The Procurement Act 2023: What Changes in 2026 and Why Your CRP Needs Updating

A New Procurement Regime Starts in 2026

The Procurement Act 2023 received Royal Assent in October 2023 and comes into force on 24 February 2026. It replaces the existing Public Contracts Regulations 2015, the Utilities Contracts Regulations 2016, and the Concession Contracts Regulations 2016 — the entire framework that has governed UK public procurement since Brexit.

For businesses that hold or bid for government contracts, this is the most significant change to procurement law in a decade. And carbon reduction plans sit squarely in the middle of it.

What’s Changing for Carbon Requirements?

Under the new Act, contracting authorities will have broader discretion to set and weight sustainability criteria in their procurement exercises. The key changes that affect carbon reduction plans include:

• National Procurement Policy Statement (NPPS) — the government is publishing an updated NPPS that contracting authorities must “have regard to” when conducting procurements. The draft NPPS explicitly references environmental sustainability and Net Zero commitments
• Award criteria flexibility — the new Act gives buyers more freedom to weight environmental criteria, including carbon reduction, in tender evaluations
• Transparency requirements — all contract awards above £5,000 must be published on a new central digital platform, increasing scrutiny of environmental commitments made during bidding
• Debarment register — the Act introduces a formal debarment list. While primarily for serious misconduct, repeated failures to deliver on environmental commitments made in bids could become grounds for exclusion

PPN 006 Under the New Framework

PPN 006 itself was issued under the old procurement framework. The Cabinet Office has confirmed that carbon reduction plan requirements will continue under the new regime, but the mechanism will change. Rather than standalone Procurement Policy Notes, requirements will be integrated into the NPPS and associated guidance.

The practical implication is that carbon reduction plans are not going away — they are becoming more deeply embedded in the procurement framework. Businesses that treat their CRP as a one-off compliance exercise will find themselves caught out when the new rules start applying to procurements launched from February 2026 onwards.

The Threshold Question

One of the most significant signals from government is the likely lowering of the £5 million threshold. Under the current PPN 006 rules, only contracts above £5 million per annum require a CRP. The new framework is expected to expand this requirement to a much broader range of contracts.

Several government departments are already applying CRP requirements to contracts well below £5 million. The Procurement Act formalises this trend. If you are currently just below the threshold and thinking “this doesn’t apply to me,” think again. By February 2026, it very likely will.

What You Should Do Now

With the Procurement Act coming into force in less than three months, businesses should:

• Get your CRP in place now — do not wait for the new rules to be finalised. Having a published plan before the transition gives you a head start
• Use current DEFRA factors — ensure your plan uses the latest emission factors. Plans calculated with outdated factors will not meet expectations under the new regime
• Publish on your website — the publication requirement is not changing. Your CRP must be publicly accessible
• Plan for annual updates — the new framework will place greater emphasis on demonstrating year-on-year progress, not just having a static document

With Carbonhogs, you can have a professional, compliant carbon reduction plan ready in minutes — not months. Get ahead of the February 2026 deadline and ensure your business is ready from day one.