NHS Net Zero by 2040: What the Target Means for a Trust's Roof and Meter

The NHS has two net zero targets, and they are easy to mix up. The NHS has two net zero targets (NHS England, Greener NHS): net zero by 2040 for the emissions it controls directly (the NHS Carbon Footprint), with an 80% reduction between 2028 and 2032, and net zero by 2045 for the emissions it can influence (the NHS Carbon Footprint Plus), with an ambition of an 80% reduction between 2036 and 2039. Which one a project counts toward depends on what it changes, and for an estates team the practical question is what a roof and a meter can move.

The two targets in plain words

The NHS Carbon Footprint is the emissions the NHS controls directly. Net zero by 2040, with an 80% reduction between 2028 and 2032 on the way. The NHS Carbon Footprint Plus is the wider set it can influence: net zero by 2045, with an ambition of an 80% reduction between 2036 and 2039 (NHS England, Greener NHS). This article is about the first, because that is where an estate's energy sits.

Where the NHS is against the 2040 target

NHS England's progress review of 24 September 2025 (NHS England, Five years of a greener NHS (24 September 2025)) puts the 1990 baseline of the NHS Carbon Footprint at 14.5 million tonnes of CO2e and the 2024/25 figure at 4.7 million tonnes, a 68% reduction. The interim target is 80% by 2028 to 2032, which means falling to 2.9 million tonnes, and NHS England says the NHS is on track for 2032.

What the estate figures show

• Estates emissions are down 10% since 2019/20.
• Grid electricity emissions in secondary care fell by more than 220 thousand tonnes (21%), largely a grid effect.
• Gas, mainly for heating, was around 40% of the Carbon Footprint in 2024/25 and has fallen only 1% since 2019/20.
• Trust energy bills have nearly doubled since 2019, to over £1.4 billion.
• Solar generation has tripled since 2019.

Read together, those lines say what rooftop solar is for. It cuts the electricity a site buys, so it helps the bill and the electricity share of the footprint, but the largest and stickiest block is heat, which a roof array does not touch. A trust that treats solar as its net zero plan will leave most of the footprint where it is; the NHS Green Plan article covers how to sequence solar alongside heat.

The duty and the Green Plan

NHS England's NHS England, Green plan guidance (published 4 February 2025, updated 8 May 2025) says the Health and Care Act 2022 placed new duties on integrated care boards, NHS trusts and foundation trusts to consider statutory emissions and environmental targets in their decisions. Each organisation reviews its Green Plan annually and has a board-level net zero lead, and the guidance names investing in on- or near-site renewable energy generation as a focus for meeting NHS energy demand. That sentence is the hook for a solar scheme in a Green Plan.

The NHS Net Zero Building Standard

The NHS England, NHS Net Zero Building Standard (published 22 February 2023) applies to new buildings and upgrades with a project cost of £25 million or more at pre-strategic outline business case stage from 1 October 2023, and to Neighbourhood Health Centre and New Hospital Programme projects. The page does not mention solar PV. A stand-alone rooftop array will usually sit below that threshold, but check the standard for any larger scheme the array belongs to.

What a Board paper should say

A solar scheme should state which target it contributes to and by how much, using the trust's own half-hourly data rather than a national average; what it does for the energy bill; how it sits next to heat decarbonisation; and which funding route pays for it. The solar panels for NHS trusts page sets out the governance steps, and the NHS solar funding page and the Great British Energy NHS solar tracker show what is open.

Sources, read 31 October 2026

• NHS England, Greener NHS: the two targets and their milestone windows.
• NHS England, Five years of a greener NHS (24 September 2025): baseline, 2024/25 emissions, estate and energy figures.
• NHS England, Green plan guidance: duties, annual update, board lead, renewables focus.
• NHS England, NHS Net Zero Building Standard: scope and start date.