When does PPN 006 apply?
6 min read · Updated 15 July 2026
One of the most common questions suppliers ask is whether PPN 006 actually applies to the bid in front of them. It matters, because a Carbon Reduction Plan is a condition of taking part where the rule bites, and producing one takes time you may not have at the deadline. This guide sets out when the requirement applies, when it does not, and why you might still be asked for a plan either way.
Central government department, executive agency or non-departmental public body
Above GBP5 million per year, including VAT
A relevant public contract where the requirement is proportionate
Quick answer
PPN 006 applies to relevant central-government procurements with an estimated contract value above GBP5 million per year including VAT. It is normally used as a condition of participation, so a missing or non-compliant plan can stop a bid before scoring. This version applies to relevant procurements advertised on or after 24 February 2025; procurements commenced before that date continue under PPN 06/21.
The three tests
PPN 006, previously known as Procurement Policy Note 06/21, applies when all three of the following are true. If any one of them is not met, the mandatory requirement may not apply, though a buyer can still ask for a plan by choice.
1. The buyer is an in-scope public body
The rule covers central-government departments, their executive agencies and non-departmental public bodies. It does not automatically extend to the wider public sector such as local councils, many NHS bodies or universities, although a good number of those buyers now ask for a Carbon Reduction Plan anyway because it has become the accepted standard.
2. The contract is above the financial threshold
The requirement applies to contracts with an anticipated value above 5 million pounds per year, including VAT. Below that figure the mandatory rule does not normally apply. Note that it is an annual value, not just the total contract value. For frameworks and dynamic markets, the test is based on the expected value of the individual contract to be awarded through that route.
3. It is a qualifying procurement
The plan is required as part of the selection stage for qualifying procurements where the buyer has determined that the measure is relevant and proportionate. Where it applies, it is a pass-or-fail condition of participation rather than a scored question: a compliant, published plan keeps you in the process, and a missing one can exclude your bid regardless of how strong the rest of it is.
What to check in the tender pack
- The buyer name and whether it is an in-scope central-government body.
- The estimated annual contract value and whether VAT is included.
- Whether the Carbon Reduction Plan is a condition of participation.
- The required publication, sign-off and submission instructions.
- Whether the buyer accepts a parent-company plan, and under what conditions.
Wales and the devolved picture
Wales runs its own equivalent, WPPN 006, for Welsh public-sector procurement, framed against the Welsh public sector’s Net Zero by 2030 goal. The plan structure is the same, but the citations and context differ, so if you bid in Wales it is worth producing a plan aimed at that regime.
When the rule does not apply, but you are still asked
Plenty of buyers outside the strict scope of PPN 006 now include a Carbon Reduction Plan in their selection questionnaire. When that happens, the buyer’s own tender documents set the requirement, not the policy note, so read them carefully for what they expect. In practice the document you produce is the same one: the PPN 006 format has become the common reference point for showing carbon credentials in a bid.
If you are unsure
Treat the tender documents as the final instruction for that bid. If they ask for a Carbon Reduction Plan, prepare one in the PPN 006 format unless the buyer gives a different template or wording. It is usually faster to produce the plan than to risk a clarification question close to deadline.
Frequently asked questions
Does PPN 006 apply to local councils?
Not automatically. The mandatory rule covers central-government departments, executive agencies and non-departmental public bodies. Local authorities, many NHS bodies and universities are outside the strict scope, but a large and growing number ask for a Carbon Reduction Plan in the PPN 006 format anyway, so in practice you should expect the requirement.
Does PPN 006 apply below 5 million pounds?
The mandatory requirement applies above 5 million pounds per year including VAT. Below that, a buyer can still choose to ask for a Carbon Reduction Plan in the tender documents, and many do. The tender pack, not the threshold, is the final word for any individual bid.
Is a Carbon Reduction Plan pass or fail?
Where PPN 006 applies, yes. It is used as a condition of participation at the selection stage, not a scored question. A compliant, published plan keeps you in the process; a missing or non-compliant one can exclude the bid before quality and price are even looked at.
What is the difference between PPN 006 and PPN 06/21?
PPN 006 is the updated successor to PPN 06/21. It reflects the terminology and processes introduced by the Procurement Act 2023 and Procurement Regulations 2024. Use PPN 006 for relevant procurements advertised on or after 24 February 2025; procurements commenced before then continue under PPN 06/21. The core Carbon Reduction Plan requirement, threshold and technical content remain closely aligned, but always follow the policy and tender documents for the procurement you are entering.
Do subcontractors need a Carbon Reduction Plan?
The requirement sits with the bidding supplier, not the whole supply chain. Subcontractors are not required by the policy to have their own plan, but prime contractors increasingly ask key subcontractors for one anyway, both to strengthen their own bids and to cover their Scope 3 reporting.
What to do if it applies to you
If your bid meets the three tests, or the buyer has asked for a plan regardless, you need a compliant Carbon Reduction Plan published on your website before you submit. The mechanics are the same in every case: report your emissions across Scope 1, 2 and 3, include the required sections, and get a director-level sign-off. The step-by-step writing guide covers the whole process. If you would rather not build it by hand, you can produce a procurement-ready plan from a guided questionnaire and have it ready for the bid.
Practical next step
Use this checklist before submitting a tender to confirm the plan has the required sections, publication details and sign-off.
Download the PPN 006 checklistReviewed for accuracy
Written by the Carbon Sorted editorial team and reviewed against current UK procurement and carbon-reporting guidance. Last reviewed 15 July 2026.
Sources checked