What ESG Do Tenders and PQQs Actually Ask For?
Updated 2 July 2026 · SEO Dons Editorial
Losing a tender you should have won, for the want of a single document, is one of the most avoidable commercial failures in ESG. It happens constantly. A bid team assembles a strong technical and commercial submission, then hits a mandatory question asking for a Carbon Reduction Plan the business has never produced — and the bid is marked non-compliant before the quality panel ever reads it. This guide sets out, from the buyer’s side of the table, what public-sector and large private tenders actually ask for on carbon and sustainability, so you can have the evidence ready rather than scrambling at the deadline.
The one requirement that disqualifies bids: the PPN 006 Carbon Reduction Plan
The headline ESG requirement in UK public procurement is the Carbon Reduction Plan (CRP) demanded under Procurement Policy Note 006 (PPN 006), which replaced and updated the former PPN 06/21 to reflect the Procurement Act 2023 and the Procurement Regulations 2024. It applies to procurements commenced on or after 24 February 2025, and it is not a “nice to have” — where it applies, it is a pass/fail selection criterion.
PPN 006 requires suppliers bidding for major central-government contracts with an estimated value above £5 million a year (including VAT) to have, and to publish, a Carbon Reduction Plan. A compliant plan must:
- confirm the supplier’s commitment to achieving net zero by 2050;
- state the supplier’s current carbon footprint, covering UK Scope 1 and Scope 2 emissions and a defined subset of Scope 3 categories;
- set out the environmental management measures and reduction projects the supplier is implementing; and
- be published on the bidder’s own website in the specified format, signed off at board (or equivalent) level.
Stat callout — the disqualifier. Above the £5 million-a-year threshold, a missing or non-compliant Carbon Reduction Plan is a mandatory-fail: an otherwise winning bid is excluded on compliance, not on quality. Verified against gov.uk, 2 July 2026.
The important point for a bid director is timing. A Carbon Reduction Plan is not a form you fill in on the portal — it depends on a carbon baseline built from your actual energy and fuel data, which takes real work to assemble. If the first time you read the requirement is the week the tender closes, you have already lost. Building the plan properly, once, and keeping it current is the only reliable position. Our net-zero roadmap service produces a Carbon Reduction Plan to the PPN 006 standard as part of a costed decarbonisation plan, rather than as a standalone paper exercise.
Below £5 million: selection questionnaires and the wider public sector
Most public-sector work sits below the £5 million central-government threshold, so it does not trigger the formal PPN 006 duty. That does not mean carbon falls out of the assessment — it means it arrives through a different door: the selection questionnaire (SQ), the successor to the old pre-qualification questionnaire (PQQ), and through buyers’ own social-value and sustainability policies.
Across local authorities, NHS bodies, universities, housing associations and combined authorities, selection questionnaires increasingly ask a bidder to evidence some or all of the following:
- Your carbon footprint — usually Scope 1 and 2 at minimum, and often a request for material Scope 3.
- Your reduction targets — a stated net-zero or reduction target, sometimes with interim milestones, and increasingly whether it is aligned to a recognised standard.
- An environmental management system — evidence of a structured approach such as ISO 14001, or a proportionate equivalent for smaller suppliers.
- A policy set — an environmental policy, and commonly policies on modern slavery, ethical procurement and (through the social-value lens) local employment and skills.
- Governance — who in the business owns environmental performance, and how it is overseen.
The scoring here is rarely pass/fail in the way PPN 006 is, but it is weighted, and in a close competition the sustainability score decides the outcome. A bidder with a quantified footprint, a credible target and a named owner beats a bidder offering a values statement, every time.
The NHS and universities are running ahead of the baseline
Two parts of the public sector are pushing carbon requirements harder than the general standard, and if you sell to them you should expect it.
The NHS operates the NHS Net Zero Supplier Roadmap. Under it, suppliers are asked to complete the Evergreen Sustainable Supplier Assessment, and the roadmap sets escalating expectations year on year, including a requirement for suppliers to reach at least level 1 of the assessment from April 2026. NHS procurement builds directly on the government’s PPN 006 policy, so a supplier that has a Carbon Reduction Plan and a real baseline is already most of the way to what an NHS trust will ask.
Universities increasingly operate supplier codes of conduct and sustainable-procurement policies that require bidders to evidence action on their carbon footprint. The University of Manchester, for example, has set a target of zero direct carbon emissions and engages suppliers through its Supply Chain Code of Conduct — a concrete, local Scope 3 pressure on any business wanting to trade with a major anchor institution. We cover this regional dimension in detail on our ESG compliance in Manchester page, and the same anchor-institution pattern repeats around every large university city, including Birmingham, Bristol and Cambridge.
Why a supplier’s Scope 3 is the buyer’s problem — and yours
The reason carbon questions have spread so far down the supply chain is structural, and it is worth understanding because it explains why the pressure will only increase.
A large buyer’s own Scope 3 emissions — the emissions in its value chain, across the fifteen GHG Protocol categories — include the emissions of its suppliers. Your Scope 1 and 2 are part of your customer’s Scope 3. So when a large customer commits to reducing its Scope 3, or has to report material Scope 3 information, it has no choice but to ask its suppliers for data. That is what turns Scope 3 from an accounting abstraction into a live tender and PQQ issue. We explain the mechanics of value-chain emissions on our Scope 3 and supply-chain emissions hub.
Stat callout — the pressure point. For many organisations, Scope 3 is the largest part of the total footprint, which is precisely why buyers cannot hit their own targets without engaging suppliers. If you are in a large customer’s or public buyer’s supply chain, expect to be asked — the only question is whether you are ready.
This is also why SMEs get pulled in despite sitting well below the SECR reporting thresholds. An SME rarely has a direct legal duty to disclose its emissions. But a prime contractor that must publish a Carbon Reduction Plan, or a corporate customer reporting its Scope 3, will require a footprint and a reduction plan from its supply chain regardless. The honest framing is that the driver is commercial, not statutory — but the commercial driver is every bit as binding when a contract depends on it.
What “good” evidence looks like — and what gets marked down
Buyers and their evaluators have read enough vague sustainability statements to spot one instantly. The difference between a scoring answer and a filler answer is quantification and methodology.
What scores:
- A carbon footprint stated in tonnes of CO2 equivalent, with the reporting boundary and base year named.
- Emissions calculated on the UK government conversion factors for company reporting — the recognised, defensible dataset — with the methodology disclosed.
- A target with a date, ideally with interim milestones, and honesty about whether it is externally validated (for example to the Science Based Targets initiative) or an internal commitment.
- A named owner and a description of governance, so the buyer can see the commitment is managed, not aspirational.
- Both location-based and market-based Scope 2 figures where the business buys renewable electricity, rather than cherry-picking the flattering number.
What gets marked down — or fails:
- “We are passionate about sustainability” with no numbers. This is the single most common weak answer and it scores close to zero.
- An unquantified net-zero or carbon-neutral claim with no baseline or plan behind it — which is not only weak in a tender but a greenwashing risk under the Competition and Markets Authority’s Green Claims Code.
- A footprint with no stated methodology or boundary, which an evaluator cannot rely on.
- A Carbon Reduction Plan that is out of date, or that quietly omits the Scope 3 categories PPN 006 requires.
The pattern is consistent across the public sector and large private buyers: the evidence that wins work is the same quantified, methodologically sound disclosure that satisfies an auditor. Getting the underlying carbon footprint and baseline right is what makes every tender answer credible, because the same numbers feed the CRP, the SQ response and any SECR disclosure you also have to file.
PPN 06/21 is the wrong name now — and why that matters
A surprising amount of bid guidance, template libraries and even buyer documentation still refers to PPN 06/21. That label is superseded. The current policy is PPN 006, updated to reflect the Procurement Act 2023 and in force for procurements commenced on or after 24 February 2025.
This matters for two reasons. First, if your bid library still cites 06/21, it signals to an evaluator that your compliance material has not been refreshed — a small but real credibility cost. Second, the underlying detail has moved with the new procurement regime, so working from an old note risks missing a current requirement. Being current on the procurement rules is a concrete, checkable authority signal, and it is exactly the kind of thing a specialist keeps straight so you do not have to.
How to get tender-ready before the next bid closes
If your business bids for public-sector or large private-sector work, the sequence to get ahead of this is straightforward, and it is the same work whether the trigger is PPN 006, an NHS assessment or a corporate customer’s supply-chain questionnaire:
- Build a defensible carbon baseline. A Scope 1 and 2 inventory on the GHG Protocol and the UK government conversion factors, with a screened view of your material Scope 3 categories. This is the foundation every tender answer draws on.
- Set a dated target. A commitment to net zero by 2050 at minimum, with a near-term reduction target, and a clear position on whether it is externally validated.
- Produce and publish a Carbon Reduction Plan to the PPN 006 standard if you bid, or expect to bid, above the £5 million central-government threshold — and keep it current, because it has to reflect your latest year.
- Assemble the supporting policy set — environmental policy, environmental management arrangements, modern slavery statement — proportionate to your size.
- Name an owner. Give a real person accountability for environmental performance and describe how it is governed.
Do that once, properly, and the next tender’s carbon section stops being a fire drill. It becomes a strength you can point at.
For the detail of what a programme costs and how it is scoped to your business, see our ESG compliance cost guide; for the funding available for the decarbonisation measures a plan recommends (the reporting itself is a paid professional service, not a grant), see our grants and funding page. For the wider regulatory picture — how tender requirements sit alongside SECR, TCFD-aligned disclosure and the emerging standards — our UK ESG compliance specialists will tell you honestly which duties actually bind your business.
If you have a live bid that requires a Carbon Reduction Plan you do not yet have, the fastest route is a short readiness conversation. Use the enquiry form below, or request a quote, and we will tell you what the specific tender needs and whether it is deliverable in the time you have.
Related reading
- UK SRS and the ISSB: what UK companies need to know — how the emerging reporting standards fit the wider picture.
- How to build a carbon baseline — the foundation every Carbon Reduction Plan and tender answer depends on.
Government sources, verified 2 July 2026: PPN 006 on Carbon Reduction Plans in major government contracts (gov.uk) and the UK government environmental reporting guidelines including SECR (gov.uk).
Frequently asked questions
What is a Carbon Reduction Plan under PPN 006?
A Carbon Reduction Plan (CRP) is a published document that confirms a supplier's commitment to reaching net zero by 2050, states its current carbon footprint, and sets out the measures it is taking to reduce emissions. Under Procurement Policy Note 006 — which updated the former PPN 06/21 to reflect the Procurement Act 2023 — a compliant CRP is required from suppliers bidding for major central-government contracts with an estimated value above £5 million a year including VAT. It must be produced to the technical standard the policy specifies, cover the supplier's UK Scope 1 and 2 emissions plus a defined subset of Scope 3, and be published on the bidder's website. Verified against gov.uk as at 2 July 2026.
Does the £5 million PPN 006 threshold apply to every public tender?
No. The formal PPN 006 Carbon Reduction Plan requirement applies specifically to major central-government contracts with an estimated value above £5 million per year including VAT. Below that threshold, and for the wider public sector such as local authorities, NHS trusts and universities, there is no automatic PPN 006 duty, but those buyers increasingly build their own carbon and sustainability questions into selection questionnaires as a matter of procurement policy. The practical result is that carbon evidence is asked for well below the £5 million line, just not always under the PPN 006 label.
We are an SME bidding as a subcontractor — do we need ESG evidence too?
Often, yes, even though the direct legal duty may sit with the main contractor. A large prime contractor that has to publish a Carbon Reduction Plan, or that reports its own Scope 3 value-chain emissions, will pass carbon and sustainability questions down to its supply chain, because your emissions form part of its footprint. So an SME below the SECR reporting thresholds frequently still needs a credible carbon baseline and a simple reduction plan to stay in a prime's supply chain or to win subcontract work. We are honest about the distinction: the pressure is commercial and contractual rather than a direct statutory reporting duty on the SME itself.
Talk to an ESG compliance specialist
Responds within one working day
- 1. Readiness call — an honest read on which duties (SECR, TCFD-aligned disclosure, PPN 006) actually apply, no obligation.
- 2. Scoped proposal — a programme priced on your size, sites and reporting scope, set out in writing.
- 3. Delivered & assurance-ready — baseline, report and net-zero roadmap built to the GHG Protocol.
- GHG Protocol
- ISO 14064-1
- SBTi
- TCFD-aligned