18 September 2026 A £40,000 freelance contract and a one-person business sit below every threshold that requires a calculated carbon footprint. I’ve spent a couple of years assuming tenders or clients would eventually make individual freelancers and “micro” sized companies count their carbon. It felt inevitable - reporting requirements are ratcheting up everywhere else, so why not here too? I even wondered if measuring freelancer emissions might be a business opportunity. Free online calculators are clunky. I’ve calculated my own scope 1-3 emissions by hand two years running, so I know the job is doable for a freelancer business that amounts to a desk, video calls, one heated room and a bit of saas and AI. The question was what the alternatives cost. Most providers won’t quote publicly. Two band by headcount: Green Business charges £599+VAT for a services-only business with 0-9 employees, and The Carbon Stamp quotes £1,495+VAT for 11-25 people. Self-serve software starts lower - £132 a year from Climate Essentials, £299 from Compare Your Footprint. And at the top end, a carbon measurement vendor told me in 2024 that they start detailed assessments at £4,000-4,500. £132 a year to £4,500, depending on how much of it someone else does for you. Lower than I’d assumed. I searched Contracts Finder for sub-£5m notices asking for a Carbon Reduction Plan, and found nothing, which fits what follows but doesn’t independently confirm it. So before building anything I spent an afternoon looking at 5 sets of rules to find the person who is forced to produce a carbon number. And… nope, they don’t exist. Here’s why: 1. Central government asks only above £5 million, including VAT PPN 006 requires a Carbon Reduction Plan for central government contracts “in excess of £5 million (including VAT) per annum”. It’s a condition of participation: the guidance says contracting authorities “must verify that the successful supplier satisfies the condition of participation…prior to award of the contract”. No plan, no contract. The VAT part is the single place in this post where a rule got wider rather than narrower. PPN 006 replaced PPN 06/21 in February 2025, and per NHS England it “changed the requirements to include VAT in the threshold for CRPs”, which “could mean that more activity is captured”. There’s no small-supplier exemption, but none is needed. The £5m threshold does the work - the Government Commercial Agency says: “This threshold means plenty of contracts are exempt from CRP requirements.” The rules do say that if you bid as part of a consortium, “a CRP should be completed by each consortium member” - so a small firm inside a big consortium bid does need one. Subcontractors, though, aren’t mentioned anywhere I can find. The obligation attaches to the bidding supplier, consortium members are named explicitly and subcontractors aren’t, so I read that as meaning you don’t need a plan to work on somebody else’s £5m contract. That’s me joining dots - I haven’t found a written rule saying that. 2. The NHS asks for a plan, a sentence, or nothing at all Since April 2024 the NHS has “proportionately extended” its Carbon Reduction Plan requirements to cover all new procurements. The proportionality is the whole story, and it comes in three tiers. £5m a year and above, including VAT: the full Carbon Reduction Plan. Scopes 1 and 2, five categories of scope 3, board approved, published, updated annually. The same applies to new frameworks “irrespective of the value of the contract, where relevant and proportionate to the framework”. Below £5m but above the relevant procurement threshold: a Net Zero Commitment. A public commitment to reach net zero by 2050 or earlier, signposted and published on your website. No measurement, no plan. Below the procurement threshold: nothing at all. There’s an exceptional circumstances provision too. Suppliers with “an acceptable reason for being unable to gather emissions data” can submit a plan with whatever emissions they do have, an explanation of the gaps, and the steps they’ll take to improve. Small businesses and voluntary sector organisations (VCSEs) with acceptable reasons may use it. And there’s an interesting carve-out: a CRP requirement can be disapplied where “a light touch contract, framework or dynamic market is set up…to support SMEs or VCSEs to access public contracts, and the request to implement a CRP could be a barrier to entry”. The requirements do cover all new procurements, which is true, and which is easy to quote without the word “proportionately”. At least one consultancy guide states flatly that the NHS requires Carbon Reduction Plans at all contract values. It doesn’t - below £5m it isn’t a plan, it’s a sentence. And below the procurement threshold it isn’t even that. 3. G-Cloud 15 and DOS 7 ask by lot, not by contract value Both G-Cloud 15 and DOS 7 come from the same place - the Government Commercial Agency - and work the same way. A Carbon Reduction Plan is a “Condition of participation - Carbon reduction” on specific lots, and you satisfy it by publishing your plan on your own website. The template in the tender pack is only there for bidders who haven’t got a website to put one on. G-Cloud 15 applies it to Lots 1a and 1b only - cloud hosting, IaaS and PaaS. Software and support suppliers, which is most of the framework, need nothing. DOS 7 applies it to Lot 2 only - digital capability and delivery partners. Lots 1, 3 and 4, which is where individual specialists sit, ask for nothing to join. The NHS framework carve-in above does the same thing. It’s frameworks, not contract values, where this reaches down towards smaller suppliers. The other place where a small supplier might get asked for a number is here: both frameworks carry an optional call-off schedule 26: carbon reduction, which lets a buyer apply carbon reduction plan provisions to an individual contract, whatever lot you’re in and whatever it’s worth. Nothing to get on the framework. Something, occasionally, to win a job on it - at the buyer’s discretion rather than as a rule. 4. Scotland asks for emissions sources, not a calculation Scottish public bodies use question 4C.7 of the Single Procurement Document, which asks bidders for a Bidder Climate Change Plan at selection stage. There are two standard templates, published with guidance on the Procurement Journey: Priority contracts (£4 million or greater, and/or commodities the buyer has identified as climate priorities): identify your emissions sources, provide calculated scope 1 and 2 emissions, a reduction timeline, and your actions. Everything else: identify your emissions sources across scopes 1, 2 and 3, and list what you’re doing about them. The guidance is explicit that this template “does not ask bidders to calculate their carbon emissions”. SPPN 3/2022: “For lower value, lower risk contracts, users are encouraged to adopt a lighter touch in the form of a climate change plan which includes emissions sources and actions only”. And then it goes further, and tells buyers to ask for less even when they could ask for more: “To reduce barriers to participation in a procurement process, you may wish to use the ‘relevant’ template for higher value/ priority contracts. For example, for frameworks or Dynamic Purchasing System (DPS) exercises where smaller enterprises may be expected to bid.” So: an instruction to ask for less than the rules entitle you to, if small firms might be in the room. 5. The EU caps what large companies can ask of small suppliers The Commission adopted a delegated act on 3 July 2026 establishing a voluntary sustainability reporting standard for smaller companies. Its title says what it’s for: “sustainability reporting standards for voluntary use by undertakings protected by the value chain cap”. The cap is a prohibition - in the Commission’s own words, it “prohibits CSRD companies from requiring companies in their value chain that have 1000 employees or fewer, to provide more sustainability information than the content of” that standard. The standard itself is “intended for undertakings which, on their balance sheet dates, do not exceed an average number of 1000 employees”, with a footnote confirming that “includes self-employed, non-incorporated undertakings”. So the standard is a ceiling. If you’re small, the Basic Module “is the target approach for micro-undertakings”, and inside it disclosure B3 covers energy and greenhouse gas emissions - scope 1, and location-based scope 2. The adopted annex: “[Voluntary for undertakings with 10 employees or less]”. Same tag on energy consumption, on water, on waste. The act says why: “To ensure that the standard is proportionate for undertakings of different sizes, some datapoints are voluntary for undertakings with 10 employees or less even though they are essential datapoints for other undertakings applying the standard.” Scope 3 isn’t in the Basic Module at all - it appears in the Comprehensive Module as a “consideration when reporting sector information”, aimed at SMEs in manufacturing, agrifood, construction and packaging. So the ceiling on what Europe’s largest companies may demand from a ten-person supplier contains no emissions figure at all, unless that supplier volunteers one. It applies to financial years beginning on or after 1 January 2027, with early adoption permitted for 2026. But nb: it is not yet in force, awaiting publication in the Official Journal. Every other rule in this post protects small suppliers by accident of where a threshold happens to sit. This one says it out loud. And in the private sector? A few of my customers have asked for input to their own emissions calculations, typically by spend or days worked/distance travelled, but I haven’t seen anyone making it mandatory. That seems to be usual. The SME Climate Hub’s 2025 survey found that “only 17% of SMEs have been asked by corporate customers to reduce emissions and only 15% have been asked by individual customers” (p6) - and that’s among businesses committed enough to climate action to have joined a climate network. Big companies measuring their scope 3 tend to work from spend. One example: in 2025 Colt Technology Services joined CDP’s Supply Chain membership, which “enabled us to engage with our top 200 suppliers and request carbon footprint data”. Out of those 200, they “integrated supplier specific data from 18 suppliers, whose information met quality criteria including carbon footprint verification and geographical accuracy” (Colt Group Sustainability Report 2025, p41). Everyone below the line gets estimated using spend-based emission factors, which requires nothing from the supplier, who might not even know it happened. If you invoice a large client £40,000 a year, you are not in anybody’s top 200. Asking for a paragraph makes this a harder business OK, back to the business idea. Government bodies landed on the same design: ask small suppliers for a commitment and a list of actions. Save the calculated numbers for large contracts. The artefact a small supplier is compelled to produce isn’t a spreadsheet, it’s a paragraph. This means the measurement-tool-as-business-idea is a long shot, because the person who has to buy it doesn’t exist, and five separate policy regimes have independently declined to create one. Whether small businesses would pay for help with something they want to do is a different question, perhaps with harder answers. The SME Climate Hub’s 2025 survey suggests not many will: 78% of respondents calculate their emissions, 42% use a free calculator, and 17% pay for a calculator or measurement services (p9). Those respondents are 471 businesses, 54% of them in the UK, 45% of them with ten employees or fewer, self-selected from a climate network’s committed members and tool users. About as motivated a customer base as this market has, and weighted towards exactly the companies I had in mind. I don’t know yet why the other 83% don’t pay. It might be that they won’t at any price. It might be that nothing on offer is worth it. But the likeliest reading is the simplest: the job is already getting done adequately, at no cost. And 41% of the same respondents say the cost of reporting is too high (p9), while 55% say what they need is tools for measuring and monitoring emissions (p7) - which is the case for building a better one. There are, by a British Business Bank and Icebreaker One count, “over 270 carbon accounting providers targeting SMEs” (p22). I nearly became the 271st, and would have been building it against free. Though: the thing that beat me is a free tool, chosen by many of the most motivated small businesses on the planet. That’s an argument against a business, but not against a calculator. If you run a small business and someone - a client, a tender, a framework, a bank - has asked you for something on climate in the last year, I’d like to know what they actually asked for, and what you did about it. Because yes I’m still thinking about it. This post was researched with Claude, tediously fact-checked by me, written by both of us. Claude did the svg diagram, neat.