NHS England has published new, statutory guidance to help integrated care boards (ICBs), NHS trusts and foundation trusts update their green plans for the next three-year cycle. Green plans need to be board approved and published by 31 July 2025. Here’s what you need to know.
2025 green plan guidance: specific asks and deadlines
The previous green plan guidance came out in 2021, not long after the NHS committed to net zero. As you might expect, the 2025 update is much more developed. It outlines 6 focus areas: workforce & leadership, clinical transformation, digital transformation, medicines, transport/travel and estates/facilities.
However, in terms of its “asks”, this guidance is far more prescriptive than its predecessor. For example, the 2021 guidance suggested heat decarbonisation as an area to explore. By contrast, the 2025 guidance requires trusts to develop full heat decarbonisation plans and phase out fossil-fuel heating systems by 2032.
Similarly, where the previous guidance asked trusts to “explore interventions” to reduce travel/transport emissions, the new guidance says trusts must now develop a sustainable travel plan by December 2026 and commit to zero-emission only vehicles from December 2027 onwards.
There are much clearer leadership responsibilities too. For example, trusts are asked to identify a net-zero clinical lead, with formal links into the board.
New: A range of metrics to track progress
The guidance says that in the short term, it’s difficult to use emissions alone as an indicator of progress towards net zero targets, due to lags in data availability, limitations of spend-based calculations and factors over which the NHS has no control, such as the rate of national electricity grid decarbonisation.
So, it’s produced a set of suggested emissions-based and non-emissions-based metrics to support organisations to track progress. We’ve outlined those below:
Focus area | Metric | For use by | Data source |
Workforce | Named board-level lead for green plan delivery | Trusts and systems | |
Medicines | Emissions (tCO2e) and volume (litres) of nitrous oxide by trust | Trusts and systems (aggregate of trust data) | |
Medicines | Emissions (tCO2e) and volume (litres) of nitrous oxide and oxygen (gas and air) by trust | Trusts and systems (aggregate of trust data) | |
Medicines | Average inhaler emissions per 1,000 patients | Systems (aggregate of primary care data) | |
Medicines | Mean emissions of Short-acting beta-2 agonists (SABAs) inhalers prescribed | Systems (aggregate of primary care data) | |
Medicines | % of non-SABA inhalers that are MDIs | Systems (aggregate of primary care data) | |
Travel and transport | % of owned and leased fleet that is ultra-low emission vehicle (ULEV) or zero-emission vehicle (ZEV) | Trusts and systems (aggregate of trust data) | |
Travel and transport | Total fleet emissions | Trusts and systems (aggregate of trust data) | |
Travel and transport | Does the organisation offer only ZEVs in its salary sacrifice scheme | Trusts and systems (aggregate of trust data) | |
Travel and transport | Does the organisation operate sustainable travel-related schemes for staff (for example, salary sacrifice cycle-to-work) | Trusts and systems (aggregate of trust data) | |
Estates and facilities | Emissions from fossil-fuel-led heating sources | Trusts and systems (aggregate of trust data) | |
Estates and facilities | Number of oil-led heating systems | Trusts and systems (aggregate of trust data) | Estates Return Information Collection/Greener NHS dashboard (from Q4 24/25) |
Estates and facilities | % of gross internal area covered by LED lighting | Trusts and systems (aggregate of trust data) | Estates Return Information Collection/Greener NHS dashboard (from Q4 24/25) |
Estates and facilities | % of sites with a heat decarbonisation plan | Trusts and systems (aggregate of trust data) | Estates Return Information Collection/Greener NHS dashboard (from Q4 24/25) |
Supply chain and procurement | Inclusion of Carbon Reduction Plan and Net Zero Commitment requirements in all relevant procurements | Trusts and systems | |
Supply chain and procurement | Inclusion of requirements for a minimum 10% net zero and social value weighting in procurements, including defined KPIs | Trusts and systems | |
Food and nutrition | Weight (tonnes) of food waste, with further break down by spoilage, production, unserved and plate waste | Trusts and systems (aggregate of trust data) | |
Adaptation | Number of overheating occurrences triggering a risk assessment (in line with trust’s “heatwave” plan) | Trusts and systems (aggregate of trust data) | |
Adaptation | Number of flood occurrences triggering a risk assessment | Trusts and systems (aggregate of trust data) |
Climate change adaptation
The new guidance also places much greater emphasis on preparedness for extreme weather events caused by climate change. It requires trusts to factor in the effects of climate change when making infrastructure decisions and designing new facilities, including enhancements like improved green spaces, drainage systems and passive cooling solutions.
Advice and support
Sustainable Energy First is supporting trusts with the refresh of their green plans, ahead of the 31 July 2025 deadline. For no-obligation advice on the new green plan guidance, get in touch via the form below.
For more advice on your NHS green plan, get in touch with Sustainable Energy First’s ESOS Lead Assessors.
