Under PPN 06/21, an organisation submits one Carbon Reduction Plan covering all its operations, not separate plans for each site. The CRP must include baseline emissions aggregated across all locations under the organisation's operational control.
You need one Carbon Reduction Plan, not separate plans for each site. According to the UK Government's PPN 06/21, the Carbon Reduction Plan is an organisational document that covers the entirety of your business operations.
This is one of the most common questions multi-site businesses ask when preparing for government contract bids. The confusion often arises because different sites may have very different emissions profiles, leading businesses to assume they need individual plans. However, the PPN 06/21 template and guidance are unambiguous: one organisation, one CRP. The plan must report your total organisational Scope 1, 2, and 3 emissions, with all sites consolidated into a single set of figures.
According to the UK Government's procurement policy, contracts valued at £5 million or more require suppliers to submit a CRP as part of the selection process. This CRP represents your entire organisation, not a specific division, department, or location. When a procurement team reviews your submission, they are assessing whether your organisation as a whole has measured its carbon footprint and committed to reducing it. A per-site plan would not satisfy this requirement.
That said, best practice is to include a per-site breakdown within your single CRP. This demonstrates to evaluators that you have granular understanding of where your emissions originate and where reductions can be targeted most effectively. Many successful bidders include a table showing each site's contribution to the overall footprint, broken down by Scope 1 and Scope 2 emissions. This level of detail, contained within one unified document, is what sets strong CRP submissions apart from basic ones.
Operational control determines which sites fall within your CRP boundary. According to the GHG Protocol Corporate Standard, you have operational control over a site if your organisation has the authority to introduce and implement operating policies at that location.
For most multi-site businesses, this is straightforward. If you own or lease offices, warehouses, or retail units and your organisation manages the day-to-day operations, including decisions about heating, lighting, and equipment, those sites are under your operational control. All emissions from these sites must be included in your CRP. You cannot selectively exclude sites that are inconvenient to measure or that have high emissions.
The distinction becomes more nuanced with serviced offices, co-working spaces, and managed properties. If you occupy a desk or suite in a serviced office where the building operator controls the energy systems, you may not have operational control over the building's Scope 1 and 2 emissions. In this case, the energy consumed by the building would appear in your Scope 3 emissions under "upstream leased assets." However, if you lease an entire floor and control the heating and lighting for that space, it likely falls within your operational control boundary.
According to DEFRA's environmental reporting guidelines, organisations should document their chosen consolidation approach and apply it consistently. If you determine that a particular site falls outside your operational control, you must explain why in your CRP methodology. Procurement evaluators will look for logical consistency in how you have drawn your organisational boundary. Excluding sites without justification raises red flags during evaluation, particularly for contracts valued at £5 million or more where scrutiny is highest.
Within your single CRP, a well-structured site breakdown adds significant credibility. While PPN 06/21 does not mandate a per-site table, including one demonstrates methodological rigour and helps procurement teams understand your emissions profile.
The recommended structure is a simple table listing each site with its location, type (office, warehouse, manufacturing, retail), floor area, headcount, and Scope 1 and Scope 2 emissions. This gives evaluators immediate visibility into your operational footprint. For example, a business with three offices and two warehouses might show that the warehouses account for 70% of total emissions despite having only 20% of the headcount, because they consume significant amounts of gas for heating large spaces.
Below the site breakdown, your CRP should present the aggregated totals. Sum all Scope 1 emissions across sites, then all Scope 2, then all Scope 3. These aggregated figures are what PPN 06/21 requires. The per-site detail is supporting evidence that your aggregated numbers are grounded in real, location-specific data rather than rough estimates or industry averages.
When presenting reduction targets, you can reference specific sites where you plan to implement measures. For instance, "We will install LED lighting across our Birmingham and Manchester warehouses, reducing Scope 2 emissions by an estimated 15 tonnes CO2e annually." This site-specific detail within an organisational-level CRP shows that your reduction plan is practical and actionable, not just aspirational. For more on how to structure your CRP, see our guide on multi-site carbon reporting.
Subsidiaries that are separate legal entities bidding for contracts in their own right will each need their own CRP. According to PPN 06/21, the CRP is tied to the organisation submitting the bid, which is identified by its legal entity and registration details.
If a parent company has three subsidiaries, each registered as separate companies at Companies House, and each subsidiary bids independently for government contracts, then each subsidiary needs its own CRP covering only the sites under its operational control. The parent company does not submit one overarching CRP on behalf of all subsidiaries unless the parent itself is the bidding entity.
This distinction matters for group structures where a holding company owns multiple operating businesses. If the holding company bids for a contract and then subcontracts work to its subsidiaries, the holding company's CRP must cover all sites across its subsidiaries that fall under its operational control. According to the GHG Protocol, if the holding company sets operating policies for its subsidiaries, it has operational control and must include their emissions.
Conversely, if subsidiaries operate autonomously with their own management teams and policies, each subsidiary has operational control over its own sites. In this case, separate CRPs are appropriate. The key test is not the legal ownership structure but who has the authority to introduce and implement operating policies. Document this clearly in your CRP to avoid confusion during procurement evaluation. Among the UK's 5.5 million SMBs, many operate through group structures, and getting this boundary definition right is critical for compliant CRP submissions.
Consider a facilities management company with a head office in London, regional offices in Birmingham and Leeds, and 50 client sites where their staff work daily. The head office and regional offices are clearly under operational control and must be included. The client sites are more complex: if the company's staff work at client premises where the client controls heating and lighting, those sites likely fall outside the company's operational control boundary.
In this scenario, the company's CRP would include Scope 1 and 2 emissions from its three offices, plus Scope 3 emissions for employee commuting and business travel to client sites. The energy consumed at client premises would not be reported unless the facilities management company controls those energy systems. According to the GHG Protocol Corporate Standard, the company should document this boundary decision and explain why client sites are excluded from its Scope 1 and 2 reporting.
Another example: a retail chain with 12 high-street stores and a distribution warehouse. All 13 sites are under operational control, so the CRP must include electricity and gas consumption from every location. The distribution warehouse likely uses gas-powered forklifts (Scope 1) and significant electricity for lighting and refrigeration (Scope 2). The retail stores may primarily consume electricity with minimal gas usage. All of these emissions aggregate into one set of organisational totals in the CRP.
A third example involves a professional services firm with five offices nationwide, plus 30 staff working from home permanently. The five offices clearly fall within the CRP boundary. According to DEFRA's environmental reporting guidelines, home-working emissions can be reported under Scope 3 as "employee commuting" or "other" emissions. The firm should include an estimate of home-working energy consumption, calculated using the DEFRA homeworking emission factor, which accounts for the additional electricity and heating employees use when working from home. This demonstrates comprehensive reporting and strengthens the CRP submission for bids on contracts valued at £5 million or more.
Awais built CarbonPass to help UK SMBs navigate PPN 006 procurement requirements without expensive consultants. With a background in technology and compliance, he's focused on making carbon reporting accessible and affordable for small businesses bidding for government and NHS contracts.
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View Business plan →No. PPN 06/21 requires one Carbon Reduction Plan per organisation, not per site. Your CRP must cover emissions from all locations under your operational control. Submitting separate plans for individual offices would not meet the procurement requirement and could lead to disqualification from the bidding process.
Your CRP should cover all sites under your operational control, including international locations. Use DEFRA emission factors for UK sites and country-specific grid factors for overseas locations. The GHG Protocol Corporate Standard provides guidance on applying consistent methodology across international operations while accounting for regional differences in electricity grid carbon intensity.
Include a site breakdown table within your single CRP showing each location, its type, and its Scope 1 and 2 emissions. This is not required by PPN 06/21 but is considered best practice and helps procurement evaluators understand your footprint distribution. Your total organisational figures should be the sum of all individual site contributions.
It depends on operational control. If the franchisor controls operating policies at each location, all franchise sites should be included in the franchisor organisation CRP. If individual franchisees operate independently and bid for contracts in their own right, each franchisee would need their own CRP covering only the sites they control.
Joint ventures require careful consideration of your consolidation approach. Under the operational control method, you include 100% of emissions from joint ventures where you have operational control, and exclude those where you do not. Under the equity share approach, you report emissions proportional to your ownership stake. Most organisations use operational control for PPN 06/21 compliance.
CarbonPass Business plan allows you to enter data for each site individually, then automatically consolidates everything into one CRP document. The platform calculates per-site emissions, aggregates totals across all locations, and generates a single Carbon Reduction Plan that meets PPN 06/21 requirements for multi-site organisations.