PPN 006 Explained: What UK Tender Evaluators Actually Check in Your Carbon Reduction Plan

If you bid for large central government contracts, sooner or later you will hit a requirement that trips up even experienced bidders: the Carbon Reduction Plan, demanded under Procurement Policy Note 006 (commonly written as 'PPN 006', and known as PPN 06/21 under the previous procurement rules).

Here is what catches people out. A Carbon Reduction Plan is not a 'nice to have' sustainability statement that earns you a few extra marks. It is a pass/fail condition of participation. Get it wrong and your bid can be excluded before an evaluator reads a single word of your quality response — regardless of how strong your price, your method statement or your track record might be.

The frustrating part is that most rejections have nothing to do with a company's actual environmental performance. They come down to formatting, missing emissions categories, an out-of-date plan, a plan that isn't published, or a signature from the wrong person. These are entirely avoidable mistakes.

This guide explains exactly what evaluators check when they assess your Carbon Reduction Plan against PPN 006 (and its predecessor, PPN 06/21). You will learn the specific compliance tests, the emissions you must report, the common reasons plans get rejected, and a checklist you can use before you submit.

What is PPN 006 (and how it relates to PPN 06/21)?

A Procurement Policy Note is official guidance issued by the Cabinet Office that tells public sector buyers how to run their procurements. PPN 006, titled 'Taking account of Carbon Reduction Plans in the procurement of major government contracts', sets the rules for procurements run under the Procurement Act 2023. It applies to relevant procurements advertised on or after 24 February 2025.

Its predecessor, PPN 06/21, introduced the same requirement under the old Public Contracts Regulations 2015 and took effect on 30 September 2021 (see our short PPN 06/21 explainer for the predecessor in brief). The 'PPN 006' and 'PPN 06/21' labels you will see across tender portals and forum posts refer to the same policy at heart — the numbering simply changed when the Procurement Act came into force.

The policy does one thing: it requires suppliers bidding for major government contracts to publish a Carbon Reduction Plan (CRP) that confirms a commitment to achieving Net Zero by 2050 and sets out the environmental management measures the supplier has in place. The aim is to use the government's purchasing power to drive decarbonisation through its supply chain.

Crucially, the requirement is applied as a condition of participation (a selection-stage requirement under the old rules) and is assessed on a pass/fail basis. You either provide a compliant plan or you don't. This is what makes it so different from social value, which is scored.

PPN 006 vs PPN 06/21: which one applies to your tender?

The Procurement Act 2023 came into force on 24 February 2025 and replaced the Public Contracts Regulations 2015 for new procurements. As part of that transition, the Cabinet Office reissued the Carbon Reduction Plan guidance under the new PPN 006 number. In practice, the two notes run in parallel during the transition:

The good news for bidders: the substance is essentially the same. The same Net Zero commitment, the same emissions scopes, the same template and the same pass/fail logic carry across. What changes is the legal framework the requirement sits within — under the Act it is described as a 'condition of participation', whereas under the old rules it was a 'selection criterion'.

Practical takeaway: always check the tender documents to see which note the buyer references, then make sure your published plan and your bid response use the matching terminology. If you are bidding across both regimes — which most active suppliers are during this transition period — keep your published CRP generic enough to satisfy both, and tailor only the covering references in each bid.

Does PPN 006 actually apply to your bid?

Before you spend time on this, confirm the requirement is genuinely in scope. PPN 006 applies where all of the following are true:

• The buyer is an in-scope organisation — all central government departments, their executive agencies, and non-departmental public bodies. (The wider public sector, such as local councils and universities, is not automatically caught, though many adopt the requirement voluntarily.)
• The contract has an estimated value above £5 million per year, including VAT, over its lifetime.
• The procurement is for goods, services or works (other than certain special regime contracts).

A common point of confusion: the £5 million threshold is about the contract's value, not your company's turnover. A small business bidding within a consortium, or as a subcontractor on a major contract, can absolutely find itself asked to produce a Carbon Reduction Plan even with modest revenue.

It is also worth noting that the NHS runs its own, separate Carbon Reduction Plan requirement for its procurements under the NHS Net Zero Supplier Roadmap, with its own thresholds. So even where PPN 006 doesn't strictly bind a particular buyer, an equivalent CRP is fast becoming a baseline expectation across UK public procurement — having one ready is increasingly non-negotiable.

What a compliant Carbon Reduction Plan must contain

This is the heart of the matter. PPN 006 sets out specific, mandatory content. A compliant Carbon Reduction Plan must:

• Confirm the supplier's commitment to achieving Net Zero by 2050 (at the latest) for its UK operations.
• Report its current emissions across the required scopes, expressed in tonnes of CO₂ equivalent (CO₂e).
• Use the standard reporting template published alongside PPN 006, or follow its format and headings exactly.
• Be published and clearly signposted on the supplier's UK website, accessible to the public without a login — with the link placed prominently, ideally on the homepage.
• Be reviewed and updated regularly — at least annually, and within six months of the organisation's financial year-end.
• Be signed off by a director (or equivalent), and clearly state that board (or equivalent management body) approval has been given, with the date of approval.
• Reflect recognised emissions reporting standards, consistent with the GHG Protocol Corporate Accounting and Reporting Standard.
• Set out the environmental management measures and carbon reduction projects the organisation has in effect, ideally with quantified savings.

Miss any one of these and you risk a fail. The template, the publication, the review date and the sign-off are the four that catch people most often — and all four are administrative rather than environmental. You can be a genuinely low-carbon business and still fail on a missing director's sign-off.

Understanding Scope 1, 2 and 3 emissions in plain English

The emissions reporting is where bidders most often slip up, partly because the terminology sounds more intimidating than it is. Here is the plain-English version.

Scope 1 — emissions you create directly

These are emissions from sources your business owns or controls: fuel burned in your company vehicles and vans, gas burned in boilers to heat your premises, and fuel for on-site plant and machinery. All Scope 1 emissions must be reported.

Scope 2 — emissions from the energy you buy

These are the indirect emissions created when someone else generates the electricity, heat or steam you purchase and use. For most SMEs this means the electricity you buy for your offices, depots and sites. All Scope 2 emissions must be reported.

Scope 3 — a defined subset of your value chain

Scope 3 is the big one and, in full, it covers everything from the products you buy to how customers use what you sell. Crucially, PPN 006 does not require you to report all of Scope 3. It requires a specific, defined subset of five categories:

• Upstream transportation and distribution (goods being delivered to you).
• Waste generated in your operations.
• Business travel.
• Employee commuting.
• Downstream transportation and distribution (your products being delivered onwards).

This distinction matters enormously. Many SMEs panic and assume they must measure their entire supply chain footprint. You don't — for PPN 006 you must report all of Scope 1, all of Scope 2, and those five Scope 3 categories. Reporting beyond that is encouraged and looks good, but the five categories are the compliance line.

What evaluators actually check: the pass/fail tests

When an evaluator opens your Carbon Reduction Plan, they are not grading your environmental ambition. They are working through a compliance checklist. Understanding their mindset is the single biggest advantage you can have. Here is, in effect, what they tick off:

• Is there a plan at all, and is it the right organisation's? The plan must be in the name of the bidding entity — the legal entity submitting the tender. A group parent company's plan does not automatically cover a subsidiary that is the actual bidder.
• Is it published and publicly accessible? They will follow the URL. If the plan is behind a login, returns a 404, or only exists as an attachment in your bid, that can fail. It must be clearly signposted on your public-facing UK website.
• Is it current? They check the reporting period and the date of board approval. A plan that hasn't been reviewed since well before your last financial year-end raises an immediate red flag — it should be refreshed at least annually and within six months of your year-end.
• Does it confirm the 2050 Net Zero commitment? They look for an explicit statement. Implying it is not enough; the words need to be there.
• Does it report the required emissions scopes? They check that all Scope 1, all Scope 2 and the five required Scope 3 categories are present with figures in CO₂e. A plan that quietly omits employee commuting or waste is incomplete.
• Is it signed off correctly? They check for a named director (or equivalent), a statement that the board has approved the plan, and the date of approval. An unsigned plan, or one approved by a junior member of staff, is a frequent fail.
• Does it follow the required template and headings? They check the structure against the published template. Free-form sustainability reports that don't map to the template create doubt — and doubt at the pass/fail stage rarely goes the bidder's way.

The theme across all seven: most checks are binary and administrative. That is genuinely good news, because it means compliance is fully within your control. You are not being marked subjectively. You either tick the box or you don't.

This is also exactly where a tool like BidPilot earns its keep. BidPilot reads the tender and flags mandatory pass/fail conditions of participation — like the PPN 006 Carbon Reduction Plan requirement — before you commit time to writing, so the CRP never becomes the thing you discover 48 hours before the deadline.

Worked example: a compliant CRP for an SME

Consider Greenfield Facilities Ltd, a 40-person facilities-management SME bidding as a subcontractor on a £6m-per-year central government estates contract. Here is how they pass cleanly:

• Reporting period: They report against a defined financial year and keep the same reporting period throughout the document.
• Scope 1 (45 tCO₂e): Diesel for their van fleet and gas heating at their depot.
• Scope 2 (28 tCO₂e): Grid electricity across office and depot, using their supplier's published emissions factor.
• Scope 3 (62 tCO₂e): Deliveries in and out (supplier and courier data), operational waste (skip provider's reports), business travel (mileage claims), and employee commuting (a short staff survey).
• Reduction measures: Switching the van fleet to electric over three years, a cycle-to-work scheme, and a move to a renewable electricity tariff — each with an estimated saving.
• Governance: The plan states it has been reviewed and approved by the board, names the Managing Director who signed it, gives the approval date, and is published on the company website, linked from the homepage.

Notice what made this work: none of the data was perfect or expensive to gather. Mileage claims, a staff survey and a skip provider's report are enough to produce a defensible figure. Completeness beats precision at the pass/fail stage.

Pre-submission checklist

Run through this before every bid that cites PPN 006 or PPN 06/21:

• ☐ The plan is in the name of the exact legal entity submitting the bid.
• ☐ It is published and clearly signposted on our public UK website, with a working link (ideally from the homepage).
• ☐ It has been reviewed and updated within the last 12 months and within six months of our financial year-end.
• ☐ It explicitly confirms commitment to Net Zero by 2050.
• ☐ It reports all Scope 1 emissions in CO₂e.
• ☐ It reports all Scope 2 emissions in CO₂e.
• ☐ It reports all five required Scope 3 categories (upstream transport, waste, business travel, commuting, downstream transport).
• ☐ It follows the published template structure and headings.
• ☐ It is signed off by a director (or equivalent) and states board approval with the date.
• ☐ It lists environmental management measures, ideally with quantified savings.
• ☐ The tender references are matched to the correct note (PPN 006 vs PPN 06/21).

Common mistakes that get plans rejected

• Treating it as scored, not pass/fail. Bidders polish the narrative and forget the compliance basics. Evaluators don't award marks for eloquence here — they check boxes.
• Letting the plan fall out of date. A plan that hasn't been reviewed since well before your last year-end risks a fail. Diarise a refresh within six months of your financial year-end, and at least annually.
• Omitting Scope 3 categories. Reporting Scope 1 and 2 but skipping commuting or waste is the single most common incompleteness. All five required categories must appear.
• Wrong signatory or missing board approval. A sustainability officer signing instead of a director, or no statement that the board approved the plan and when.
• Plan not published, or behind a login. Submitting the CRP only as a bid attachment, with no signposted public version, fails the accessibility test.
• Using a parent company's plan for a subsidiary bidder. The plan must match the bidding entity's legal name.
• Free-form sustainability report instead of the template. A glossy ESG brochure that doesn't follow the required structure creates doubt and risks a fail.
• Leaving it to the last minute. A compliant CRP, properly published and board-approved, takes time to produce. Discovering the requirement two days before the deadline is how good companies lose winnable contracts.

Conclusion

The Carbon Reduction Plan requirement under PPN 006 (and PPN 06/21 before it) feels daunting, but it rewards diligence rather than ambition. Almost every rejection comes down to administrative detail — a plan that hasn't been refreshed, a missing emissions category, the wrong signatory, a plan that isn't published — and every one of those is avoidable.

Treat it for what it is: a pass/fail condition of participation with a clear, finite checklist. Build a complete, board-approved, properly published plan once, keep it current with a review within six months of your year-end, and you turn a recurring source of bid anxiety into a box you tick with confidence.

Related guides: How to analyse a UK tender document, what is pass/fail in procurement, understanding tender evaluation weighting, and common tender disqualification reasons.

Authoritative sources

• GOV.UK — PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts.
• GOV.UK — PPN 006: Technical standard for the Completion of Carbon Reduction Plans.
• GOV.UK — Procurement Policy Note 06/21 (predecessor guidance).
• GHG Protocol — Corporate Accounting and Reporting Standard.
• NHS England — Carbon reduction plan requirements for the procurement of NHS goods, services and works.