Bidding for Public Work? Your Carbon Reduction Plan Is Now a Pass/Fail Question.

If you bid for central government work, there is a question on the tender that no amount of good pricing can rescue: do you have a compliant Carbon Reduction Plan? Under PPN 006, the answer is a condition of participation. Get it wrong and you are screened out before anyone reads about your delivery record.

PPN 006 is the Procurement Act 2023 successor to PPN 06/21, and it applies to relevant procurements advertised on or after 24 February 2025. The rule: central government departments, executive agencies and non-departmental public bodies must require a Carbon Reduction Plan from every supplier bidding for contracts worth more than £5 million a year, including VAT.

The £5 million test is not what most bidders think

The value is averaged over the life of the contract. The government's own FAQ uses this example: a four-year contract worth £21 million in total is in scope, even if year one alone comes in under £5 million. If you have been treating the threshold as a year-one figure, you may be closer to it than you think. Framework call-offs and multi-year service contracts reach £5 million a year faster than most mid-sized contractors expect.

What "compliant" actually means

The technical standard is specific. A Carbon Reduction Plan must:

• Commit to net zero by 2050 or earlier for your UK operations
• Report current emissions for Scope 1 and 2, plus five defined Scope 3 categories: business travel, employee commuting, upstream transportation and distribution, downstream transportation and distribution, and waste
• State emissions in CO₂e covering the seven Kyoto Protocol gases
• Describe the environmental management measures you have in place and will apply when delivering the contract
• Be approved by a director or equivalent senior leadership
• Be published and clearly signposted on your UK website
• Be updated at least annually

Every one of those is checkable in minutes by an evaluator, which is exactly how they are assessed.

Where bids actually fail

Having reviewed plenty of these from the supplier side, the same problems come up again and again:

1. The plan is stale. A CRP dated two years ago fails the annual update requirement on its face.
2. Scope 3 is missing or partial. Scope 1 and 2 from your energy bills is the easy half. The five Scope 3 categories are where suppliers either estimate honestly or leave gaps, and gaps are visible.
3. It is not really published. A PDF that lives in a tender portal but not on your website misses an explicit requirement.
4. The measures are generic. "We encourage recycling" is not an environmental management measure you will apply when performing the contract. Name the systems, the sites and the changes.

What to do before your next bid

1. Check your pipeline against the averaged £5 million test, not the annual invoice value.
2. Stand up the five Scope 3 categories now. Travel, commuting, transport and waste data takes weeks to assemble the first time and minutes thereafter if you capture it continuously.
3. Put the plan on your website, board-signed and dated, and put the annual refresh in the calendar.

For construction and infrastructure suppliers this stopped being optional some time ago: main contractors increasingly ask their supply chains for the same document, whether or not the contract crosses £5 million. A current, published, properly scoped CRP is becoming the cost of entry to public work. The suppliers who treat it as live data rather than an annual scramble win the same bid twice: once on compliance, and again on credibility.