Lead by example through government and the public sector implementing mandatory standards, regulations and business practices that meet the urgency and scale of the climate emergency.

The Scottish Government has a vital role to play in leading by example and providing clear standards, regulations, and guidance over future government policy, regulations, and the path of public investment. We are laying the ground for new sustainable markets in net zero products and services that will stimulate private investment over the coming years.

Scotland’s public sector bodies have a strong leadership role in delivering the transition to net zero. Strengthened legislation requires public bodies to report on any targets they have for achieving zero direct emissions and reducing indirect emissions.

The Climate Change (Scotland) Act 2009 makes provision for targets for the reduction of greenhouse gases emissions and also makes provision about advice, plans and reports in relation to those targets, with the objective of Scotland contributing appropriately to the world’s efforts to deliver on the Paris Agreement. Business action will be crucial in order to meet Scotland’s emissions reduction targets in a way that is just and fair, capturing the economic and social benefits of a net zero economy.

Following analysis of the Assembly’s recommendations, the Scottish Government will take the following actions:

  • We will consult on measures to support businesses in transitioning to net zero including, for large businesses, annual public disclosure of how climate change will affect their business.
  • We will consult on requiring a published carbon management plan for achieving emissions reductions at a level consistent with Scotland’s 2045 net zero target for businesses receiving grant or loan / equity funding of over £500,000 and for major contracts.
  • We will review our public sector food procurement guidance document Catering for Change, alongside other work, considering how to integrate healthy, nutritious, plant-based and low carbon foods including sustainably produced fruit, vegetables, fish, seafood and meat, into public sector canteens.

Recommendation 18: Building and Trading Standards

Strengthen building and trading standards to quality assure energy efficiency work carried out by private companies, to make sure it actually delivers emission reductions to homes.


Scottish Government Response

The Scottish Government supports this recommendation and is taking action to strengthen standards.


We are currently consulting on a new Compliance Plan approach for our building regulations. This should increase assurance that building work meets the requirements of building regulations, through more detailed evidence on the design and construction process.

For retrofit work funded by Scottish Government, we will adopt the British Standards Institution (BSI) Publically Available Specification (PAS) 2035/30 standards. As well as ensuring Scottish Government funds high standard works, this will help to raise standards across the supply chain more broadly. Earlier this year, we also consulted on proposals to ensure that people involved in retrofit (assessors, installers, designers) have the appropriate skills to carry out works to the appropriate standards. Our proposals span qualifications and career paths, greater clarity in roles and responsibilities, and boosting skills in heat networks. We are also considering the potential for the TrustMark scheme to be used in Scotland as a way of helping consumers ensure works are carried out to required standards. As well as technical standards, TrustMark requires compliance with a Code of Conduct and Customer Charter. It helps consumers navigate the market by providing a list of registered businesses. Should we adopt TrustMark in Scotland, we will ensure that Trading Standards Scotland plays a key role. We will publish our analysis of this and the response to our skills consultation shortly.

Recommendation 19: Greenfield and Brownfield Development

Strengthen planning restrictions immediately so that development on greenfield sites should not be permitted until all other development options, such as brownfield and existing building repurposing, have been considered and legitimately rejected.

Children’s Parliament: Create more nature parks and stop green spaces from being built on. In towns and cities, create green, traffic free areas for children and adults to play.


Scottish Government Response

The Scottish Government supports this and is clear that the planning system can proactively support the re-use of vacant and derelict land and buildings.


As set out in response to Recommendation 8 alongside an explanation on the importance of the development plan, the draft NPF4 has been published for consultation. It will have the status of development plan for planning decisions once adopted. The draft sets out six spatial principles to build a climate-conscious and nature-positive future. One of those principles is ‘compact growth’, this limits urban expansion where brownfield, vacant and derelict land and buildings can be used more efficiently. This prioritises the re-use of vacant and derelict land and redundant buildings. The draft also sets out that development proposals on greenfield sites should not be supported unless the site has been allocated for development or the proposal is explicitly supported by policies in the development plan, and there are no suitable brownfield alternatives. As set out in response to other recommendations, including Recommendation 8, we welcome comments on the draft at this time, and further information is available from www.transformingplanning.scot.

Recommendation 20: Net Zero Public Sector by 2030

Require all public sector buildings, vehicles and supply chains to be net zero by 2030 with an interim target of 75% by 2027 and a target for absolute zero by 2035.

Children’s Parliament: Help schools to be environmentally-friendly. Schools can be places for planting trees.


Scottish Government Response

The Scottish Government agrees with the Assembly on the importance of rapidly decarbonising public sector buildings, vehicles and supply chains.


It is vital that the public sector takes the lead in decarbonising its estate. On 29 October 2021, the Scottish Government issued guidance for the public sector, entitled ‘Public Sector Leadership on the Global Climate Emergency’. The public sector is tasked with reducing emissions close to zero without offsetting, to support Scotland meeting its national climate change goals. Public bodies are expected to drive down emissions as close to zero as possible, as quickly as possible, and this includes addressing supply chain emissions.

While we are unable to commit to the timescales in the recommendations, we are committed to developing and agreeing, through consultation, a series of phased targets for the decarbonisation of public sector buildings starting in 2024, with the most difficult buildings like hospitals being decarbonised by 2038, and for all publicly-owned buildings to meet zero emission heating requirements, with a backstop of 2038. This is seven years earlier than the backstop of 2045 for the rest of the building stock. Accelerating delivery further will be extremely challenging and is likely to drive up costs and create supply chain shortages, particularly in the short term. Many parts of the public sector estate, including the NHS estate are technically complex to make fit for a net zero economy and may not currently be suitable for using available renewable heat technologies such as heat pumps. It will take time to design and develop other solutions, such as heat networks. For these parts of the public estate any work to convert the buildings to zero emission heating systems will need to be carefully planned to minimise disruption to health services and patients. Costs will need to be assessed on a building by building basis but these are expected to be significant and will need to be spread over a period of time. NHS Scotland purchases a wide range of goods from international suppliers and cannot ensure that suppliers in other countries operate with net zero emissions by 2030.

The Scottish Green Public Sector Estate Decarbonisation Scheme will distribute £200 million of capital support pledged over the next five year period to aid the decarbonisation of Scotland’s public sector estate. NHS Scotland’s £10 billion programme of investment in new hospitals and healthcare facilities is guided by a commitment that all new buildings and major refurbishments will be designed to produce net zero emissions and use renewable heat. The £2 billion Learning Estate Investment Programme, managed by the Scottish Futures Trust, aims to benefit around 50,000 pupils across Scotland by the end of the next Parliament by delivering digitally enabled, low-carbon schools and campuses.

Furthermore, Transport Scotland’s Switched on Fleets programme is supporting the transition of the public sector fleet to zero emission vehicles.

The 1140 Early Learning and Childcare (ELC) expansion programme continues to support the design and delivery of low carbon investment and infrastructure across the ELC estate by following a hierarchy of investment to use what we have, buy what we can and create only what we need. Whilst Net Zero was not a key target of the expansion at the outset, we have increasingly sought to embed the importance of Net Zero in investment decision making. The approach taken to ELC service design during the expansion programme ensured that we made the best use of the existing public sector estate and reduced the carbon footprint of the investment.

Photo of Humza Yousaf MSP

Cabinet Secretary for Health and Social Care, Humza Yousaf MSP

“I was delighted to meet Assembly members to explore the recommendations. As representatives of Scotland’s citizens, hearing concerns first-hand and understanding the Assembly’s expectations has been invaluable in considering how to decarbonise the NHS as quickly as possible, whilst improving public health.”

Case Study: Balfour Hospital, Orkney – Scotland’s first net zero hospital

NHS Balfour Hospital is the first to operate as an all-electric acute services healthcare facility. Heating and hot water are provided by twin air source heat pumps. Green electricity is provided by an array of solar photovoltaic cells which powers low energy LED lighting and high frequency low loss fluorescent lighting in clinical areas, with lighting control software managing demand according to occupancy levels. The building fabric and components all contribute to reduced energy demand due to insulation properties, high construction standards and thermal efficiencies.

Balfour Hospital, NHS Orkney, Scotland’s first net zero hospital. Photo © Keppie Design and David Cadzow

Photo of Balfour Hospital

Recommendation 21: Sustainable Public Sector Procurement

Introduce a public sector procurement requirement for companies to provide details of their sustainability performance (measured against agreed standards) in any tenders for work, and for this to be used alongside costs in making the final decision on whom to select.


Scottish Government Response

The Scottish Government supports sustainable procurement and mechanisms are already in place to deliver on this recommendation.


The Scottish Government is committed to action on the climate impact of the £13.3 billion of annual public procurement in Scotland. The Scottish Government’s approach to sustainable public procurement is encapsulated in national legislation that encourages procurement to make the best use of public money by driving access to contracts for business; jobs and training; and reflecting climate change goals. The Procurement Reform (Scotland) Act 2014 introduced the Sustainable Procurement Duty, requiring public bodies to consider how they can improve the economic, social and environmental well-being of their constituency, and act in a way that secures the improvements identified.

Public bodies must set out in their Organisational Procurement Strategy how they will use procurement to drive local environmental well-being, and report progress in their annual Procurement reports.

The Scottish Government has developed the Sustainable Procurement Tools, to help public bodies adjust to a more resource-efficient and sustainable procurement practice. Launched in June 2020, this platform offers a one-stop shop for sustainable procurement guidance, tools, good practice examples, and e-Learning. Use of the Sustainable Procurement Tools has increased since the e-Learning was launched. A month prior to the launch, 350 users were enrolled on the Tools website. Currently, there are 1506 users from 293 organisations around the globe, demonstrating the success of this resource in engaging procurement professionals in climate action.

The Scottish Government established the cross sectoral Climate and Procurement Forum, providing leadership and direction for public bodies across Scotland to help address the Climate Emergency through their procurement activity. The Forum has identified and commissioned targeted activities which will help influence and empower buyers, suppliers and key stakeholder communities. The Forum will continue to take action to embed climate considerations in a ‘whether’, ‘what’, ‘how’ and ‘how much’ we buy approach through procurement and contract and supplier management activities, ensuring that Scottish private and third sector businesses are involved in this work, preventing barriers to participation.

Case Study: Driving Climate Literacy to Enable Local Action

The Scottish Government is driving low carbon procurement across the public sector. To achieve this we need a ‘climate literate’ workforce that can confidently embed sustainability into their spending decisions. We developed Climate Literacy e-Learning and revamped the Scottish Sustainable Procurement Toolkit to build understanding of the climate emergency across the public sector. Buyers, department directors, sustainability managers and facilities staff from 56 public sector organisations have used our eLearning, and have reported increased confidence that procurement can reduce carbon emissions. Our Sustainable Tools platform is also being used across the globe, driving innovative climate change solutions in public tenders locally.

Recommendation 22: Public Sector Vehicles

Make it mandatory for all public service vehicles (ambulances, police cars etc.) to have zero tailpipe emissions, extending to delivery vans and public transport where possible.


Scottish Government Response

The Scottish Government supports all public sector vehicles reaching zero tailpipe emissions as soon as possible.


The public sector is, and must remain, at the forefront of the shift to zero emission mobility, leading by example and contributing to change required to achieve our net zero emission ambitions. The Programme for Government 2019 set out the ambition for the public sector to decarbonise its fleet vehicles in stages, removing the need for all petrol and diesel vehicles, starting with cars and new light commercial vehicles by 2025 and all new vehicles by 2030, applying flexibility and pragmatism for front line, specialist and emergency service vehicles where required.

Public sector organisations have been procuring an increasing number of zero emission vehicles, supported by Transport Scotland’s Switched on Fleets programme. Significant progress has already been made across the public sector and many organisations have set target dates for their fleets to have zero, or close to zero, tailpipe emissions, for example:

  • Ultra-low emitting electric vehicles make up 53% of the Scottish Government’s current road fleet and our ambition is for a rationalised, fully electric fleet by 2025.
  • We have supported decarbonisation of fleets in local authorities since 2014 and in public bodies since 2019, with over £50 million invested to date, enabling the procurement of over 3,450 zero and ultra-low emission vehicles as well as charging and refuelling infrastructure.
  • Police Scotland's Fleet Strategy aims to have the UK's first ultra-low emission blue light fleet by 2030.
  • NHS Scotland aims to decarbonise their fleet of small and medium vehicles by 2025 and stop the purchase of all large fossil-fuelled vehicles by 2030.
  • We are working with the Bus Decarbonisation Taskforce to ensure that the majority of new buses purchased from 2024 are zero-emission, and to bring this date forward if possible.
  • Scotland’s passenger rail services will be decarbonised by 2035.

Whilst technology is not currently sufficiently developed for all frontline, emergency service and specialist vehicles to mandate the fleet to have zero tailpipe emissions immediately, urgent work is underway with manufacturers to develop zero emission vehicles. Switched on Fleets continues to support the Emergency Services, providing support and grant funding to assist the Police, Scottish Fire and Rescue Service and the Scottish Ambulance Service with the procurement of zero/low carbon vehicles to decarbonise their fleets.

Photo of Keith Brown MSP

Cabinet Secretary for Justice, Keith Brown MSP

“All parts of society need to take action to reach net zero. I’m particularly proud that Police Scotland's Fleet Strategy aims to have the UK's first ultra-low emission blue light fleet by 2030.” 

Recommendation 23: Benchmarked Standards

Establish strengthened benchmarked standards and set a requirement for public organisations and private companies to measure their annual progress on the path to net zero and publish this in a clear and transparent way.


Scottish Government Response

The Scottish Government supports the principle of the Assembly’s recommendation that there are strong benchmarked standards for public organisations and private companies to measure their annual progress on the path to net zero and for this information to be published.


The public sector has a crucial role to play across climate policy. The Scottish Government has enacted secondary legislation to strengthen the reporting duties of public bodies on their compliance with climate change duties. The new requirements, which came into force on 9 November 2020, require specified public bodies to demonstrate their contribution towards our national target of net zero emissions by 2045 by including in their annual reports on compliance with climate change duties, where applicable: a target date for achieving zero direct emissions; how the body aligns its spending plans and use of resources to contribute towards delivering its emissions reduction targets; how they will report on the progress it is making towards those targets; and how they are contributing to Scotland’s 2019 Climate Change Adaptation Programme.

The Scottish Government is committed to working in partnership with businesses to develop effective net zero transition planning, and to showcase progress and investment opportunities.

As part of the agreement between the Scottish Government and the Scottish Green Party, and influenced by the Assembly’s recommendations, we will consult on: the role of Just Transition Plans and the annual public disclosure of how climate change affects large businesses; and a commitment for all businesses receiving grants or loans in excess of £500,000 to reduce their greenhouse gas emissions and for this to be set out through a published carbon management plan. We anticipate this consultation will take place in the first half of next year. In the same time period we will be working with businesses to develop of guidance on Just Transition Planning, which will support businesses in transitioning to net zero.

For SMEs there are already a number of tools published with which businesses can measure their emissions and climate impact. This includes guidance from Zero Waste Scotland, a link to which is provided in our greener business guide.

As the Assembly acknowledges in its other recommendations, our approach needs to be balanced and flex as required given the differing nature of Scottish Businesses; responsibilities of a large cooperation will be very different to those of a small firm. In addition, our action will need to take into account ongoing developments at a UK level, in particular with regards to Climate Risk Disclosures and changes to the UK Companies Act, to avoid conflict, confusion or unintended consequences.

We will keep this work under review as it progresses in order to ensure we are being as ambitious as possible and meeting the spirit of the Assembly’s recommendations.

Recommendation 24: Electricity Generation

Produce a green paper contrasting different methods of electricity generation focusing on capacity to meet baseload, £ per KWH, embodied carbon, safety and environmental impact and use this paper to plan Scotland electricity generation in the future.

Children’s Parliament: Create more wind farms and solar panels so all energy in Scotland is renewable.


Scottish Government Response

The Scottish Government supports the ambition to ensure that plans for Scotland’s future electricity generation capacity is evidence led, and based on a clear understanding of the value that each technology brings to a net zero energy system.


The Scottish Government’s updated Climate Change Plan includes an ambition to ensure that electricity generation in Scotland is completely decarbonised by the end of the decade. In response to the Assembly’s recommendation, we will explore what this means for Scotland’s electricity generation mix, including the current portfolio, future make-up, influence on security of supply, climate change commitments, and economic and supply chain goals. This will be set out in our Energy Strategy and Just Transition Plan which will be the first of our sectoral Just Transition Plans. We will publish a draft of this document for consultation in Spring 2022, with the co-design process for that Plan commencing at the start of 2022.

Electricity generation and security of supply policy are reserved to the UK Government, and implemented by the National Grid, via regulation delivered by Ofgem. The Scottish Government continues to work closely with UK Government and wider sector to ensure that decisions about electricity markets, regulation and governance reflect Scotland’s needs.

Recommendation 25: Climate Change Business Bill

Introduce a ‘Climate Change Business Bill’, to be enacted within the next five years, which sets climate impact standards and requires all businesses to assess the carbon emissions of their business practices on climate change (against variable criteria depending on the size of the business). Establish an independent climate change regulatory authority to inspect, audit and ensure compliance.


Scottish Government Response

The Scottish Government supports the principle of the Assembly’s recommendation to set out climate impact standards and require businesses to assess the carbon emissions of their business practices on climate change.


UK legislation requires businesses over a certain size (most companies over 250 employees) to disclose their greenhouse gas emissions annually through their annual report and accounts. Provision for Streamlined Energy and Carbon Reporting (SECR) is made under the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. The Conduct Committee of the Financial Reporting Council is legally responsible for monitoring compliance of SECR reporting. If company annual reports do not meet the SECR requirements, the whole annual report can be rejected and a penalty applied for late compliance. In addition, on 3 November 2021, the UK Government announced that financial institutions and listed firms will also be required to publish net zero plans from 2023.

As a result of the Assembly’s recommendations, the Scottish Government will also encourage and incentivise SMEs to report on their greenhouse gas emissions, energy consumption and efficiency.

In addition, as set out in Recommendation 23, and agreed in the Scottish Government and Scottish Green Party shared policy programme we will also consult on measures to support businesses in transitioning to net zero including, for large businesses, annual public disclosure of how climate change will affect their business. We will also consult on requiring a published carbon management plan for achieving emissions reductions at a level consistent with Scotland’s 2045 net zero target for businesses receiving grant or loan / equity funding of over £500,000 and for major contracts.

The Scottish Government welcomes the Assembly’s acknowledgement that there is an important distinction between large and small businesses and that criteria ought to be flexible enough to recognise differences in resources and emissions. A significant proportion of Scotland’s business base is made up of sole traders and very small enterprises with fewer than 100 employees, many of which operate in sectors such as retail and leisure that were hardest hit by the pandemic, and taking on debt finance to survive. Our approach therefore needs to focus on support, guidance and incentivisation to lower carbon emissions as part of our just transition to our net zero target.

The Scottish Government will keep this work under review, particularly in light of our commitment to consult on Just Transition Plans and annual disclosure of climate change impacts, with a view to encouraging greater transparency and reporting as we transition to a net zero nation.

Recommendation 26: Plant-Based and Low Carbon Food

Immediately require government and public services to procure plant based and low carbon food for all public sector catering and canteens.

Children’s Parliament: Make more plant-based, animal-free options available in schools, nurseries and places where people work.


Scottish Government Response

The Scottish Government partially supports this recommendation and will review its public sector food procurement guidance document Catering for Change, alongside other work to make Scotland a Good Food Nation.

This updated guidance will help public bodies make sustainable choices when procuring food and catering services, including how to provide more locally produced and locally sourced food. As part of this review, we will carefully consider the Assembly’s recommendation and identify how we can integrate healthy, nutritious, plant-based and low carbon foods, including sustainably produced fruit, vegetables, fish, seafood and meat, into public sector canteens.


All public bodies in Scotland have a legal duty to take account of how they can improve the social, economic and environmental well-being of their area, acting to ensure improvements are made where identified. They can, and do, include criteria such as nutritional value and fresh and seasonal produce when procuring food. Menu planning helps to promote these factors. For example, the Scottish Government places an emphasis on healthy eating and nutrition, and promotes fresh and seasonal produce. We will continue to work with Public Health Scotland, Food Standards Scotland and other agencies to evaluate the evidence base surrounding diet, health and climate impacts and use that to inform future policy.

Education authorities also have a statutory duty to consider sustainability guidance published by Scottish Ministers as they procure food, drink and catering services in schools. ‘Better Eating, Better Learning’ guidance was produced to support this duty, alongside the public sector food procurement guidance document ‘Catering for Change’.

Food Standards Scotland have developed ‘Eat Well Your Way’, an online resource that helps consumers understand what a healthy balanced diet looks like by translating the ‘Eatwell Guide’ into meaningful, practical advice and tips to help people make healthier food and drink choices when planning, shopping and eating out. The resource contains a number of sustainability messages including reducing food waste and eating less meat. It is due for public launch in January 2022, and we will increase the sustainability messaging as it develops.

The Healthy Living Award, although suspended since the pandemic, has transformed the wider public sector in its provision of food, including mandating 70% healthier options in hospitals. The Prisons Service, the Scottish Government and the Scottish Parliament have also adopted the criteria. These will be strengthened further through the ‘Eat Out Eat Well Framework’ announced in the ‘Out of Home Action Plan’.

In addition, the Nutritional Requirements for Food and Drink in Schools (Scotland) Regulations 2020, were introduced in April 2021. These requirements are based on scientific evidence and dietary advice, and are designed to ensure children and young people are provided with an appropriate amount of energy and key nutrients. They are flexible enough to cater for all diets, including animal free. These regulations introduce a required increase in the amount of fruit and vegetables offered as part of school meals, and across the whole school day, and align the provision of red and red processed meat with the advice in the Scottish Dietary Goals to limit consumption of such foods to 70g per day.

The Food for Life Programme is currently operating across 17 local authorities in Scotland, supporting the provision of more locally sourced, healthier food being served throughout schools. The Scottish Government is continuing to support the programme and we are in discussions with the Soil Association around options for expanding into other settings within the public sector.