What's Changing (and Not Changing) This April?
Carbon reporting has become an essential part of the NHS supplier landscape, progressively increasing in rigour and importance each year. With sustainability taking centre stage, understanding and navigating these reporting requirements is crucial for NHS suppliers. Interestingly, April 2025 is unique, presenting a rare respite in an otherwise intensifying compliance landscape.
A Quick Recap of Recent NHS Carbon Reporting Developments
The past few years have seen NHS suppliers adjust to increasingly stringent requirements:
- April 2022: NHS procurement began including at least a 10% weighting for Net Zero and social value.
- April 2023: Introduction of mandatory Carbon Reduction Plans (CRPs) for contracts valued over £5 million.
- April 2024: Expansion of CRP requirements to cover all NHS frameworks.
Suppliers have steadily adapted, meeting the new standards and gearing up for future demands.
April 2025: Calm before the storm
For the first time in recent memory, April 2025 does not introduce any additional carbon reporting obligations for NHS suppliers. This gap year offers a critical opportunity to reflect, consolidate, and prepare strategically rather than facing immediate new compliance pressures.
Looking Ahead: Preparing for the Next Wave of Carbon Reporting (2026-2029)
The roadmap ahead is clear and challenging:
- April 2026: Mandating Evergreen Level 1 assessments.
- April 2027: Mandatory comprehensive global Scope 3 carbon reporting.
- April 2028: Possible introduction of product-specific carbon footprinting.
- April 2029: Potential implementation of Evergreen Level 2 assessments.
Each milestone significantly increases the scrutiny and detail required, placing additional burdens on suppliers to improve transparency and sustainability practices.
Making the Most of This Unique Opportunity
April 2025 presents NHS suppliers with a unique opportunity to proactively enhance their carbon reporting readiness by reviewing and strengthening existing systems for accuracy, investing in capacity-building through training and advanced carbon accounting tools, proactively engaging with stakeholders and suppliers to prepare for comprehensive Scope 3 reporting, and strategically implementing sustainability initiatives to position themselves advantageously for upcoming compliance requirements.
Conclusion
Instead of viewing this year as simply a lull in compliance pressures, NHS suppliers should embrace it as a critical strategic opportunity. By proactively preparing now, organisations can ease future burdens, maintain compliance, and position themselves as leaders in sustainability.
