Summary
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Details
- The United Kingdom
Suppliers bidding for UK government contracts with an anticipated value exceeding £5 million annually.
Deep dive
Background
Government procurement in the UK is a major means of public service delivery. According to the latest official estimates, in 2020/2021 the UK government spent £329 billion (32% of the total government spending for the year) buying a range of goods and services from the private sector. Between 2014/15 and 2020/21, on average £277.6 billion was spent on government procurement. The UK government published over 38,000 tenders and awarded 70,000 contracts in 2023. The bidding process for government contracts is therefore a key tool at government's disposal for directing private sector action towards certain national policy objectives. Accordingly, the UK government published the Procurement Policy Note (PPN 06/21) in June 2021 requiring all "Central Government Departments, their Executive Agencies and Non-Departmental Public Bodies" to include climate-related disclosures as a selection criterion for prospective suppliers. The climate disclosure criterion applies to the procurement of goods, services and works with an annual value of over £5 million (excluding VAT) which fall under the scope of the Public Contracts Regulations 2015.
Before the publication of PPN 06/21, there were no specific, climate disclosure rules for public procurement in the UK. However, some related policies and frameworks encouraged or indirectly addressed environmental and sustainability considerations in public procurement. For example, the Greening Government Commitments (GGCs) first published in 2011, set targets for UK government departments to reduce their environmental impact (including carbon emissions) while encouraging sustainable purchasing practices. The PPN 06/20 (June 2020) also established a "social value model" with climate change as one of its themes.
Requirements of PPN 06/21
With effect from 30 September 2021, the PPN 06/21 requires bidding suppliers to submit a Carbon Reduction Plan (CRP) stating the supplier’s commitment to attaining net zero emissions by 2050 in the UK, along with environmental management processes that they have established and will implement during the contract's execution. PPN 06/21 provides a template for the CRP. Among other information, the CRP, which should also be published on the supplier's website, should include the supplier’s Scope 1, Scope 2, and a subset of Scope 3 emissions following the GHG Protocol. The CRP should also disclose the supplier's emissions in CO2e (Carbon Dioxide Equivalent) for the six greenhouse gases covered by the Kyoto Protocol.
Consequences of Noncompliance
An obvious consequence of failing to provide the Carbon Reduction Plan (CRP) with the required information is disqualification from the bidding process. Though not mentioned in the PPN 06/21, false or misleading emissions claims by bidding suppliers could result in legal action under existing misrepresentation laws in the UK. Suppliers must therefore ensure that the statements in their Carbon Reduction Plans are accurate and verifiable. Tools that can assist suppliers in meeting their obligations under the PPN 06/21 include:
TISCreport Supplier CRP Compliance Check: helps suppliers verify CRP publication, track compliance status, and flag missing information through automated dashboards.
Ecologi Zero: offers integrated emissions calculation, hotspot analysis, carbon accounting workflows, and professional CRP guidance aligned to PPN 06/21.
Current Status
Since its publication in June 2021, PPN 06/21 has been widely adopted across UK central government and sector bodies including Crown Commercial Service (CCS), NHS England, and devolved administrations like Wales, with participation from thousands of suppliers. CCS now offers weekly CRP training, document reviews, and public CRP visibility on its site, backed by dedicated compliance teams. NHS England and CCS also host webinars and Q&A sessions to support suppliers. While enforcement remains largely reputational (disqualification for noncompliance), PPN 01/24 introduced contract-level carbon-reduction targets, enabling remediation plans or penalties under future agreements. No major legal challenges have emerged that might threaten the operation of PPN 06/21. The government’s support infrastructure including technical guidance, sector-specific training, and evolving contractual mechanisms reflects a clear commitment toward stronger enforcement and broader uptake across public-sector supply chains.
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