Carbon Reduction Plans in 2026: What UK Businesses Need to Know About PPN 006
PPN 006 replaced PPN 06/21 for procurements commenced from 24 February 2025. Here is what a compliant Carbon Reduction Plan must contain, who must sign it, and why there is no minimum percentage target.
Zero to Green Editorial
If your organisation bids for central government work, the rules you may have learned as “PPN 06/21” have moved on. For procurements commenced on or after 24 February 2025, the date the Procurement Act 2023 and the Procurement Regulations 2024 took effect, the applicable policy is PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts.
What the evidence says
- Government policy: PPN 006 applies to all central government departments, their executive agencies and non-departmental public bodies.
- Government policy: it applies to relevant contracts with an estimated value above £5 million per year including VAT, unless applying it would not be relevant or proportionate.
- Government policy: the technical standard requires a commitment to Net Zero by 2050 at the latest. It does not set a minimum percentage reduction target.
- Zero to Green interpretation: the practical bar is evidence and consistency, not ambition theatre.
What replaced PPN 06/21?
PPN 06/21 was issued in June 2021. Its successor, PPN 006, was published on 17 February 2025 and updated in July 2025. The underlying idea is unchanged: suppliers bidding for major central government contracts must publish a Carbon Reduction Plan showing their UK carbon footprint and their commitment to Net Zero. What changed is the legal framework underneath it, the Procurement Act 2023, and the numbering. Procurements commenced before 24 February 2025 continue under the old note.
Which contracts are in scope?
PPN 006 applies when in-scope organisations award public contracts for goods, services or works, other than special regime contracts, with an estimated contract value above £5 million per year including VAT. It also bites on frameworks and dynamic markets where individual contracts awarded are expected to exceed that threshold. Contracting authorities may disapply it where it would not be relevant to the contract or proportionate to its nature, complexity and cost.
Is a 25% reduction target required?
No. This is the single most common misunderstanding, and it is worth stating plainly: the PPN 006 technical standard contains no mandated minimum percentage cut. What it requires is that, within the Carbon Reduction Plan, suppliers “must confirm their organisational commitment to achieving Net Zero by 2050 at the latest”, report their emissions to the specified standard, and describe the measures they are taking. A 25% figure is a reasonable ambition benchmark that some buyers and consultants use, it is not a compliance threshold, and presenting it as one misleads suppliers.
What must the Carbon Reduction Plan report?
The plan is a summary document, not a replacement for full carbon accounting. It must cover a single reporting year and include:
- All Scope 1 and Scope 2 emissions for the organisation’s UK operations.
- A defined subset of Scope 3 emissions, five categories: upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution.
- The seven Kyoto Protocol greenhouse gases, measured in tonnes of carbon dioxide equivalent (tCO2e) using the UK Government conversion factors.
- Emissions reduction measures already taken and planned, plus the projected trajectory.
- A confirmed commitment to Net Zero by 2050 or sooner.
Reporting should follow the GHG Protocol Corporate Standard and current UK environmental reporting guidance. There is no requirement to have the footprint independently audited, although ISO 14064-3 and ISAE 3410 are widely used where assurance is wanted.
Who signs the plan, and where does it go?
Two governance steps are easy to miss and both are explicit in the technical standard:
- The plan should state that board of directors approval (or the equivalent management body; for an LLP, the members) has been given, with the date of approval.
- The plan must be signed off by a director or equivalent, or a designated member for an LLP, giving their name, job title and date. A physical signature is not needed, but the plan must clearly state that it has been signed.
Publication matters too. Suppliers should publish the latest plan on their UK website with the link in a prominent place on the homepage, keep previous versions available so progress can be tracked, and, if they have no website, supply a written copy to anyone who asks within 30 days.
How often must it be updated?
Annually. The technical standard asks suppliers to review and update the plan within six months of their financial year-end, using a consistent reporting period throughout the document.
A practical order of work
- Fix your reporting year and gather Scope 1 and 2 data for UK operations.
- Collect the five required Scope 3 categories, travel and commuting data usually take longest.
- Convert everything to tCO2e with the current government factors.
- Write the reduction measures section around things you can evidence, not aspirations.
- Take it to the board, record the approval date, get a director’s sign-off.
- Publish it, link it from the homepage, and diarise next year’s update.
Sources and methodology
- PPN 006: Taking account of Carbon Reduction Plans, Cabinet Office, published 17 February 2025, updated 10 July 2025.
- PPN 006: Technical standard for completion of Carbon Reduction Plans, Cabinet Office, updated February 2025.
Quoted requirements are taken directly from the technical standard. Where this article offers a view on sequencing or interpretation it is labelled as our own.
Last reviewed: 30 August 2026.
Zero to Green helps UK organisations build and publish a Carbon Reduction Plan alongside a public commitment. See how we verify organisations, browse the public pledge directory, or create your pledge.