The CO₂ Performance Ladder and CSRD: one dataset, two reports

Can I reuse my Ladder footprint for ESRS E1?

Yes. The emission inventory you build for the CO₂ Performance Ladder uses the same scope classification as the ESRS, includes all greenhouse gases and not CO₂ alone, and is built on ISO 14064-1 and the GHG Protocol. SKAO, the scheme owner, writes that the footprint can be used "directly" in the CSRD report (SKAO on the relationship between CSRD and the Ladder).

Two things decide whether that works in your case.

1. The organisational boundary has to be the same in both frameworks. SKAO says so explicitly in the Dutch version of the same article: it matters that "de organisatie voor beide dezelfde organisatorische grenzen aanhoudt", that the organisation keeps the same organisational boundaries for both (source). If the boundaries differ, the footprint does not transfer without recalculation. In a group with several operating companies they almost always differ.
2. Carbon offsetting sits outside the measurement scope of the Ladder. Your ESRS disclosure on removals and carbon credits has to be built separately from scratch.

One thing that often gets presented as a third condition is not one. In the same text SKAO establishes that "het toegestaan is om tank-to-wheel-emissies apart te rapporteren", that reporting tank-to-wheel emissions separately is permitted (source). That is a permission, not an extra requirement.

What is the Ladder, and why does it bind you commercially?

The CO₂ Performance Ladder (CO₂-Prestatieladder in Dutch) is a certifiable carbon management scheme run by SKAO. Around 8,000 organisations hold a certificate and more than 300 public contracting authorities use it in procurement. Roughly 75 percent of certificate holders are small and medium-sized enterprises.

The reason it is not a voluntary label in practice is a Dutch and Belgian procurement mechanism called gunningvoordeel, which translates as tender advantage or award advantage. A contracting authority treats your certificate level as a notional discount on your bid price for evaluation purposes only. A bid of 30 million euro with a 4 percent advantage is scored as 28.8 million, which can beat a cheaper uncertified bid, and the winner is still paid the full 30 million. That is why a climate certificate is commercially binding in a way a voluntary framework is not (SKAO on tendering with version 4.0). The mechanism is set out in how tender advantage works and what it is worth.

Since handbook 4.0, published on 14 January 2025, the scheme has three steps (treden in Dutch), not the five levels (niveaus) that most pages online still describe. See why there are now three steps instead of five levels.

What does SKAO itself say?

SKAO's English article on the relationship states (source):

"By meeting the requirements of the CO₂ Performance Ladder version 4.0, an organisation covers part of the ESRS set, specifically ESRS E1 on climate change."

"the footprint produced by the organisation in accordance with the CO₂ Performance Ladder requirements can be used directly in the CSRD report, since the same scope classification is used, all greenhouse gases (not just CO₂) are included."

"During the development of the CO₂ Performance Ladder 4.0, CSRD was taken into account."

The Dutch version of the same article adds (source):

"doordat met de CO₂-Prestatieladder een CO₂-managementsysteem wordt geïmplementeerd, kan de organisatie hier steeds opnieuw op terugvallen als onderbouwing van het jaarlijkse CSRD-duurzaamheidsverslag."

Because the Ladder makes you implement a carbon management system, the organisation can fall back on it every year as the substantiation for its CSRD sustainability statement. And: "CO₂-Prestatieladder 4.0 hanteert daardoor zoveel mogelijk dezelfde randvoorwaarden als CSRD", version 4.0 uses the same underlying conditions as CSRD wherever possible.

SKAO is not consistent about how much of E1 is covered, and that decides how much of your file you can reuse. The CSRD article says the organisation covers "een deel van de ESRS-set af, namelijk ESRS E1", a part of the ESRS set (source). The article explaining version 4.0 says you cover "een substantieel deel van ESRS E1", a substantial part (source). We use the more cautious of the two throughout this page, and the table below says which part.

What SKAO does not publish is the crosswalk itself: which Ladder requirement corresponds to which disclosure requirement.

What is the difference between the Ladder and CSRD?

SKAO puts the distinction this way: the CSRD report makes the organisation's impact transparent, while an organisation implementing version 4.0 also steers towards steadily less climate impact (source). That is where the Ladder's requirements on measures and value chain cooperation come from, none of which appear in ESRS E1.

Which Ladder requirement covers which ESRS E1 disclosure?

The table uses the ESRS E1 numbering currently in force, from Delegated Regulation (EU) 2023/2772. The renumbering coming from financial year 2027 is further down.

The table is a division of labour. If you hold a certificate, the left hand column is already on your shelf. The anticipated financial effects and the climate scenario analysis are work the Ladder never asked for and you will be doing for the first time.

For building the scope 3 numbers E1-6 asks for, see value chain analysis in practice.

What does the Ladder not cover at all?

Twelve ESRS standards, of which the Ladder touches one, and that one not fully. Anyone telling you the Ladder makes you CSRD ready is selling you something.

Why is the climate transition plan the bridge to ESRS E1?

The climate transition plan (klimaattransitieplan) is new in 4.0. SKAO writes that you only have to draw one up from step 2 of version 4.0 (SKAO on the climate transition plan). Its structure follows E1-1, the transition plan disclosure of ESRS E1.

SKAO names six components: strategy and business model, substantiated measurable and time bound targets, concrete actions and planning, a financial substantiation, governance and accountability, and monitoring and transparency (source). Put that list next to E1-1 and it is the same architecture.

SKAO adds that the Ladder's plan is "concreter" on targets and measures and "ambitieuzer dan dat van de CSRD", more ambitious than the CSRD version, and it carries an obligation ESRS E1 does not have (source). For organisations with more than 250 employees the plan "moet worden afgestemd met een onafhankelijke deskundige en in het kader van samenwerking twee keer per jaar moet worden besproken met een ketenpartner. Dit moet telkens een andere partner zijn": it has to be aligned with an independent expert and discussed twice a year with a value chain partner, and it has to be a different partner each time (SKAO on steps 2 and 3). That last clause is the operationally hard part: you need two different chain partners per year willing to spend time on your plan.

Write the climate transition plan once, and write it so it satisfies both frameworks at the same time.

Is my Ladder boundary the same as my CSRD boundary?

Usually not, and this is where reuse breaks down in practice.

CSRD reports on the consolidated group, so on the list of legal entities in the financial statements. The CO₂-bewust certificaat is issued to a specific certified organisation, which is rarely that exact list. In a group with several operating companies you are looking at two different entity lists.

People notice the consequence late. A document written for the group, a climate transition plan for instance, cannot be used as is for the Ladder certificate of one specific entity. It has to be rewritten to the correct scope, and for the auditor that is not a formality.

Underneath sits a structural problem. In working sessions with sustainability teams at construction and infrastructure groups, one sustainability lead put it like this:

"The reason that this is so complicated is because you have two overlapping systems."

Every mid-size group runs two sets of books at once: statutory accounting on legal entities, operational accounting on business units. They do not line up, and neither is wrong. The same sustainability lead on how the two relate:

"A business unit can work for two different legal entities, but it will always be the same activity."

The activity is what stays stable across years. Which legal entity does the invoicing changes more often.

A profile that keeps coming back in the conversations we have, at an order of magnitude you may recognise: around 170 business units, more than 60 locations, 50 legal entities, three countries. At that scale your collection level decides everything. Collect at the finest level you can sustain and report coarse. The other direction does not exist: what you did not collect, you cannot split afterwards. The full treatment is in organisational boundaries for groups with multiple entities.

Do I have to write two climate plans?

Preferably not. Run both tracks separately and two certification processes flag gaps in the same document, gaps that only partly overlap. The question practitioners then ask is a governance question: how big is the risk that we end up with two documents saying different things?

An assurance opinion from a large accounting firm on your transition plan also does not guarantee that everything the Ladder asks for is in it. An assured document and a framework complete document are two different things.

Draft one plan that satisfies all the frameworks at once. Writing it costs extra time. You get that time back at every subsequent audit.

Then the evidence. From the same working sessions, a description of what audit ready actually means:

"If we can have a disclosure, all the evidence locked to the data point, and the text with evidence where it got it from, then I think we already won the discussion with the auditor beforehand."

That holds for both frameworks. CSRD assurance and the Ladder audit may draw on the same source, as long as the evidence hangs off the data point rather than off the document.

What does Omnibus mean for this combination?

The Council of the European Union signed off the Omnibus I directive on 24 February 2026. CSRD now applies to undertakings with "more than 1,000 employees and above €450 million net annual turnover" (Council of the EU). It was published in the Official Journal on 26 February 2026, entered into force on 18 March 2026, and has to be transposed by 19 March 2027 (Latham & Watkins).

Companies in the first reporting wave that fall outside the new scope parameters get transitional relief. The Council describes "a transition exemption for companies that had to start reporting from financial year 2024" and therefore "falling out of scope for 2025 and 2026" (source).

Of the roughly 8,000 organisations certified on the Ladder, 75 percent are small and medium-sized enterprises, and almost none reach those thresholds. Until last year CSRD was the big obligation and the Ladder a subset of it. That relationship has flipped.

What is left for most of the Ladder population:

• The CO₂ Performance Ladder is the climate management system that actually binds, because it lands in the contract through tender advantage.
• Demand for your numbers does not go away, because your clients need your figure for their own scope 3.
• The adopted Omnibus I directive does put a limit on that demand. It introduces a value chain cap restricting the sustainability information reporting undertakings may request from value chain companies with fewer than 1,000 employees (Latham & Watkins).

That cap points at the voluntary standard. The delegated act the Commission adopted on 3 July 2026 contains a basic module B3 "Energy and greenhouse gas emissions", a comprehensive module C3 "GHG reduction targets and climate transition" and a module C4 "Climate risks" (annex to C(2026) 5011). Your step 1 footprint fills most of B3. See the CO₂ Performance Ladder and VSME for that comparison, with the caveat that SKAO publishes no official mapping between the two. Its CSRD article gives the subject a single sentence: "Dit geldt ook voor de VSME", this applies to VSME as well (source).

Is ESRS E1 being renumbered?

Yes, and you want to know that before you freeze a crosswalk into a template.

The European Commission adopted the delegated acts containing the revised ESRS on 3 July 2026. Mandatory datapoints fall by "over 60%", total datapoints by "over 70%", and the Commission expects reporting costs "more than 30% per company" lower (European Commission, 3 July 2026).

They are not settled law yet. The delegated acts were transmitted to the European Parliament and the Council for a scrutiny period of two months, which can be prolonged by a further two months, and they take effect only once that period is over (European Commission). At the time of writing, 11 August 2026, that scrutiny window is still open. Once the act enters into force, the revised standards apply to financial years beginning on or after 1 January 2027, with early adoption permitted for financial year 2026 (EFRAG).

ESRS E1 is renumbered in the process. From EFRAG's comparative table of December 2025 (Comparative Table December 2025, E1):

Look at the second row. The new E1-2 does not come from the old E1-2. It comes from the process for identifying impacts, risks and opportunities (IRO-1) in ESRS 2. The old E1-2 on policies becomes E1-4. Anchor your Ladder file to disclosure numbers instead of subjects and you have anchored it to exactly the part that moves.

What should you do now?

1. Check first whether you are still in CSRD scope after Omnibus. For many certificate holders the answer is no.
2. Put both organisational boundaries side by side at entity level. If they differ, you already know which documents need rescoping.
3. Collect at business unit or activity level, not at legal entity level alone.
4. Write the climate transition plan once, against both frameworks at the same time.
5. Attach evidence to the data point, and build your crosswalk on subjects rather than on disclosure numbers, because those numbers change as soon as the revised ESRS enter into force.

For the wider context on versions and transition dates: why there are now three steps instead of five levels and moving from 3.1 to 4.0, what you can reuse. What the certification itself costs is set out in what the CO₂ Performance Ladder costs in 2026. What Palau does for the Ladder is summarised on the CO₂ Performance Ladder solution page.

How Palau handles this

Palau stores your activity data once in Reef, the data warehouse layer, and generates both the CO₂ Performance Ladder reporting and the ESRS E1 disclosures from it without duplicating the dataset. The Organisational structure module consolidates across entities, so the certificate's entity list and the financial statements' entity list can sit side by side. Evidence and documents live in Vault, linked to the reporting that uses them.

Request a pilot.

Frequently asked questions

Can I reuse the CO₂ Performance Ladder footprint for ESRS E1? Yes, provided the organisational boundary is the same in both frameworks. SKAO confirms the footprint can be used directly in the CSRD report.

Which part of the ESRS does the Ladder cover? Part of ESRS E1, and nothing else. Social, governance and the other environmental standards stay entirely uncovered.

Do I need two climate transition plans? No. Write one that satisfies both frameworks, and account for the discussion obligation that only the Ladder imposes.