SDF2 (Scheme Delivery Framework 2): carbon reduction plans, PAS 2080, and what bidders need to have ready

In this article, we'll cover all you need to know to meet carbon requirements for National Highways’ SDF2 procurement.

What is SDF2 (Scheme Delivery Framework 2)?

SDF2 is National Highways’ next major framework for work on England’s Strategic Road Network (SRN) – the motorways and major A-roads. It builds on earlier frameworks (SDF and the Pavement Delivery Framework) and is set up to renew and maintain existing assets.

National Highways describes SDF2 as an “enabled” framework, meaning it is intended to facilitate usage by other programmes/suppliers too (for example, Lower Thames Crossing and Maintenance & Response suppliers).

Who is SDF2 for?

At a high level, SDF2 is relevant to organisations involved in design and delivery across renewals and maintenance work on the SRN. National Highways is using a lot-based approach that includes access for specialists, and – whilst you don’t need to memorise the lot structure to understand the carbon point – it’s worth knowing that SDF2 is built to cover a wide range of work types – from complex work orders needing a single prime supplier, through to specialist delivery.

SDF2 procurement timeline (key dates)

National Highways includes an indicative procurement timeline in the Information Memorandum, and flags that dates may be subject to change. You can see them below:

What's happened already:

29 September 2025 – UK4 Tender Notice published
24 October 2025 – last date for applicants to submit CoP queries
14 November 2025 – CoP return deadline

What's coming up (at the time of writing):

April 2026 – Invitation to Tender (ITT) expected
Quarter 2 2027 – framework award & mobilisation

Remember: treat the tender notice and any portal updates as the source of truth when it comes to timelines.

What are the carbon reporting requirements for direct bidders under SDF2

National Highways is explicit that carbon management is not “nice to have” in SDF2. SDF2 will “embed carbon management as a contractual requirement throughout the Framework lifecycle” as part of its objective to deliver low-carbon infrastructure and achieve net zero for maintenance and construction by 2040.

In practice, National Highways enforced carbon management as an explicit entry requirement for SDF2, checking at CoP that all direct Applicants had:

An active Carbon Reduction Plan, and
Plans in place for PAS 2080 certification, or (for smaller, specialist suppliers) an environmental plan aligned to PAS 2080 requirements.

So: 14 November 2025 was the key “carbon gate” date for any organisation bidding directly onto SDF2, not just prime contractors.

Going forward, active carbon management is expected to show up not only in tender responses, but in how work is delivered once on the framework.

What are the key SDF2 dates for carbon compliance for non-prime suppliers?

In practice, if you're a non-applicant supplier, your key dates are driven by when Applicants need to prepare bids and delivery plans (and therefore start locking down their supply chain and evidence):

April 2026 – ITT issued (expected): Applicants start building tender responses and delivery plans, including how they will manage carbon across their supply chain.
Tender period after ITT: Applicants firm up delivery partners and ask for evidence and data. (The IM provides indicative timing.)
Q2 2027 – framework award & mobilisation: Applicants move from “bid mode” into “delivery mode”, including contractual carbon requirements and reporting.

Rule of thumb: if you want to be an easy “yes” for an Applicant, have your carbon pack ready before April 2026, not halfway through their tender work.

Do non-prime suppliers under SDF2 need a Carbon Reduction Plan or PAS 2080 certification?

If you are only a subcontractor to a prime (not an Applicant), the IM doesn’t spell out a separate CRP/PAS 2080 mandate for you.

What it does say is:

carbon management will be a contractual requirement throughout the framework lifecycle
and the contracting model includes subcontract flow down provisions for framework suppliers to contract with other suppliers (including those outside the framework).

That combination is why this tends to “trickle down” in practice: primes will need carbon data and credible plans from their supply chain to meet their own contractual duties. But that expectation is an inference from how frameworks operate – it’s not written as a standalone “subcontractors must have X” rule in the IM.

Plain-English takeaway for non-prime SDF2 suppliers‍

Even if you’re not bidding as a prime, you’re likely going to be asked by primes for (at minimum) a Carbon Reduction Plan and some evidence you can work in a PAS 2080-aligned way – because they can’t carry the carbon requirement alone.

Carbon readiness checklist for SDF2 suppliers

If you’re supplying to an organisation bidding onto SDF2, you will likely be asked for carbon information so they can demonstrate supply chain capability and meet their contractual carbon obligations. This checklist is aimed at making you easy to onboard as a supplier.

1) Carbon Reduction Plan (CRP): have the standard document ready to share

A Carbon Reduction Plan is usually expected in a recognisable, set format (the one commonly used for UK public sector bids). For supply chain use, make sure yours is:

Current (updated within 6 months of your latest FY end).
Complete (covers baseline, current emissions reporting, reduction targets, and the actions you’re taking).
Owned (named responsible person and sign-off).
Publicly available (published on website)

To learn more about Carbon Reduction Plan compliance - and for a guided template to get you started - head here.

2) PAS 2080: have a short statement of how you align

You may be asked how you work in a way that supports PAS 2080-style carbon management. Keep this factual and brief:

Current status: certified / working towards certification / not certified.
What you do in practice: how you identify and choose lower-carbon options in your scope (materials, transport, plant, waste, design choices where relevant).
How it’s managed: who is responsible, and how it is checked on projects.

3) Timing: don’t wait to be asked

Because the CoP deadline has already passed, your timing is now driven by tendering and mobilisation. If you want to be included in bids and early delivery planning, have your CRP and PAS 2080 statement ready before bidders finalise supply chains and method statements.

SDF2 carbon FAQs

I’m a specialist / subcontractor (not bidding directly). Do I need a Carbon Reduction Plan?
National Highways’ formal check is on Applicants (organisations bidding directly onto SDF2) at the CoP stage.
But in practice, if you want to supply into SDF2 work, expect Applicants to ask you for a CRP (and to use your info in their delivery and reporting approach), because carbon management is intended to be contractual across the framework lifecycle.

What does National Highways mean by a Carbon Reduction Plan (CRP) in this context?‍

The CoP guidance sets a pass/fail check for Applicants’ CRPs, including that the CRP:

confirms a Net Zero by 2050 commitment,
reports emissions for required scopes (per the required methodology), and
has a reporting period within 12 months of the procurement start (with some conditions/exemptions).

For supply chain suppliers, this is still a useful benchmark for what “bid-ready” tends to look like.

I’m not an Applicant. Is PAS 2080 mandatory for me?‍

The SDF2 documents set expectations at CoP for Applicants (plans in place to be certified to PAS 2080, or for small suppliers an environmental plan aligned to PAS 2080).
They don’t spell out a separate “must” rule for non-Applicants, but you should expect PAS 2080 to come up in supply chain conversations because it’s referenced in the procurement materials and appears in carbon scoring guidance.

What should I have ready to send to an Applicant asking about carbon?‍

At minimum:

your Carbon Reduction Plan (CRP) (in the standard public-sector style), and
a short PAS 2080 statement (certified / working towards / aligned approach and what that means in your delivery).

Does carbon still matter after the framework is awarded?‍

Yes. The IM states SDF2 will embed carbon management as a contractual requirement throughout the framework lifecycle.

How Seedling can help with SDF2 carbon compliance

If you’re looking to supply to SDF2, you’ll probably get asked for carbon info as part of supplier onboarding and delivery planning.

At Seedling, we're experts at helping growing teams to meet carbon reporting requirements, without it becoming a full-time job.

With our easy-to-use carbon footprint software - plus one-to-one support from a dedicated carbon expert -Seedling can help you get ready, with:

A Carbon Reduction Plan (CRP) in the standard public-sector format (up to date and ready to share)
A short PAS 2080 statement explaining how you manage and reduce carbon in delivery
A simple “carbon pack” you can send when someone asks, so you’re not pulling it together from scratch every time

If SDF2 work is on your horizon and you want to get your CRP and PAS 2080 story sorted, book a call with the Seedling team to see how we can help!

Key resources (official documents)

Find a Tender – Scheme Delivery Framework 2 (SDF2) tender notice (National Highways)
The main public notice page with the official summary and procurement details.
SDF2 Information Memorandum (Attachment A-5623)
The core “how SDF2 works” document (including the carbon expectations).
SDF2 Conditions of Participation (CoP) Guidance (Attachment A-5624)
The selection-stage guidance, including what National Highways will verify at CoP (where the carbon reduction plan requirement sits).