the seven greenhouse gases in the Kyoto Protocol.9 In practice, an SME does this by multiplying activity data, such as litres of diesel or kWh of electricity, by the UK government's conversion factors, which the technical standard tells you to use.6
The factors are published each year. The 2026 set was published on 11 June 2026, with a revised flat file in July 2026, and is meant for reporting UK activities in 2026.10 Use the set for the year your data covers, and say which you used.
Diagram
Measuring a first carbon footprint
- Set the boundary and periodThe contracting entity, operational control, your last financial year
- Gather Scope 1 and 2 recordsFuel cards, gas and electricity bills in litres and kWh
- Gather the five Scope 3 recordsHaulage, waste transfer notes, mileage claims, a commuting survey
- Apply the conversion factorsActivity × the factor for that year, converted to tonnes CO2e
- Set the baseline and targetsFirst year as baseline, a five-year projection and reduction measures
The work is mostly gathering records: fuel cards for diesel, energy bills for kWh, mileage claims for business travel, a short staff survey for commuting and waste transfer notes for tonnages. Choose one boundary method, usually operational control for a small firm, and the same 12-month period for every figure.6
Chart
Worked example: emissions by source (tCO2e)
If a consultant or online tool produces the plan for you, it still has to meet the requirements.5
A simple Carbon Reduction Plan template
The government publishes a template with PPN 006, and buyers accept other layouts only if every piece of information in it is provided.5 The simplest course is to follow its structure. This outline follows the template's sections, with notes on what to write in each.3
| Section | What to write |
|---|---|
| Supplier name and publication date | The legal entity that signs contracts, not a trading name or parent |
| Commitment to achieving net zero | One sentence with your target year, 2050 or earlier |
| Baseline emissions footprint | Baseline year, Scope 1, Scope 2, the included Scope 3 sources and the total in tCO2e. If this is your first footprint, say so and use it as the baseline |
| Current emissions reporting | The same table for your latest reporting year |
| Emissions reduction targets | Projected emissions in five years and the percentage reduction |
| Carbon reduction projects | Completed measures since the baseline and the reduction they achieved, then future measures you plan |
| Declaration and sign-off | The standard declaration, board approval with its date, and a director's name, job title and date |
The template's guidance notes give examples of measures that belong in the projects section: ISO 14001 or PAS 2060 certification, joining the Science Based Targets initiative, LED lighting with presence sensors, less business travel and electrifying the fleet.3 For a civils firm, telematics to cut plant idling, newer engines, HVO trials, route planning and more local labour are the kinds of measures you can describe honestly. A dated list of what you have done reads better than general statements.
Publishing your plan on your website
The standard asks for the plan on your UK website, with the link in a prominent place on your homepage, and says it is good practice to keep previous plans online so progress can be followed.6 If you have no website, you must provide a copy in writing to anyone who asks within 30 days.6
In practice:
- A dedicated page, such as /carbon-reduction-plan, with the plan as readable text and a PDF copy
- A link to it in your homepage footer or sustainability section, not buried in a downloads folder
- Earlier plans listed on the same page by year
- The page in your sitemap and open to search engines, so buyers searching for it find it
On most sites this is an afternoon's work. If yours makes adding a page or editing the footer awkward without a developer, it is worth looking at the website as a whole, since supply chain teams check it before they call. Our SEO work makes sure pages like this, and your case studies, are indexed and easy to find, and our guide to website design for construction companies covers the rest.
Keeping it up to date
The plan should be updated at least annually,3 and the technical standard asks you to review and update it within six months of your financial year-end.6 Buyers check that it was published since the tender notice or in the 12 months before it.8 One plan covers every procurement where the measure applies during its 12 months.5
The simplest routine is to tie the update to your year-end accounts: pull the fuel, energy, mileage and waste figures, apply that year's conversion factors, add the measures completed, get board approval and publish the new version beside the old ones. If emissions rose because the business grew, explain it; the FAQ suggests doing so, and notes that a firm whose footprint jumps after an acquisition may want a new baseline.5
The year-end pull is quicker when those records already sit in one place. Eccles, a Walsall manufacturer, replaced fragmented systems with a custom ERP bringing CRM, stock, vendor data and operations together, so reporting no longer depends on people compiling spreadsheets. Read the Eccles case study.
Once the plan is live, link to it from your pre-qualification profiles and your tender library so every questionnaire uses the current version. Our guide to bid writing for construction subcontractors covers building that library, and the pre-qualification guide covers the schemes that ask for it.
Frequently asked questions
Has PPN 06/21 been replaced?
Yes, for new procurements. PPN 006 was published in February 2025 and applies to central government procurements under the Procurement Act 2023 advertised on or after 24 February 2025. PPN 06/21 still applies to procurements started and contracts awarded before that date, including frameworks set up under the old rules. The government says the reissue is not a change in policy.
What is the threshold for a Carbon Reduction Plan?
Under PPN 006, central government buyers should ask for a plan on contracts with an estimated value above £5 million a year including VAT, averaged over the life of the contract, unless it is not relevant or proportionate. For frameworks, it applies where an individual contract awarded under the framework is expected to exceed £5 million a year. PPN 06/21 used £5 million a year excluding VAT.
Do subcontractors need a Carbon Reduction Plan?
Not under PPN 006 itself. The government's FAQ says subcontractors do not need one unless they are bidding for a procurement in their own right, and each consortium member needs one. Many tier 1 contractors ask their supply chain for emissions data or a net zero commitment under their own policies, so in practice many subcontractors are asked for one anyway.
Which Scope 3 emissions go in a Carbon Reduction Plan?
Five of the 15 GHG Protocol categories: upstream transportation and distribution, waste generated in operations, business travel, employee commuting and downstream transportation and distribution. Scope 1 and Scope 2 are reported in full. Figures are in tonnes of carbon dioxide equivalent, calculated with the UK government conversion factors.
Does a Carbon Reduction Plan need to be audited?
No. The PPN 006 technical standard says there is no requirement to have your carbon footprint audited, although it should follow the GHG Protocol Corporate Standard and be as accurate as you can make it. The plan must be approved by the board, signed off by a named director and published on your website.
How often should a Carbon Reduction Plan be updated?
At least once a year. The technical standard asks suppliers to review and update the plan within six months of their financial year-end, and buyers check that it was published since the tender notice or in the 12 months before it. Keep earlier plans on your website so progress can be followed.
Sources
- Procurement Policy Note 06/21: Taking account of Carbon Reduction Plans in the procurement of major government contractsCabinet Office
- PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contractsCabinet Office
- PPN 006: Taking account of Carbon Reduction Plans (HTML)Cabinet Office
- Procurement policy notesCabinet Office
- PPN 006: Frequently asked questionsCabinet Office
- PPN 006: Technical standard for Completion of Carbon Reduction PlansCabinet Office
- PPN 016: Carbon reduction contract scheduleCabinet Office
- PPN 006: Guidance on taking account of carbon reduction plans: adopting and applying conditions of participationCabinet Office
- Corporate StandardGreenhouse Gas Protocol
- Greenhouse gas reporting: conversion factors 2026Department for Energy Security and Net Zero
