NHS Carbon Reduction Plan 2027: What Suppliers Need to Know
From 1 April 2027, NHS England replaces its current carbon reduction plan (CRP) rules with a stricter 2027 version for new procurements. Suppliers on the 2027 tier must publish a board-approved plan covering all relevant Scope 3 emissions on a global boundary. Tenders that start before that date stay on the old rules, so this is about bids you plan for 2027 onwards, not a deadline this winter.
The short version
The main change is scope. The 2027 NHS CRP asks for baseline and current emissions across Scope 1, Scope 2 and all relevant Scope 3 categories. The plan must be approved by the board and published on your website. Plans are assessed pass or fail. They are not scored or compared with each other.
Evergreen, the NHS supplier sustainability self-assessment, is a separate requirement that sits alongside the CRP. If you bid for NHS England medicines tenders you must submit one. From 1 April 2027, suppliers on that route are expected to hold a current assessment in the updated format.
This guide covers who is affected, what the rules ask for, how Evergreen fits and what to do now. It is correct as at 28 October 2026 and based on NHS England guidance and NHS Specialist Pharmacy Service (SPS) guidance. Always check the tender pack for any procurement you bid on.
Who does the 2027 NHS carbon reduction plan apply to?
The rules are tiered by contract value and type, so not every NHS supplier faces the 2027 version.
| Procurement | Requirement |
|---|---|
| Contracts of £5m a year or more (including VAT) | 2027 NHS CRP |
| New frameworks, framework agreements and dynamic markets, any value | 2027 NHS CRP, unless the owner judges it disproportionate, then 2024 CRP |
| New contracts below £5m a year and above the procurement threshold | 2024 CRP |
A few points decide whether it affects you:
- Procurements started before 1 April 2027 keep the old rules.
- For frameworks the requirement is applied at framework level, not to each call-off.
- Subcontractors are not in scope, although suppliers are expected to engage them on their emissions.
- It applies under both the Procurement Act 2023 and the Provider Selection Regime (PSR). Under PSR direct award processes A and B it is a due diligence question, not pass or fail. Under process C it is pass or fail.
- NHS trusts and integrated care boards (ICBs) bidding for other NHS contracts can use a published Green Plan. Other public bodies need a compliant CRP.
- The CRP sits on top of the minimum 10% net zero and social value weighting that has applied to NHS procurement since April 2022.
What must a 2027 NHS carbon reduction plan contain?
A 2027 plan must do six things:
- Commit to net zero by 2050 or earlier for the whole organisation, as a minimum for the supplier engaging with the NHS.
- Give baseline and current emissions for Scope 1 and 2 and all relevant Scope 3, following the GHG Protocol Scope 3 standard, which lists 15 Scope 3 categories to consider.
- Report in CO2e for the seven Kyoto Protocol gases.
- Set out the environmental management measures you can deliver during the contract.
- Be approved by the board, or a director if there is no board.
- Be signposted and published on your website.
For any Scope 3 category you judge not relevant, you must explain why. The reporting period should fall no more than 18 months before the tender notice, unless you give an acceptable explanation. Contract terms may also require annual updates.
The 2027 plan goes further than PPN 006, so meeting it also meets PPN 006. The reverse is not true.
2024 plan versus 2027 plan
| Area | 2024 CRP | 2027 NHS CRP | NHS recommends |
|---|---|---|---|
| Net zero commitment | 2050 | 2050 or earlier, whole organisation | 2045 or before |
| Geographical boundary | UK minimum, global encouraged | Global | Global |
| Scope 3 | Five categories: upstream transport, waste, business travel, commuting, downstream transport | All relevant categories under the GHG Protocol | All relevant categories |
| Target validation | Not required | Not required | Independent third-party validation |
| Offsetting | Not required | Not required | Disclose the expected share of the target met by offsetting |
The reporting entity can be the supplier or its parent, if the parent reports with a global boundary and the subsidiary is wholly owned and adopts the commitment.
Where does Evergreen fit?
Evergreen is a supplier self-assessment, updated once a year, and it is a separate requirement from the CRP. You do not resubmit it for every tender, and you can update it during the year.
Who must submit. Anyone bidding in a tender run by the NHS England Medicines Value and Access team. That covers medicines, medical technology, borderline substances, plasma derived products and homecare. New-to-market and negotiated access medicines are excluded. Subcontractors, distributors and wholesalers acting for a bidder do not have to submit. Medicines tenders run by DHSC, UKHSA, the devolved administrations and NHS procurement hubs are outside this requirement.
How it is assessed today.
- A bidder with no Evergreen submission at the selection stage is excluded from the tender.
- A bidder that submits but does not reach a level is not excluded at this time.
- Submissions are pass or fail. Bidders are not scored or ranked by level.
- NHS England says outcomes may count in future procurements. If so, the tender documents will set out how.
What changed in April 2026. The maturity criteria were updated. Level 1 now reflects the 2024 CRP. Level 2 reflects the April 2027 CRP requirements. Answers to the Level 1 questions are now mandatory to submit an assessment, but reaching Level 1 is not required.
Timeline.
- Suppliers holding a 2025/26 assessment stay eligible until it is renewed during 2026/27.
- Suppliers registering from 1 April 2026 complete the 2026/27 format.
- From 1 April 2027, suppliers on this route must hold a current assessment in the updated format.
A subsidiary can report at entity, regional or global level, as long as the figures fully cover the bidding entity’s targets and emissions and the level is used consistently. The submission must be recorded under the bidding entity’s supplier record. Other NHS buyers may use Evergreen differently, so check the tender pack. The NHS SPS Evergreen FAQ has the detail.
Not sure where you stand? Check your readiness with our free NHS Evergreen readiness check. It takes about five minutes and is indicative only.
What if you do not have full supply chain data yet?
NHS England accepts that many suppliers cannot get full supply chain data in the first year, and the guidance builds in room for that.
- Estimates are allowed. Under the GHG Protocol you can estimate Scope 3, for example with spend-based methods using carbon conversion factors.
- First-year gaps can pass. For FY2027/28 tenders, a supplier with gaps in the extra Scope 3 data can still pass with an acceptable explanation and a plan to report from the following year. Contract terms may record that commitment.
- Exceptional circumstances. An SME or VCSE with an acceptable reason for not gathering emissions data can submit what it has, explain the gap and set out the steps it will take to improve. The buyer judges this case by case.
- Light-touch frameworks. Where a CRP would be a barrier to entry for SMEs, a framework owner can apply a lighter requirement, but only if market engagement supports that.
This is a route for honest gaps, not a way round the requirement. Buyers expect a published plan and a clear commitment to improve the data.
Seven steps to take now
- Find your tier. Check the value and type of the NHS contracts and frameworks you plan to bid for, and read the tender pack for the CRP requirement it names.
- Choose your reporting entity and boundary. Decide whether the supplier or its parent reports, and apply a global boundary.
- Confirm your net zero commitment. 2050 or earlier is required for the 2027 tier. 2045 is recommended.
- Collect the data. Export 12 months of your purchase ledger by supplier and category, and gather energy bills and fleet records. This is the base for a spend-based Scope 3 estimate.
- Screen the 15 Scope 3 categories. Mark which are relevant and write down why you excluded the others.
- Draft and publish the plan. Follow the structure of the PPN 006 CRP template, get board or director approval and publish it on your website.
- Submit or renew Evergreen. If you bid for NHS England medicines tenders, diary the annual renewal and keep your evidence, owners and review dates in one place.
The earlier you start step 4, the more of the 2027 requirement you can meet with real data rather than estimates.
Need help with your plan or Scope 3 data?
If you want a second pair of eyes on your carbon reduction plan or your Scope 3 data, we can help. SBS is a BSI and NQA Associate Consultant for ISO 14064-1, ISO 14068 and PAS 2080, and we help UK SMEs measure, reduce and report their emissions. See our compliance service and Net-Zero Program, or browse our wider Net-Zero services and latest news.
Frequently asked questions
When do the 2027 NHS carbon reduction plan rules start?
From 1 April 2027. The 2027 NHS carbon reduction plan requirements replace the previous requirements for new procurements. Procurements that started before 1 April 2027 stay on the old rules.
Is a PPN 006 plan enough from April 2027?
It is accepted for the 2024 tier. The 2027 tier asks for all relevant Scope 3 emissions and a global boundary, so most PPN 006 plans will need extending.
What is the difference between a carbon reduction plan and Evergreen?
They are separate requirements. A carbon reduction plan is a published plan with emissions data and a net zero commitment. Evergreen is an annual supplier self-assessment, required from anyone bidding in an NHS England Medicines Value and Access tender.
Are Evergreen levels scored in tenders?
Not at present for NHS England medicines tenders. The assessment is pass or fail, and any future scoring would be set out in the tender documents.
Are we covered if we are only a subcontractor?
Subcontractors are not in scope of the carbon reduction plan requirements, and a subcontractor acting for a bidder does not have to submit an Evergreen assessment. Your main supplier may still ask for your emissions data.
Can our parent company’s plan cover us?
Yes, if the bidding entity is wholly owned, adopts the commitment, can apply the measures in the contract, and the plan is published on its website.
Is net zero by 2045 mandatory?
No. The 2027 tier requires net zero by 2050 or earlier. NHS England recommends 2045 or before.
Do tenders already under way change?
No. Procurements started before 1 April 2027 follow the previous requirements.
Sources
- NHS England: 2027 NHS carbon reduction plan requirements for the procurement of NHS goods, services and works
- NHS SPS: Answers to frequently asked questions about Evergreen Assessments
- UK Government: PPN 006, taking account of carbon reduction plans in the procurement of major government contracts
- GHG Protocol: Corporate Value Chain (Scope 3) Standard
Information checked against NHS England and NHS SPS guidance on 28 October 2026. Rules and tender packs can change. Check the current guidance and the tender documents for any procurement you bid on, and take specialist advice where needed.