If your organisation bids for NHS contracts, 2026 is the year to act on carbon reporting. From April 2027, the requirements under PPN 006 are expanding significantly. The businesses that wait until the deadline will find themselves under real compliance and resource pressure. Here is what is changing, why it matters, and how to prepare.
What is PPN 006?
PPN 006 (formerly PPN 06/21) is the UK government’s Procurement Policy Note requiring suppliers bidding for public sector contracts above the relevant threshold to submit a Carbon Reduction Plan (CRP). For NHS suppliers, this is tied directly to the NHS Net Zero 2045 target and sets a rising bar for transparency around emissions reporting. Until now, PPN 006 compliance has required reporting on Scope 1, Scope 2 and five categories of Scope 3 emissions. That is about to change.
What Changes to Expect From April 2027
From April 2027, NHS suppliers will be required to:
- Report full Scope 1 and 2 emissions.
- Expand Scope 3 reporting from 5 categories to all 15.
- Align their Carbon Reduction Plan with NHS Net Zero 2045 targets.
The increase from 5 to all 15 Scope 3 categories is the critical shift. For many organisations, this means collecting and reporting emissions data that has never been gathered before, including categories such as:
- Purchases goods and services.
- Capital goods.
- Both upstream and downstream transportation and distribution.
- Use of sold products.
- End of life treatment of sold products.
Scope 3 emissions typically represent the largest proportion of an organisation’s total carbon footprint. They are also the most complex and resource-intensive data to collect accurately, subsequently making early preparation critical.
Why Waiting Until 2027 Is a Risk
Organisations that delay Scope 3 data collection until the year of the deadline face compounding problems:
- No Baseline Data – a credible Carbon Reduction Plan requires a reliable baseline. Without now, estimates will be required, weakening the quality and credibility of your submission.
- Internal Resource Pressure – collecting data across 15 Scope 3 categories requires supplier engagement, system integration, and internal resource. Doing this under deadline pressure will likely increase error risk, and will definitely increase cost.
- Procurement Risk – NHS procurement teams are raising their expectations. Suppliers that can’t demonstrate robust, evidenced reporting may find their tenders at a disadvantage.
Practical Steps You Can Do in 2026 To Prepare:
Starting in 2026 allows your organisation to pace the work, build reliable data over time, and approach the 2027 deadline with confidence rather than urgency. Our experts have suggested to begin following the three steps below in order to get ahead of the April 2027 requirements.
Map all 15 Scope 3 categories against your business
Begin by identifying which of the 15 categories are relevant to your operations and where the significant data gaps lie. This scoping exercise if the foundation for everything that follows.
Begin Scope 3 data collection this year, not 2027
Collecting a full year of data during 2026 gives you a baseline to report against and allows time to address data quality issues before the compliance deadline. This is particularly important for supply chain categories, where engaging suppliers to provide accurate emissions takes time.
Work with a specialist sustainability consultant
PPN 006 compliance is not just a check-box exercise. The Carbon Reduction Plan must be structured correctly, signed off by a senior director, and aligned with procurement expectations. Working with an experienced sustainability consultant ensures your reporting is proportionate, evidenced, and submission-ready.
How Enistic Can Support You
At Enistic, we support organisations navigating regulatory change with clarity and confidence. We work with hundreds of businesses across the UK including NHS suppliers, public sector contractors, listed entities and growing private organisations to turn regulatory change into competitive advantage. Organisations that build capability now will not only meet future requirements, but will demonstrate leadership, strengthen stakeholder trust and embed sustainability into long-term strategy. If you bid for NHS contracts and want to get ahead of the April 2027 requirements, the right time to start is now. Get in touch today.