NHS requirements for suppliers are changing again. From April 2027, higher-value NHS procurements and new NHS frameworks will be subject to expanded Carbon Reduction Plan requirements, including reporting on relevant Scope 3 emissions.
If your business plans to supply goods or services to the NHS, what do you need to know?
How it currently works
NHS England currently uses two tiers of requirements for suppliers.
For higher-value procurements of £5m or more per annum, suppliers must provide a Carbon Reduction Plan.
For lower-value procurements below £5m per annum, and above the relevant published procurement thresholds, suppliers must provide a Net Zero Commitment.
The Net Zero Commitment is a simpler requirement than a full CRP. It is a public commitment from the supplier to achieve net zero by 2050 or earlier, approved by the company’s board or director.
However, the requirements are changing from 1 April 2027.
What’s changing?
From April 2027, NHS England will no longer use a separate Net Zero Commitment for new procurements. Instead, in-scope procurements will use one of two tiers of CRP requirements.
For higher-value procurements – £5m or more per annum, including VAT – suppliers will need to meet the new 2027 NHS Carbon Reduction Plan Requirements. This is an expanded version of the existing CRP, with more comprehensive emissions reporting.
For lower-value procurements – below £5m per annum and above the relevant published procurement thresholds – the existing 2024 CRP requirements will continue to apply.
New NHS frameworks and open frameworks will also generally fall under the 2027 NHS CRP requirements, regardless of their value, unless the requirements are deemed not proportionate and relevant to the nature of the framework.
The important point for suppliers is that the 2027 NHS CRP is not a completely new type of document. It builds on the existing CRP, but expands the emissions reporting requirements and introduces some additional requirements around targets and reporting.
What will the 2027 NHS Carbon Reduction Plan require?
The biggest change is the amount of emissions data higher-value suppliers will need to report.
Under the current 2024 CRP requirements, suppliers report their Scope 1 and Scope 2 emissions, alongside five specified Scope 3 categories:
- Upstream transportation and distribution
- Waste generated in operations
- Business travel
- Employee commuting
- Downstream transportation and distribution
The 2027 NHS CRP will require suppliers to report their global Scope 1 and Scope 2 emissions, as well as all relevant Scope 3 emissions. The GHG Protocol identifies 15 Scope 3 categories to consider, although suppliers do not need to report categories that are genuinely not relevant to their organisation.
The 2027 CRP will also need to confirm the supplier’s commitment to achieve net zero by 2050 or earlier, provide a baseline and current emissions data, set out relevant environmental management measures, and be approved by the board or company director. It must be published on the supplier’s website. The 2027 update also introduces additional requirements around target validation and disclosure of the proportion of net zero target expected to rely on offsetting.
This means that businesses currently reporting on only the five required Scope 3 categories should start assessing their wider value-chain emissions if they expect to bid for contracts in the higher-value tier from April 2027.
For more information on Scope 3 emissions, visit our Scope 3 FAQs. Or, for expert advice on your organisations net zero strategy, get in touch with the experts at Sustainable Energy First.
What happens to lower-value procurements?
The change does not mean that every NHS supplier will need to produce the more detailed 2027 NHS CRP.
For lower-value procurements, the 2024 CRP requirements will continue to apply. These require suppliers to report Scope 1 and Scope 2 emissions and the five specified Scope 3 categories, alongside their commitment to achieving net zero by 2050 or earlier.
The key change for these suppliers is that they will move from the current Net Zero Commitment to a Carbon Reduction Plan. They will not need to meet the expanded 2027 CRP requirements unless the procurement falls into the higher-value tier or is otherwise subject to them.
What should NHS suppliers do now?
If you are already supplying the NHS, or planning to bid for NHS work, the first step is to understand which procurement tier is likely to apply to you.
If you expect to bid for contracts worth £5m or more per annum, start preparing for the 2027 NHS CRP now. In particular, review your Scope 3 emissions and identify which of the 15 categories are relevant to your business. This will help you identify where you have good-quality data and where you need to improve your data collection or use estimates.
For lower-value procurements, the 2024 CRP requirements are less demanding, but suppliers will still need to understand their Scope 1, Scope 2 and required Scope 3 emissions and demonstrate their commitment to achieving net zero by 2050 or earlier.
NHS Supply Chain: a separate requirement
There is another change that businesses supplying the NHS Supply Chain should be aware of. From 6 April 2026, suppliers submitting tenders to NHS Supply Chain must achieve Evergreen Level 1 at tender close.
Evergreen is an NHS sustainability assessment for suppliers. To achieve Level 1, suppliers must demonstrate a commitment to net zero by 2050, publish a PPN-006-compliant Carbon Reduction Plan, and report Scope 1, Scope 2 and relevant Scope 3 emissions.
This is a specific NHS Supply Chain requirement and is separate from the changes to NHS England Carbon Reduction Plans coming into force in April 2027.
Go beyond the minimum
Even where a particular NHS procurement does not require the most detailed level of carbon reporting, having a credible understanding of your emissions can strengthen your position as a supplier.
If your organisation is in scope of the Streamlined Energy and Carbon Reporting scheme (SECR), you may already have some of the data needed for your Carbon Reduction Plan. However, the new NHS requirements could require you to go further, particularly when it comes to Scope 3.
The 2027 requirements are not in force yet. But, NHS England has published the details. For businesses likely to be affected, preparing early means understanding which procurement tier applies to you. If you’d like support with your CRP, the team at Sustainable Energy First are ready to help identify gaps in your emissions data and make sure your Carbon Reduction Plan is ready for the requirements that will apply from April 2027. Get in touch via the form below.