What is PPN 006 and Does Your Business Need to Comply?

What is PPN 006?

Procurement Policy Note 006 (PPN 006) is a UK government policy that requires suppliers bidding for central government contracts to have a published carbon reduction plan. Introduced on 30 September 2021 and taking effect from that date, it applies to all new central government procurement where the contract value exceeds £5 million per annum.

The policy is part of the UK government's broader commitment to achieving Net Zero greenhouse gas emissions by 2050, as mandated by the Climate Change Act 2008 (as amended in 2019). The logic is straightforward: the government is the UK's largest buyer of goods and services, and it is using its purchasing power to drive decarbonisation across the economy.

PPN 006 was issued by the Cabinet Office and applies to all central government departments, their executive agencies, and non-departmental public bodies. Many wider public sector organisations — including NHS trusts, local authorities, and universities — have voluntarily adopted similar requirements.

Who Needs to Comply?

The mandatory requirement applies to suppliers bidding for contracts where:

• The contracting authority is a central government department, executive agency, or non-departmental public body
• The contract is a new procurement (not an existing contract or extension)
• The contract value exceeds £5 million per annum

However, the practical reach is much wider than these criteria suggest. Here is why:

Subcontractors and supply chains: While the PPN technically applies to the prime contractor, many Tier 1 suppliers now require their own subcontractors to have carbon reduction plans as a condition of their supply agreements. If you supply a business that holds government contracts, you may need a CRP even if you never bid directly for government work.

Framework agreements: Major procurement frameworks such as G-Cloud, Digital Outcomes and Specialists, and Crown Commercial Service frameworks increasingly include carbon reduction plan requirements. Some frameworks have applied the requirement to all lots regardless of the £5 million threshold.

Wider public sector adoption: NHS England, many local authorities, and several university procurement consortia have adopted CRP requirements for their own procurement processes. The threshold is often lower than £5 million, and in some cases there is no threshold at all.

What Does a Compliant CRP Require?

The Crown Commercial Service published a template that outlines the expected content of a carbon reduction plan. A compliant CRP must include:

• Commitment to Net Zero — a clear statement committing your organisation to achieving Net Zero by 2050 at the latest
• Baseline emissions — your current greenhouse gas emissions across Scope 1, 2, and 3, calculated using recognised methodology (DEFRA emission factors and the GHG Protocol)
• Emission reduction targets — specific, measurable targets with defined timelines
• Carbon reduction measures — the actions your business is taking or plans to take to reduce emissions
• Publication — the plan must be published on your corporate website and updated annually

The Scope 3 Requirement

One of the most significant aspects of PPN 006 is that it requires reporting of Scope 3 emissions, not just Scope 1 and 2. Scope 3 covers indirect emissions from your supply chain, business travel, employee commuting, purchased goods and services, and waste.

For many businesses, this was the first time they had been required to calculate and report Scope 3. It is the most complex scope to measure because the data comes from outside your direct operations. However, it is also typically the largest scope — often representing 70% to 90% of a business's total emissions.

The CCS guidance acknowledges that Scope 3 data may be estimated in the first reporting year, with the expectation that data quality improves over time. This is a pragmatic approach that allows businesses to start reporting without perfect data.

What Happens if You Do Not Comply?

The consequence is binary: if a CRP is required for a procurement and you do not have one, your bid is excluded. You cannot submit a compliant tender without a published carbon reduction plan. There is no grace period and no alternative evidence that can substitute for a CRP.

For businesses that rely on government work, this is an existential compliance requirement. It is not a scoring criterion that you can accept a lower mark on — it is a pass/fail gate in the procurement process.

Deadlines and Timeline

PPN 006 has been in effect since 30 September 2021. If you are bidding for applicable contracts today, you need a CRP now. There is no upcoming deadline to prepare for — the requirement is already active.

Plans should be reviewed and updated annually, and the government has indicated that the scope of the requirement may expand in future policy updates. This could include lowering the £5 million threshold, extending the requirement to all public sector procurement, or strengthening the content requirements.

How to Get Compliant Quickly

Creating a compliant carbon reduction plan does not require months of consultancy. With Carbonhogs, you can complete a 10-minute questionnaire about your business operations and receive a professional, PPN 006 compliant carbon reduction plan instantly.

Every plan includes Scope 1, 2, and 3 emissions calculated using DEFRA 2024 emission factors, SBTi-aligned reduction targets, specific reduction measures tailored to your business, and a publication-ready format that you can upload directly to your website.

Plans cost just £99 — a fraction of what traditional consultancies charge, with none of the waiting.