Carbon Reduction Plans under PPN 006, and the business travel line

A supplier bidding for a large central government contract has to publish a Carbon Reduction Plan (CRP) to get through the door. The rule that asks for it, PPN 06/21, was reissued as PPN 006 in February 2025 for procurements under the Procurement Act 2023. Unlike the statutory directors’ report, a CRP must include business travel — flights and rail as well as cars. This page quotes PPN 006, its technical standard and its FAQ on who needs a plan, what goes in it and how it is assessed, and sets out where the business travel figures come from.

Who needs a Carbon Reduction Plan

The buyer side first. “This Procurement Policy Notice (PPN) applies to all central government departments, their executive agencies and non-departmental public bodies.” It applies to contracts “with an estimated contract value above £5 million per year” (including VAT) under the Procurement Act 2023, where relevant and proportionate. For frameworks: “This PPN applies to frameworks and dynamic markets but only where it is estimated that the individual value of any contract to be awarded in accordance with the framework or by reference to a dynamic market is greater than £5 million per year (including VAT).” The FAQ adds: “PPN 006 is not stated to be mandatory for Devolved Administrations.” Other public bodies may ask for a CRP on their own initiative, but PPN 006 does not require them to.

The PPN lists the kinds of contract where it is likely to be relevant, including “contracts which require the transportation of goods or people used in the delivery of the contract” — wording that on its face takes in a travel management contract as well as one that requires staff to travel to deliver it.

PPN 06/21 and PPN 006

“In-scope organisations must apply the provisions of this PPN to relevant procurements advertised on or after 24 February 2025.” and “For procurements commenced and contracts awarded before this date, please refer to PPN 06/21.” The FAQ is clear that the substance has not changed: “The substantive obligation introduced by PPN 06/21, now PPN 006, remains the same under the Act” but as a condition of participation rather than a selection criterion. An existing CRP written to the 06/21 template does not need rethinking on that account, but should still be checked against the PPN 006 technical standard.

How bids are assessed

The CRP is a gate, not a score. The PPN asks buyers to include, “as a condition of participation, a requirement for bidding suppliers to provide a CRP (using the template at Annex A) confirming the supplier’s commitment to achieving net zero by 2050 in the UK”. The FAQ: “Supplier CRPs should not be scored or compared against each other and assessment takes the form of a check that they meet the requirements of the measure.” Its worked example has one supplier committed to net zero by 2050 and another by 2030; both pass, and neither gains an advantage.

The buyer checks that the plan is on the supplier’s website, that it “has been signed off at an appropriate level and published since the publication of the tender notice, or in the preceding 12 month period”, that it includes a signed net zero commitment, the emissions, and the measures that will apply to the contract. Two shortcuts are refused: “No, CSR statements, policies and/or case studies cannot be accepted instead of a CRP.” and, for SBTi or Race to Zero membership, “these schemes do not align with the requirements of PPN 006 and a CRP based on/using the template outlined in PPN 006 is required.”

What goes in the plan

• Commitment: net zero by 2050 at the latest for UK operations, approved at the top — “It should be approved by a director (or equivalent senior leadership)”.
• Emissions: “providing the supplier’s current emissions for the sources included in Scope 1 and 2 of the GHG Protocol, and a defined subset of Scope 3 emissions”, for a baseline year and the current reporting year.
• Measures: the environmental management measures in effect, and those that will apply when performing the contract.
• Publication on the supplier’s UK website, linked prominently.

The five Scope 3 categories

“There are 15 categories of Scope 3 emissions defined by the GHG Protocol. In completing your CRP, suppliers are required to detail their emissions for five of these categories as detailed below.”

Category 6 is defined as “Transportation of employees for business related activities during the reporting year (in vehicles not owned or operated by the reporting company)”, and the minimum boundary is “The scope 1 and scope 2 emissions of transportation carriers that occur during use of vehicles (e.g., from energy use)”. Manufacturing the vehicles is optional. Category 7 is “Transportation of employees between their homes and their worksites during the reporting year” Travel in company-owned cars is not category 6 — it is Scope 1, already in the plan.

Rules that shape the numbers

• UK sources: “The data required to complete your Carbon Reduction Plan will come from completing a carbon footprint for your organisation’s emissions from sources in the United Kingdom.”
• Factors: emissions calculated “using the appropriate conversion factors published by the UK Government”.
• Timing: “your Carbon Reduction Plan should be reviewed and updated within 6 months of your organisation’s financial year-end.”
• Assurance: verification standards exist, but “there is no requirement to have your carbon footprint audited.”
• Overseas suppliers: “If an overseas supplier does not currently carry out operations in the UK, and therefore does not have UK emissions data, compliance with the measure can be achieved without this, provided the supplier fulfils the other requirements of the CRP, i.e. by confirming they have made a Net Zero commitment and providing details of environmental management measures in place where they carry out operations”.

One inconsistency in the published documents is worth knowing. PPN 006 itself asks for “providing emissions reporting in CO2e (carbon dioxide equivalent) for the six greenhouse gases covered by the Kyoto Protocol”; the technical standard says “The specific greenhouse gases to be reported against are the seven greenhouse gasses named by the Kyoto Protocol:” and lists seven, including nitrogen trifluoride. Reporting in CO2e using the government factors covers both readings.

Producing the business travel figure

The business travel figure can be built from three sources: the travel supplier’s booking data for flights, rail and hotels; expense claims for mileage, taxis and anything booked outside the programme; and hire car records. The government factors convert each into CO2e:

• Flights: distance by haul and cabin class, multiplied by the 2026 factor — with or without the indirect effects of aviation, stated in the plan and kept consistent between years. The 2026 values are on business travel emissions factors.
• Rail and taxis: passenger-km by mode.
• Mileage in employees’ cars: miles by car size and fuel, from the claims; the same data serves SECR if the company is in scope.
• Hotels: not mentioned in the category 6 minimum boundary quoted above; if they are reported, the government factor is per room night by country.

Two questions decide whether a travel supplier’s carbon report can go straight into a CRP: does it give distance by haul and class rather than just tonnes, and does it state the factor year and the air set used.

A short checklist

• Check whether the tender was advertised before or after 24 February 2025, and use PPN 06/21 or PPN 006 accordingly.
• Use the template; a sustainability report or policy will not pass.
• Make the plan specific to the bidding entity, or meet all four conditions for relying on the parent’s.
• Report Scope 1, Scope 2 and the five Scope 3 categories for UK operations, in CO2e with the government factors.
• Get director sign-off, publish on the UK website, and refresh within six months of each year-end.

Travel contracts for central government are themselves bought through frameworks; that side is on public sector travel management. This page quotes PPN 006 and its supporting documents as read on 2026-10-03; it is not procurement advice for a particular tender.

Common questions