Regulations

Carbon reduction plans: what small care providers actually need

Fleet emissions, scope 1-2-3 simplified, and a practical approach to CRP for domiciliary care and supported living providers.

What is a Carbon Reduction Plan and why does it matter for NHS bids?

A Carbon Reduction Plan (CRP) is a document that sets out your current greenhouse gas emissions, your commitment to reach net zero by 2050, and the steps you’ll take to get there. It is not a complicated sustainability report. For most small care providers, it is a few pages of straightforward data and a commitment statement.

The requirement comes from PPN 006 (formerly PPN 06/21), updated in February 2025. NHS England has embedded these requirements into procurement, and they apply regardless of which procurement route the commissioner uses.

If you bid for NHS contracts, you need to know where you stand.


What the rules actually require

The NHS operates a two-tiered system based on contract value:

Contract value (per annum, exc. VAT)What you need
£5m and above (or any framework)Full Carbon Reduction Plan
£10k–£5mNet Zero Commitment
Below £10kNothing specific required

Most domiciliary care and supported living contracts awarded through ICBs and local authority commissioners fall in the £100k–£3m range annually. That means most care providers need a Net Zero Commitment, not a full CRP — though having a CRP means you automatically satisfy both requirements.

Pass/fail, not scored

The CRP or Net Zero Commitment is assessed on a pass/fail basis at the selection stage. It is not scored out of 10 or compared against other bidders. You either meet the minimum standard or you do not proceed. Getting this right is about compliance, not competitive advantage.

The separate 10% minimum weighting on net zero and social value is scored during tender evaluation. Your CRP feeds into that — but they are two distinct requirements. Do not confuse them.

From April 2027, all NHS suppliers will be required to report global Scope 1, 2, and 3 emissions and publish a full CRP regardless of contract size. If you start building your CRP now, you are ahead of the curve.


Scope 1, 2, and 3 — without the jargon

The GHG Protocol divides emissions into three scopes. Here is what they mean for a care provider:

Scope 1 — your direct emissions

Emissions from things you own or directly control. For a care provider, this is almost entirely your vehicle fleet. If your team drives company-owned cars or vans to visit clients, those tailpipe emissions are Scope 1. If you use gas heating in your offices, that is Scope 1 too.

Scope 2 — your energy use

Electricity you purchase. The electricity powering your office, any registered premises, or charging points for EVs. You get this from your energy bills. Simple.

Scope 3 — everything else in the chain

This is where it gets wider: employee business mileage in personal cars, business travel, waste disposal, purchased goods and services. For a domiciliary care provider, employee travel is often the single biggest source — in some cases over 90% of total emissions.

What you actually need to measure

For a CRP compliant with PPN 006, you must include all Scope 1 and 2 emissions and a defined subset of Scope 3. The required Scope 3 categories are: business travel, employee commuting, and any significant category relevant to your operations. For domiciliary care, that means staff travel to clients.


Fleet emissions: the biggest number for care providers

For domiciliary care and supported living providers, transport is almost always the dominant source of emissions. Care workers travel between clients all day. Whether those vehicles are owned by your organisation (Scope 1) or personal cars used for work (Scope 3 business travel), you need to account for them.

How to calculate fleet emissions:

  • Company vehicles (Scope 1): Collect fuel purchase data from receipts, fuel cards, or fleet management records. Multiply litres of petrol or diesel by the relevant DESNZ (Department for Energy Security and Net Zero) emission conversion factor. The government publishes these conversion factors annually.
  • Employee mileage in personal cars (Scope 3): Collect mileage claim records. Multiply total miles by the HMRC/DESNZ per-mile emissions factor for an average car. Most payroll or HR systems already hold this data.

If you pay mileage expenses, you already have the data you need. This is not a new data collection exercise — it is using records you already keep.


What a compliant CRP contains

A Carbon Reduction Plan for PPN 006 compliance needs five elements:

  1. Commitment statement — A clear, signed commitment to achieve net zero by 2050 or sooner, covering UK Scope 1, 2, and the relevant Scope 3 categories. A senior director or owner must sign this.

  2. Baseline emissions data — Your current (or most recent 12-month) greenhouse gas footprint, broken down by scope. This is the starting point against which future reductions will be measured. It must follow the GHG Protocol.

  3. Emissions reduction targets — Specific, time-bound targets. Not “we will try to reduce emissions.” Instead: “We will reduce Scope 1 and 2 emissions by 30% by 2030 against our 2024 baseline.” Align these with the UK’s legislated carbon budgets.

  4. Action plan — What you will actually do to hit those targets. For a care provider this typically means transitioning company vehicles to EVs, optimising care worker routing to reduce mileage, switching to a renewable energy tariff, and reducing paper and office waste.

  5. Published on your website — The completed CRP must be publicly available. A dedicated page or downloadable PDF both work. It must be updated annually.

Annual update is mandatory

Your CRP must be updated every year with the most recent 12 months of emissions data. A CRP more than 12 months old from the date a procurement opens is non-compliant. Set a calendar reminder. Commissioners check this.


Format requirements

The government provides an official CRP template via the Crown Commercial Service. You do not have to use it, but it is the safest option for small providers because it is pre-structured to meet PPN 006 requirements.

Key formatting requirements:

  • Emissions figures reported in tonnes of CO2 equivalent (tCO2e)
  • Use DESNZ conversion factors (published annually at gov.uk) — do not use generic online calculators that do not cite their source
  • Broken down by Scope 1, Scope 2, and relevant Scope 3 categories
  • Signed and dated by a senior person with authority to commit the organisation
  • Dated — the document itself must show when it was produced and when it covers

Common mistakes care providers make

Thinking you need a consultant

Most small care providers can write their own CRP using the government template. The data collection is the hard part, not the writing. If your annual contract pipeline is modest, spending £2,000–£5,000 on a sustainability consultant to produce a compliance document is disproportionate. Use the free government template and the DESNZ emission factors.

Not publishing it

A CRP that exists but is not on your website does not count. Commissioners will check. It takes ten minutes to add a page to your website or upload a PDF.

Using outdated emissions data

If your CRP references 2021 emissions data and you are bidding in 2026, you will fail the pass/fail check. Commit to updating it every 12 months.

Setting no targets

A commitment to net zero by 2050 without any interim targets or actions is technically compliant at minimum level, but it is weak. Commissioners evaluating social value questions will notice. Set at least one specific reduction target with a date.

Over-measuring Scope 3

You do not need to calculate the lifecycle emissions of every product you purchase. The required Scope 3 categories for most care providers are business travel and employee commuting — that is it. Do not spend weeks trying to trace the carbon footprint of your gloves supplier.


How CRP appears in your tender

Selection stage (pass/fail): You confirm you have a compliant CRP (or Net Zero Commitment) and provide the URL where it is published. If you cannot pass this check, your bid is excluded. No exceptions.

Evaluation stage (scored): The net zero and social value questions — worth at least 10% of the total score — will ask you to describe your environmental commitments and what specific actions you are taking. Your CRP gives you the substance to answer these questions credibly. A provider with an EV transition roadmap and measured fleet emission reductions will score higher than one with a vague commitment.

Link your CRP to your social value response

The strongest tender responses connect the two. Your CRP shows you have measured your impact. Your social value response shows how your contract-specific actions will drive further reductions. They should reference each other.


Practical steps to create your first CRP

  1. Gather 12 months of data — Pull your last 12 months of: (a) fuel receipts or fuel card statements for company vehicles, (b) mileage claim records for staff using personal cars, (c) electricity bills for all premises, (d) gas bills for any office heating.

  2. Convert to tCO2e — Use the DESNZ conversion factors (search “greenhouse gas reporting conversion factors” on gov.uk to find the latest year’s table). Multiply your fuel/electricity quantities by the relevant factors. A spreadsheet suffices.

  3. Total by scope — Add up your Scope 1 (company vehicles + gas), Scope 2 (electricity), and Scope 3 (staff mileage in personal cars, any business travel). This is your baseline.

  4. Set targets — Commit to at least one specific reduction target. For most care providers: commit to transitioning X% of company vehicles to EVs by year Y, or reducing total vehicle miles by X% through route optimisation by year Y.

  5. Write your action plan — Three to five specific actions with owners and timescales. Route optimisation software, EV transition, renewable energy tariff switch, remote team meetings to reduce office commuting.

  6. Get it signed — The owner, CEO, or a director must sign and date the document.

  7. Publish it — Add a page to your website or link to a downloadable PDF. Note the URL.

  8. Set a 12-month reminder — Update it annually with your most recent year’s data.


Free tools and resources

  • Official CRP template — Crown Commercial Service (search “PPN 006 carbon reduction plan template” on gov.uk). Free download, pre-structured for compliance.
  • DESNZ conversion factors — Updated annually on gov.uk. Search “greenhouse gas reporting conversion factors.” Essential for accurate calculations.
  • SMMT EV tool — If you are considering fleet electrification, the Society of Motor Manufacturers and Traders provides free cost-of-ownership comparison tools.
  • NHS Greener NHS supplier guidance — NHS England’s Greener NHS pages (england.nhs.uk/greenernhs) include specific guidance for suppliers, including worked examples.
  • Carbon Trust SME guide — Free guidance for small businesses on calculating and reducing emissions.

The honest truth about what this takes

Creating your first CRP will take a working day. Maybe two if your mileage records are scattered. Once it is done and published, updating it each year takes a couple of hours.

The investment is proportionate. Most care providers are already closer to compliance than they realise — the data lives in your fuel cards, mileage claims, and energy bills. It is a matter of pulling it together, running it through the conversion factors, and committing to a direction of travel.

The providers who fail CRP checks are not the ones with high emissions. They are the ones who have not started at all.

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