Last Updated on 10/06/2026 by Sarah Sarsby
NHS England (NHSE) has published new guidance setting out the next milestone of the NHS Net Zero Supplier Roadmap, with new supplier requirements due to take effect from 1 April 2027.
From April 2027, the NHS will implement new proportionate requirements for suppliers to publicly report targets and emissions, and publish a Carbon Reduction Plan (CRP) for all relevant global scope 1, 2, and 3 emissions. The requirements form part of the NHS’s wider commitment to reaching net zero by 2045, as set out in ‘Delivering a Net Zero National Health Service’.
The BHTA encourages members that supply, or intend to supply, goods, services, or works to the NHS to review the new guidance and begin preparing for the April 2027 requirements.
NHSE has published two documents to support suppliers and procurement teams ahead of the April 2027 milestone: ‘2027 NHS Carbon reduction plan requirements for the procurement of NHS goods, services and works’, and ‘Market sounding findings: net zero supplier requirements from April 2027’.
From 1 April 2027, the new guidance replaces the current carbon reduction plan guidance and associated requirements, which should continue to be followed for in-scope procurements commenced before that date.
The accompanying market sounding findings explain how supplier and stakeholder feedback informed the final policy approach, including changes to the net zero target date, target validation, and offsetting requirements.
The requirements apply to the commissioning and purchasing of goods, services, and works by in-scope NHS organisations, including where a third party acts on their behalf.
To ensure the requirements are applied in a proportionate and relevant way, the policy will follow a two-tiered approach.
The 2027 NHS Carbon Reduction Plan (2027 NHS CRP) tier will apply to high-value procurements of £5 million per annum and above, including VAT, and all new frameworks operated by in-scope organisations, irrespective of the value of the framework contract, where relevant and proportionate to the framework. A 2027 NHS CRP covers all scope 1, scope 2, and relevant scope 3 emissions.
The 2024 CRP tier will apply to lower-value procurements below £5 million per annum, including VAT, and above the relevant published procurement thresholds. A 2024 CRP covers all scope 1 and scope 2 emissions, and a subset of scope 3 emissions. NHSE states that this reflects the existing CRP content in place since April 2023 for the NHS and aligns with the CRP content defined in PPN 006.
A compliant CRP must set out the supplier’s baseline and current emissions, environmental management measures, and planned actions to achieve net zero. It must also be approved by the board, or by a company director if no board is in place, and clearly signposted and published on the supplier’s website.
CRPs will be assessed on a pass/fail basis and will not be scored or compared against each other; suppliers that do not meet the minimum requirements may be unable to proceed, except in exceptional circumstances.
Annex 2 of the guidance compares the 2024 CRP and 2027 NHS CRP requirements. In summary, the 2027 NHS CRP expands the requirements by applying a global geographical boundary and requiring suppliers to report scope 1, scope 2, and all relevant scope 3 emissions in line with the GHG Protocol Corporate Value Chain (Scope 3) Standard. The NHS also recommends that suppliers work towards a 2045 net zero target, obtain independent third-party target validation, and disclose the expected proportion of their net zero target that will rely on offsetting.
Suppliers can access a range of support to help them meet the requirements. This includes NHSE webinars on the new requirements, taking place on 16 June at 11am and 23 June at 2pm. Future webinars and on-demand support videos are also available through the NHSE Net Zero and Sustainable Procurement Team webinar programme.
Additional support is available through NHSE’s Sustainable Supplier Accelerator Programme, which provides guidance on areas such as carbon accounting and target setting. Suppliers can also use resources from the UK Business Climate Hub, including free tools and calculators.
NHSE is also encouraging suppliers to use the NHS Evergreen Sustainable Supplier Assessment to check the content of their Carbon Reduction Plan against the policy requirements using the maturity levels.