If you supply the NHS — or are planning to — the sustainability requirements attached to NHS contracts have changed significantly over the past three years. The NHS Net Zero Supplier Roadmap sets out a series of escalating compliance milestones that apply to every supplier, regardless of size, sector, or contract value.
This article explains what the roadmap requires, when each milestone applies, and what your business needs to do to stay commercially viable as an NHS supplier between now and 2030.
Where the roadmap came from
In 2020, the NHS published its commitment to become the world's first net zero national health service. The "Delivering a Net Zero NHS" report set two targets: net zero for direct NHS emissions by 2040, and net zero for emissions it influences through its supply chain by 2045.
The supplier roadmap is the mechanism for reaching that second target. It places the responsibility for emissions reduction directly onto the businesses that supply the NHS, with a series of formal compliance requirements that tighten progressively leading up to 2030.
The key milestones
Net Zero and Social Value weighting introduced
All NHS procurements began including a minimum 10% net zero and social value weighting in their evaluation criteria. For the first time, a supplier's sustainability position started directly affecting bid scores. Not as a pass/fail gate, but as a scored element that could make the difference between winning and losing a competitive tender.
Carbon Reduction Plans required for contracts above £5 million
Under PPN 006, any supplier bidding for an NHS contract valued at £5 million or more per annum was required to publish a compliant Carbon Reduction Plan. The plan needed to cover UK Scope 1, 2, and the mandatory five Scope 3 categories, aligned to the GHG Protocol and using current DEFRA conversion factors. This was the first hard pass/fail carbon compliance gate in NHS procurement.
Evergreen Sustainable Supplier Assessment launched
The NHS launched its Evergreen platform, an online self-assessment tool hosted on the Atamis procurement system that allows suppliers to report their sustainability maturity and share carbon data directly with NHS procurement teams. Evergreen has four maturity levels, from a basic net zero commitment at Level 1 through to independently verified global emissions reporting at Level 4. A compliant Carbon Reduction Plan is the foundation for achieving Level 1. Completing the Evergreen assessment is a separate step from producing a CRP document. Suppliers need to actively register on the platform, complete the self-assessment, and achieve a scored maturity level.
CRP requirement extended to all procurements
This is the milestone that changed everything for smaller NHS suppliers. The NHS proportionately extended the Carbon Reduction Plan requirement to cover all new procurements, regardless of contract value. For higher-value contracts above £5 million, a full CRP remains mandatory as a tender document. For lower-value contracts between £10,000 and £5 million, a formal Net Zero Commitment is required as a minimum.
If you supply the NHS and have not yet addressed this requirement, you are already behind.
Evergreen Level 1 becomes mandatory for NHS Supply Chain tenders
From 6 April 2026, NHS Supply Chain requires all suppliers to have achieved Evergreen Level 1 on the Atamis platform before tender closure. This deadline has now passed.
This is a distinct and additional requirement that sits alongside the April 2024 CRP obligation. A supplier with a compliant CRP published on their website satisfies the 2024 requirement but can still fail NHS Supply Chain tenders if they have not completed the Evergreen self-assessment and achieved a Level 1 maturity score within the Atamis platform itself. The two requirements work in parallel, not in place of each other.
If you have not yet completed your Evergreen Level 1 assessment, you are now non-compliant with NHS Supply Chain tender requirements. The priority is to address this before your next bid. A compliant, up-to-date CRP is the foundation for completing Level 1 on the platform - without it, you cannot progress the assessment.
For full details of what the Evergreen Level 1 requirement involves, NHS Supply Chain has published guidance here.
Full global emissions reporting required
By April 2027, all NHS suppliers will be required to publicly report targets and emissions and publish a Carbon Reduction Plan covering their global operations, not just UK emissions. This plan must align with the NHS Net Zero target and cover all Scope 1, 2, and 3 categories.
This represents a significant step up from current requirements. Businesses that have a basic UK CRP in place now will need to expand their reporting scope before this deadline. The 2027 requirement is particularly relevant for any supplier with overseas operations, international supply chains, or significant global travel. For those businesses, the gap between a current UK CRP and a 2027-compliant global plan may be substantial. Starting to gather that data now means the update is a manageable refresh rather than a rebuild under time pressure.
Product-level carbon footprinting
New requirements will be introduced covering carbon footprinting for individual products supplied to the NHS. The methodology is still being developed in consultation with suppliers and regulators, but this will affect product-based suppliers, such as those providing medical consumables, equipment, and goods, more significantly than service-based businesses.
Ongoing progress reporting mandatory
From 2030, suppliers will only qualify for NHS contracts if they can demonstrate ongoing emissions reduction progress through published reports and continued reporting through the Evergreen assessment. Sustainability will no longer be a one-time compliance exercise. It will become an annual commercial requirement with visible, measurable progress expected year on year.
Net Zero and Social Value weighting introduced
All NHS procurements began including a minimum 10% net zero and social value weighting in their evaluation criteria. For the first time, a supplier's sustainability position started directly affecting bid scores. Not as a pass/fail gate, but as a scored element that could make the difference between winning and losing a competitive tender.
Carbon Reduction Plans required for contracts above £5 million
Under PPN 006, any supplier bidding for an NHS contract valued at £5 million or more per annum was required to publish a compliant Carbon Reduction Plan. The plan needed to cover UK Scope 1, 2, and the mandatory five Scope 3 categories, aligned to the GHG Protocol and using current DEFRA conversion factors. This was the first hard pass/fail carbon compliance gate in NHS procurement.
Evergreen Sustainable Supplier Assessment launched
The NHS launched its Evergreen platform, an online self-assessment tool hosted on the Atamis procurement system that allows suppliers to report their sustainability maturity and share carbon data directly with NHS procurement teams. Evergreen has four maturity levels, from a basic net zero commitment at Level 1 through to independently verified global emissions reporting at Level 4. A compliant Carbon Reduction Plan is the foundation for achieving Level 1. Completing the Evergreen assessment is a separate step from producing a CRP document. Suppliers need to actively register on the platform, complete the self-assessment, and achieve a scored maturity level.
CRP requirement extended to all procurements
This is the milestone that changed everything for smaller NHS suppliers. The NHS proportionately extended the Carbon Reduction Plan requirement to cover all new procurements, regardless of contract value. For higher-value contracts above £5 million, a full CRP remains mandatory as a tender document. For lower-value contracts between £10,000 and £5 million, a formal Net Zero Commitment is required as a minimum.
If you supply the NHS and have not yet addressed this requirement, you are already behind.
Evergreen Level 1 becomes mandatory for NHS Supply Chain tenders
From 6 April 2026, NHS Supply Chain requires all suppliers to have achieved Evergreen Level 1 on the Atamis platform before tender closure. This deadline has now passed.
This is a distinct and additional requirement that sits alongside the April 2024 CRP obligation. A supplier with a compliant CRP published on their website satisfies the 2024 requirement but can still fail NHS Supply Chain tenders if they have not completed the Evergreen self-assessment and achieved a Level 1 maturity score within the Atamis platform itself. The two requirements work in parallel, not in place of each other.
If you have not yet completed your Evergreen Level 1 assessment, you are now non-compliant with NHS Supply Chain tender requirements. The priority is to address this before your next bid. A compliant, up-to-date CRP is the foundation for completing Level 1 on the platform - without it, you cannot progress the assessment.
For full details of what the Evergreen Level 1 requirement involves, NHS Supply Chain has published guidance here.
Full global emissions reporting required
By April 2027, all NHS suppliers will be required to publicly report targets and emissions and publish a Carbon Reduction Plan covering their global operations, not just UK emissions. This plan must align with the NHS Net Zero target and cover all Scope 1, 2, and 3 categories.
This represents a significant step up from current requirements. Businesses that have a basic UK CRP in place now will need to expand their reporting scope before this deadline. The 2027 requirement is particularly relevant for any supplier with overseas operations, international supply chains, or significant global travel. For those businesses, the gap between a current UK CRP and a 2027-compliant global plan may be substantial. Starting to gather that data now means the update is a manageable refresh rather than a rebuild under time pressure.
Product-level carbon footprinting
New requirements will be introduced covering carbon footprinting for individual products supplied to the NHS. The methodology is still being developed in consultation with suppliers and regulators, but this will affect product-based suppliers, such as those providing medical consumables, equipment, and goods, more significantly than service-based businesses.
Ongoing progress reporting mandatory
From 2030, suppliers will only qualify for NHS contracts if they can demonstrate ongoing emissions reduction progress through published reports and continued reporting through the Evergreen assessment. Sustainability will no longer be a one-time compliance exercise. It will become an annual commercial requirement with visible, measurable progress expected year on year.
What this means in practice
Both the April 2024 CRP requirement and the April 2026 Evergreen Level 1 deadline have now passed. If you are an NHS supplier and have not addressed either of these, you are at risk on two fronts.
If you do not have a published, compliant Carbon Reduction Plan in place, you are failing the Selection Questionnaire stage on every new or renewed NHS contract you bid for. This is a pass/fail gate with no exceptions.
If you have a CRP but have not completed your Evergreen Level 1 assessment on the Atamis platform, you are now non-compliant with NHS Supply Chain tender requirements. These are two separate obligations and satisfying one does not satisfy the other. A CRP document on your website is no longer sufficient on its own.
If you are in either position, the priority is to act before your next bid rather than waiting for a rejection to force the issue. A compliant CRP can be in place within 10 working days. Once that's done, completing the Evergreen Level 1 self-assessment on Atamis is a straightforward next step.
If you are a Tier 2 supplier, providing services or goods to a primary NHS contractor rather than directly to an NHS trust, you are not yet formally required to hold a CRP. But primary contractors are now under significant pressure to report their own Scope 3 supply chain emissions ahead of the 2027 global reporting deadline. Requests for carbon data from Tier 2 suppliers are becoming routine, and businesses that cannot respond are at risk of being replaced by those that can.
The Evergreen ladder and what comes next
For most SMEs, the immediate goal is Evergreen Level 1. This requires a net zero commitment and a compliant Carbon Reduction Plan covering UK Scope 1, 2, and the mandatory Scope 3 categories, with the assessment completed on the Atamis platform.
Level 2 requires a more comprehensive emissions footprint with robust annual reporting systems and formalised social value and modern slavery policies. Levels 3 and 4 require independent third-party verification of Net Zero plans, a more significant undertaking currently relevant primarily to larger suppliers or those on high-value NHS frameworks.
The practical approach for most SMEs is to achieve Level 1 correctly and completely, then build toward Level 2 as your data maturity improves and the 2027 global reporting deadline approaches. Attempting to reach Level 3 or 4 immediately is neither required nor appropriate for a business at the start of its compliance journey.
Getting compliant before your next bid
At CarbonSync, we produce audit-ready Carbon Reduction Plans for UK SMEs bidding on NHS and public sector contracts. A compliant CRP is the foundation for Evergreen Level 1 and satisfies the PPN 006 requirements for all current NHS procurement thresholds.
Our process requires less than two hours of your team's time and delivers a tender-ready, published plan within 10 working days, giving you the document you need to meet current requirements and the foundation to complete your Evergreen Level 1 assessment.
Book a free discovery call to discuss your requirements, or view our Carbon Reduction Plan service for full details.
