If you are a subcontractor on a public sector job, "do I need a Carbon Reduction Plan?" is one of those questions that gets three different answers from three different people. Here is what the government's own guidance says, where it stops, and where the pressure actually comes from.
What the guidance says
The Cabinet Office FAQ for PPN 06/21, the note PPN 006 replaced, answers it directly. A Carbon Reduction Plan is required from the organisation with whom the in-scope body will enter into a contract. There is no requirement for subcontractors to produce a plan under that policy.
Two exceptions are written into the same answer:
- A subcontractor that is also bidding in its own right. Where a subcontracted organisation is also bidding on a procurement itself, the plan is required for that separate submission only.
- A consortium. Where the response is completed on behalf of a consortium of suppliers, each member should complete a plan.
PPN 006 sits under the Procurement Act 2023 regime and carries the carbon requirement forward for contracts of £5 million a year or more. I could not retrieve a separate PPN 006 FAQ page to quote, so check the current note and the tender documents themselves for any change before you rely on this.
Why subcontractors get asked anyway
The same FAQ makes a point worth reading twice. Some suppliers set their own policies asking their supply chain for emissions data or a net zero commitment. That is separate from PPN 006. It is a commercial request from your customer, not a government exclusion test, and the guidance says to take questions on it up with the supplier asking.
In practice that is where subcontractors feel it:
- A main contractor's pre-qualification questionnaire asks for a plan or a net zero commitment.
- A framework requires members to publish one.
- A client's social value or sustainability schedule flows down a "supply chain carbon" clause.
None of those is the Procurement Policy Note excluding you. All of them can still cost you the work.
What to do when someone asks
- Find out who is asking and why. Is it the buyer under PPN 006, or your customer under its own policy? The answer changes what you owe.
- Read the wording. A request for "emissions data" is not a request for a published plan. Match your reply to what was asked.
- Say what you can do now. A short statement of your Scope 1 and 2 emissions, the method and the year is often enough for a questionnaire.
- Decide whether a plan is worth having. If you answer this question more than twice a year, one published plan removes the repeat work.
What a plan involves, in brief
If you do produce one, the guidance expects a plan published on your website, signed off within 12 months of the procurement, with a signed declaration committing to net zero by 2050 at the latest, your UK emissions and the environmental measures you can apply on the contract. The emissions section covers Scope 1 and 2 plus five Scope 3 categories: business travel, employee commuting, waste, and upstream and downstream transport and distribution. The PPN 006 guide walks through the template section by section, and the worked example shows what a finished one looks like.
A practical position for small subcontractors
You do not need an expensive consultant to answer a questionnaire. You need three things: your fuel and electricity records for a full year, the right conversion factors for that year, and a one-page statement of the result that you can send on request. That is a sound base whether or not the buyer ever asks for the full plan.
Where MetricOra fits
MetricOra lets a subcontractor keep fuel, energy and travel records in one place and produce a clean Scope 1 and 2 summary, with the factor set recorded against it. Field staff can photograph a delivery note or fuel receipt on site and the record lands in the review queue. See evidence capture and the methodology.
Frequently asked questions
Do subcontractors need a plan under PPN 006? Not under the policy, per the Cabinet Office FAQ for the earlier note. Check the current text.
When do they? When bidding in their own right, or as a consortium member.
Can my main contractor ask for one anyway? Yes. That is a commercial request, not the PPN.
Is it worth having one? Often, if you get asked regularly.
Related reading
Sources
- PPN 06/21: Frequently asked questions, question 21, GOV.UK, updated 17 April 2023
- Procurement Policy Note 006, GOV.UK