Organisations bidding for NHS and public sector contracts are facing significant changes to Carbon Reduction Plan (CRP) requirements over the coming years. During our recent webinar, our Climate Action team explored what these changes mean, why they matter, and how organisations can prepare now rather than rushing to react later.

What’s Changing?

While current CRP requirements focus on Scope 1, Scope 2 and a limited number of Scope 3 emissions categories, the NHS roadmap points towards more comprehensive reporting from April 2027, particularly for higher-value contracts and framework agreements. This is expected to include all relevant Scope 3 emissions, wider organisational boundaries and stronger evidence of progress against reduction targets.

The changes are being driven by the NHS’s ambition to reduce emissions across its entire supply chain, not just within its own operations.

Key Takeaways from the Webinar

1. Your CRP Needs to Be More Than a Compliance Document

Many organisations currently treat their Carbon Reduction Plan as an annual procurement requirement. However, future expectations are likely to focus increasingly on the evidence behind the plan, including:

• Data quality and traceability
• Documented methodologies
• Clear ownership and governance
• Evidence of progress over time
• A credible decarbonisation roadmap

Buyers are expected to look beyond the published document and assess the robustness of the processes supporting it.

2. Scope 3 Will Become Increasingly Important

For many organisations, Scope 3 emissions represent the largest proportion of their carbon footprint. Future NHS requirements are expected to move beyond the current five prescribed categories and require organisations to consider all relevant value-chain emissions.

This could include:

• Purchased goods and services
• Capital goods
• Leased assets
• Use of sold products
• End-of-life treatment
• Other material supply chain activities

Not every category will apply to every organisation, but each category should be considered and any exclusions clearly justified.

3. Progress Matters as Much as the Commitment

A commitment to achieve net zero by 2050 is no longer enough on its own.

Organisations should be prepared to demonstrate:

• Interim milestones
• Year-on-year progress
• Planned reduction activities
• Future emissions trajectories
• Ownership of delivery actions

Increasingly, procurement teams want to see how emissions will reduce over time, not just where they stand today.

4. Data Governance Should Start Now

One of the strongest messages from the webinar was the importance of establishing data ownership and collection processes early.

Preparing for future requirements means:

• Identifying data owners
• Mapping internal data sources
• Engaging suppliers where required
• Documenting methodologies
• Creating an auditable evidence trail

Organisations that start this work now will be significantly better positioned when requirements tighten.

Why This Matters Beyond the NHS

Although the NHS is leading the way, procurement requirements often influence wider public sector expectations. Organisations that supply into local government, education, housing and other public sector bodies should pay close attention to the direction of travel.

The shift is clear: carbon reporting is moving from a compliance exercise towards a demonstration of credible carbon management and measurable decarbonisation progress.

Watch the Webinar