If you bid for major UK government contracts, PPN 006 — which replaced PPN 06/21 in February 2025 — is the reason you're being asked for a Carbon Reduction Plan. What it requires is unchanged. Here it is in plain English, with the transition rules and how to produce a plan that passes.
PPN 006 or PPN 06/21 — which one applies to you?
Both are live, and which one governs a given tender depends on when that procurement started.
Procurement Policy Note 06/21 took effect on 30 September 2021. PPN 006 replaced it for procurements advertised on or after 24 February 2025, the date the Procurement Act 2023 and the Procurement Regulations 2024 came into force.
| If your procurement | Then it is governed by |
|---|---|
| Commenced before 24 February 2025 | PPN 06/21, through to the end of the contract |
| Was advertised on or after 24 February 2025 | PPN 006 |
What changed: almost nothing. GOV.UK is explicit that "the substantive obligation introduced by PPN 06/21, now PPN 006, remains the same under the Act", and that the update "does not constitute a change in policy". What a compliant Carbon Reduction Plan must contain is identical under both.
The one substantive difference is how it is applied. Under PPN 06/21 the CRP sat in selection criteria; under PPN 006 it is a condition of participation. Either way it is pass/fail and assessed before the rest of your bid is read — no compliant plan, no bid.
One caution if you are checking a specific tender: GOV.UK uses "commenced" in some places and "advertised" in others without reconciling the two, so on a borderline date confirm the position with the buyer rather than inferring it.
It sits alongside the other carbon frameworks a contractor meets — PAS 2080 for how carbon is managed through delivery, and SECR for the statutory disclosure in your annual accounts — but PPN 006 is the one that gates whether you can bid at all.
Which contracts and suppliers does it apply to?
PPN 006 applies to procurements carried out by central government departments, their executive agencies, and non-departmental public bodies for contracts with an estimated value above £5 million per year, including VAT. The figure is the advertised contract value averaged over the life of the contract, so a £21m four-year contract is in scope and a £19m four-year contract is not.
Three things catch construction firms out:
- The threshold includes VAT. "£5 million excluding VAT" is one of the most commonly repeated errors about this requirement, and at the margin it decides whether a contract is in scope at all. GOV.UK states the figure including VAT.
- It's about your organisation, not the project. The CRP reports your company's total emissions, not just the emissions of the contract you're bidding for.
- It cascades down supply chains. Even if you never bid for central government directly, a main contractor that does will increasingly ask you for the same emissions data, so the requirement reaches far beyond the £5m threshold.
What must a carbon reduction plan include?
A compliant CRP has to do five things:
- Confirm a commitment to Net Zero — a clear statement that your organisation is committed to achieving Net Zero carbon emissions in the UK by 2050.
- Report your baseline and current emissions — your Scope 1 and Scope 2 emissions in full, plus a defined subset of Scope 3 (see below).
- Set out your reduction measures — the environmental management measures and carbon-reduction projects you have in place or plan to introduce.
- Be published on your UK website and kept up-to-date, reviewed and republished at least annually.
- Be signed off at board or director level — the plan must be formally approved by a director (or equivalent).
The Scope 3 categories you must measure
PPN 006 does not require full Scope 3 reporting, but it does mandate a specific subset. As a minimum, your CRP must include these Scope 3 categories:
- Business travel
- Employee commuting
- Upstream transportation and distribution
- Waste generated in operations
- Downstream transportation and distribution
All figures should be calculated using the UK government's DEFRA greenhouse gas conversion factors for the reporting year and reported in tonnes of CO₂e.
Scope quick refresher. Scope 1 = emissions you burn directly (site diesel, plant, company vehicles). Scope 2 = purchased energy (grid electricity). Scope 3 = everything else in your value chain (materials, subcontractor transport, waste) — see our full guide to Scope 1, 2 and 3 emissions in construction. PPN 006 requires Scope 1, Scope 2, and the five Scope 3 categories above.
Common mistakes that fail a bid
- An out-of-date plan. A CRP published two years ago and never refreshed is non-compliant; it must be reviewed and republished at least annually.
- Missing the Scope 3 subset. Reporting only Scope 1 and 2 is the most common failure. The five Scope 3 categories are mandatory, not optional.
- No director sign-off. The plan has to be formally approved at board level and said so.
- Not actually published. The CRP must be publicly available on your own website. A PDF emailed only to the buyer doesn't meet the requirement.
- Emissions that don't add up. Figures that aren't traceable to a recognised methodology (DEFRA factors) invite challenge.
| Fails the bid | Passes the bid |
|---|---|
| Published once, never refreshed | Reviewed and republished at least annually |
| Scope 1 and 2 only | Scope 1, 2, and the five mandatory Scope 3 categories |
| No director sign-off | Formally approved at board or director level |
| Emailed to the buyer only | Publicly available on your own UK website |
| Figures with no stated methodology | Calculated on current DEFRA conversion factors |
How to produce a compliant Carbon Reduction Plan
The workflow is the same every year:
- Measure. Capture fuel, energy, materials, transport, and waste, and convert them to CO₂e using the current DEFRA factors.
- Report. Split the total into Scope 1, Scope 2, and the required Scope 3 categories, against a fixed baseline year.
- Commit. State your Net Zero-by-2050 commitment and the specific measures you're taking to reduce emissions.
- Approve and publish. Get the director's sign-off and publish the plan on your website.
- Repeat annually. Update the numbers and republish each year so it never lapses.
The hard part isn't the template; it's keeping accurate emissions data throughout the year so the numbers are ready when a tender lands — the same evidence that helps you answer the wider carbon questions in winning construction tenders on carbon.
Keeping those numbers current all year is what construction carbon reporting software is built for, so producing a Carbon Reduction Plan is an export rather than a scramble.