The NHS spends £35 billion annually across 80,000+ suppliers. From April 2027, every supplier must report global emissions across all Scope 3 categories and by 2030, non-compliant suppliers face complete exclusion from NHS contracts.

If you supply goods, services, or works to the NHS, this guide explains exactly what you need to do, when you need to do it, and how SustainZone can help you achieve compliance without the complexity.

What the NHS Requires from Suppliers

The NHS operates a two-tiered compliance system based on contract value. Understanding which tier applies to your business determines your immediate obligations.

Tier 1: Contracts £5 Million+ Per Annum

If your NHS contracts average £5 million or more annually (calculated over the contract lifetime), you must submit a complete Carbon Reduction Plan (CRP) meeting PPN 006 requirements.

  • Commitment to net zero by 2050 (2045 strongly encouraged)
  • Scope 1 emissions: direct emissions from fuel combustion and company vehicles
  • Scope 2 emissions: indirect emissions from purchased electricity, heat, and cooling
  • Five Scope 3 categories: upstream transport, waste, business travel, employee commuting, downstream transport
  • Board-level sign-off from a director or equivalent
  • Published prominently on your company website
  • Updated annually within six months of your financial year-end

Tier 2: Contracts Above Procurement Thresholds

For contracts below £5 million but above £207,720 (or £135,018 for central government), you need a simpler Net Zero Commitment declaring your intention to achieve net zero by 2050 for UK operations.

How SustainZone Helps

We calculate your emissions, draft your Carbon Reduction Plan or Net Zero Commitment, secure board sign-off, and ensure your documentation meets NHS requirements—typically within 4-6 weeks for SMEs.

The Critical 2027 Deadline

April 2027 represents the most significant expansion of NHS supplier requirements since the roadmap began. From this date:

  • All suppliers must report GLOBAL emissions (not just UK operations)
  • Reporting expands to ALL 15 Scope 3 categories
  • Targets must align with the NHS 2045 net zero target

This means measuring emissions from purchased goods and services, capital goods, fuel-related activities, leased assets, product processing, use of sold products, end-of-life treatment, franchises, and investments.

Start Measuring Now Building comprehensive Scope 3 measurement capabilities takes 12-18 months for most SMEs. Starting now ensures you have baseline data and reporting processes ready before April 2027.

NHS Evergreen Sustainable Supplier Assessment

The Evergreen Assessment, hosted on the Atamis platform, scores suppliers across four maturity levels. The NHS targets all suppliers reaching Level 1 by April 2026.

LevelRequirementsLevel 1Public net zero commitment (2050), modern slavery statementLevel 2Comprehensive net zero targets (all Scope 3), corporate social value programmeLevel 32045 net zero targets, global emissions reporting, independently validated targets (SBTi)Level 4Full validation (entity + parent), CDP/EcoVadis/B Corp recognition, supply chain mapping

Science-Based Targets (SBTi) for NHS Suppliers

While the NHS does not explicitly mandate SBTi-validated targets, independent validation is required for Evergreen Level 3 and above. SBTi represents the gold standard for demonstrating credible decarbonisation commitments.

Suppliers with validated science-based targets gain competitive advantage in NHS procurement evaluations and position themselves for the increasingly stringent requirements approaching 2030.

SBTi Support for SMEs

SustainZone specialises in helping SMEs navigate SBTi validation—from target setting through submission and approval. Our streamlined process reduces the typical 6-12 month timeline significantly.

Key Compliance Deadlines

DeadlineRequirementNowCRP required for £5m+ contracts; Net Zero Commitment for contracts above thresholdsApril 2026All suppliers should achieve Evergreen Level 1 maturityApril 2027Global emissions reporting across ALL 15 Scope 3 categories; 2045 target alignmentApril 2028Product-level carbon footprinting for supplied goods2030Demonstrated progress mandatory for contract eligibility—non-compliant suppliers excluded

What Happens If You Don’t Comply?

The consequences of non-compliance are immediate and escalating:

  • Carbon Reduction Plans are assessed pass/fail at selection stage—incomplete plans mean automatic exclusion
  • NHS medicines procurement requires Evergreen Assessment at tender stage—no assessment means no bid
  • Lapsed Evergreen Assessments during contracts constitute breach of contract
  • From 2030, suppliers without demonstrated progress cannot qualify for any NHS contracts

With NHS procurement representing £35 billion annually, losing eligibility means losing access to one of the UK’s largest public sector markets.

SME-Specific Support and Flexibilities

The NHS recognises that SMEs face different challenges than large enterprises. Specific accommodations include:

  • Ability to submit partial CRPs with explanations for data gaps where complete emissions data is unavailable
  • Potential waiver of requirements for light-touch contracts where market engagement demonstrates SME barriers
  • Free NHS resources including CRP checking service, webinars, and the Sustainable Supplier Accelerator

However, these flexibilities do not remove the fundamental requirements—they provide pathways to compliance, not exemptions from it.

Built for SMEs

SustainZone specialises in making sustainability compliance accessible for SMEs. Our technology-enabled approach delivers enterprise-grade carbon accounting and compliance documentation at SME-appropriate price points, typically from £2,500.

How SustainZone Delivers NHS Compliance

Carbon Reduction Plan Development

We handle the complete CRP process:

  • Calculate Scope 1, 2, and required Scope 3 emissions using UK Government conversion factors
  • Establish your baseline year and document current environmental management measures
  • Develop credible reduction targets with specific initiatives
  • Draft board-ready documentation meeting NHS/PPN 006 requirements
  • Provide annual update support to maintain compliance

Scope 3 Measurement (2027 Readiness)

Preparing for the April 2027 expansion requires measuring emissions across your entire value chain:

  • Purchased goods and services: supplier engagement and spend-based calculations
  • Capital goods: asset lifecycle emissions
  • Upstream and downstream transportation: logistics carbon footprinting
  • Use of sold products and end-of-life treatment: product lifecycle assessment
  • Investments, franchises, and leased assets: financial emissions attribution

Science Based Targets (SBTi)

For suppliers targeting Evergreen Level 3+ or seeking competitive differentiation:

  • Target boundary definition and ambition setting
  • Near-term and long-term target development
  • SBTi submission preparation and review
  • Post-validation reporting and progress tracking

Your Next Steps

Whether you’re starting from scratch or need to upgrade existing compliance, the path forward is clear:

  • Understand your tier: Calculate your NHS contract values to determine whether you need a full CRP or Net Zero Commitment
  • Assess your current state: Do you have published emissions data? An Evergreen Assessment? Board engagement?
  • Plan for 2027: Begin Scope 3 measurement across all categories now to establish baselines
  • Get expert support: Complex requirements don’t require complex processes with the right partner
Contact SustainZone for a consultation to assess your current NHS compliance status, identify gaps, and receive a clear roadmap to full compliance.

Email: connect@sustainzone.earth