The five levels of the CO2 Performance Ladder are giving way to three steps in version 4.0. The first step – Step 1 – focuses on CO2 reduction within your own organisation. In this blog, we explain what Step 1 means, how the requirements of version 4.0 have changed compared to version 3.1, and what these changes mean for your certification process. If you are not yet familiar with the Ladder, read about it here.

With the launch of this new version, the CO2 Performance Ladder remains ahead of the pack. Setting even more ambitious requirements within the Ladder helps to accelerate the transition towards an emission-free business and government. Changing standards and regulations also make it necessary to update the Ladder once in a while.

Close involvement of market

The development of version 4.0 has been a long and careful process. This involved listening carefully to the wishes of all stakeholders. Representatives from various sectors , governments, NGOs and CI’s indicated in consultation sessions that they found it important to align the Ladder even better with international standards, to focus on the main impact of organisations and to enable frontrunners to distinguish themselves even more. The readability and language of the Handbook were also points of attention.

“The accessibility of the Ladder is of great importance. The more comprehensible the language, the easier it is to use it as an organisation and the more it comes to life within the organisation”

Bastina van Houwelingen, representative MKB Infra and Cumela in the Central College of Experts (CCvD)

Accessible entry level

At the same time, parties indicated that the Ladder should retain an accessible entry level, for both large and small organisations. The new Step 1 fulfils that wish. Step 1 is in fact – despite some differences in content – comparable in effort to Levels 1 to 3 of the previous handbook, version 3.1.

Two parts

The new Handbooks consist of two parts. Part 1 contains all requirements that are the same for all Steps, 1 to 3. This part is therefore the same for all (future) certificate holders. This includes, for example, determining organisational boundaries, the requirements for the CO2 management system and the information you must document.

Differences from previous CO2 Performance Ladder version

Part 2 contains the requirements that only apply to a specific Step. The main differences between Step 1 and Levels 1 to 3 of the previous handbook are:

Requirements dropped

There are also requirements that have been dropped in the new version. For instance, for Step 1, organisations are no longer required to participate in collaborations. It is sufficient to know what knowledge or collaboration is needed.

In addition, the way in which organisations communicate on their own websites about the Ladder and their certification in version 4.0 is form-free. A link to their own page on the CO2 Performance Ladder website is sufficient, where all documents and publications about the organisation’s certification can be found. Also, as in version 3.1, an organisation no longer needs to communicate its footprint, objectives and measures every six months. In version 4.0, once a year is sufficient.

Furthermore, organisations may choose whether to report on business travel as part of Step 1. This was still mandatory in version 3.1, although business travel falls under scope 3.

“We have demonstrated several times over the past 15 years that companies significantly reduce more CO2 by using the Ladder”

Gijs Termeer, director SKAO

Explanation video Step 1

In the Dutch video below (with English subtitles), Gijs Termeer and Bastina van Houwelingen elaborate on version 4.0, the requirements of Step 1 and the differences compared to the previous Handbook. In the video, they also answer questions from organisations that attended the session. The main questions asked are addressed in the FAQ below. Should you still have questions after watching the webinar session, please contact us.

This video is a recording of the webinar given on 6 March 2025.

Questions during this event

What is the difference between the various levels of version 3.1 and 4.0?

Please see this article.

How often must my organisation prepare a footprint?

At least once a year. The purpose of preparing a footprint is to be able to steer CO₂ in a timely and focused manner. If organisational processes require it, it can be beneficial to prepare a footprint more frequently.

Is scope 3 relevant for Step 1?

In principle, Step 1 only covers scopes 1 and 2, so no. However, there are two exceptions: an organisation can voluntarily include business travel (a scope 3 category) and must always report on the supply chain emissions of fuels (so-called Well-to-Tank emissions).

How can large-scale electrification be combined with energy savings?

Electrification almost always leads to energy savings.

It does not matter whether grey or green electricity is used. For example, a car with an internal combustion engine has an energy loss of approximately 70%. If you add the conversion loss from crude oil to fuel, you arrive at a total loss of approximately 80%. An electric car loses about 20% during driving. If you then add the loss in the power station (if it is grey electricity) and the transport loss, the total loss is about 60%.

Between two comparable cars, the electric is always more energy-efficient.

How can an organisation realise energy savings while energy consumption increases due to electrification (scope 2) and diesel use by subcontractors (scope 3)?

Electrification almost always leads to energy savings. (See also the section ‘How can large-scale electrification be combined with energy savings?’)

As for the answer regarding subcontractors using more diesel: at Step 1 this is outside the mandatory targets for energy savings. The aim is to reduce the organisation’s own energy consumption (in emission terms: scopes 1 and 2). Of course, at Steps 2 and 3 the intention is that the emissions from subcontractors will be reduced.

What is the relationship/difference between international standards such as ISO and the CO₂ Performance Ladder 4.0?

Commonly used ISO standards relevant to the CO₂ Performance Ladder include ISO 14001 (environmental management) and ISO 50001 (energy management). Differences and similarities can pertain both to 1. the form and 2. the content.

  1. Form: Both certificate holders and auditors consider it important that version 4.0 adopts the same chapter structure as the ISO management systems (High-Level Structure). This has the advantage that the systems can be more easily integrated (for example, by combining audits). One difference is that, due to the tiered structure of the Ladder, the High-Level Structure could not be applied in every aspect. Thus, there are limitations to the integration possibilities.
  2. Content: Naturally, there is also an overlap in content between CO₂ on the one hand and environmental and energy management on the other. However, the overlap is limited because the Ladder 4.0 works in Steps that contain quite a number of additional requirements, such as for an emission inventory, a climate transition plan and collaboration.

Will the size determination for companies be adjusted based on the recent changes in the CSRD, from 1000 FTE?

No, we do not plan to do so.

The current CSRD size criteria suit the Ladder better than the criteria that might be introduced. The consequence of the new criteria is that only a few dozen companies would qualify as ‘large’ and hence be eligible for exemptions. With the current criteria, this number is around 250.

Also, the current CSRD size criteria (based on FTE, turnover and balance sheet total) are much better than the criteria from Handbook 3.1 and its predecessors. Those were determined on the basis of scopes 1 and 2 emissions, whereby organisations that outsource extensively or purchase a great deal of green electricity were ‘rewarded’ with more exemptions. Furthermore, it was necessary to prepare an emission inventory first before knowing whether exemptions applied.

Do you receive exemptions for the CSRD with the CO₂ Performance Ladder?

No. An accountant will always have to independently determine compliance with the CSRD. However, it is possible that the accountant may take the auditor’s opinion as background information. Certification for the Ladder can therefore be helpful.

Why should a company subject to the CSRD still certify for the CO₂ Performance Ladder?

Because a reporting obligation (the CSRD) is fundamentally different from an energy and CO₂ management system (the CO₂ Performance Ladder). This difference is explained in this article.

What is the role of a ‘key person’?

These are employees who, due to their role or function, have (or can have) a significant influence on the CO₂ and energy policy, energy consumption, the use, storage or generation of sustainable energy and/or on the CO₂ emissions of the organisation. The term ‘employees’ also includes persons who perform tasks under the authority of the organisation. Their role differs per Step. In Step 1 it is sufficient for them to be aware of their influence; in Steps 2 and 3, key persons must actively take steps. What this concretely looks like can vary enormously from one key person to another: a buyer or driver might, for example, attend a course on electric equipment. A director might receive a bonus if the emissions demonstrably decrease.

Can a key person also be an external consultancy?

An external consultant can also be a key person (it is about a person or role). It is, however, important that there is always at least one key person from within the organisation.

Is there a list of the non-CO₂ greenhouse gases?

Yes, certainly. Non-CO₂ greenhouse gases include methane (CH₄), nitrous oxide (N₂O), HFCs, PFCs, SF₆ and NF₃. These are the greenhouse gases that were included in the Kyoto Protocol in 1997 (NF₃ was added at a later stage). This article provides more explanation about the role of non-CO₂ greenhouse gases in CO₂ Performance Ladder 4.0.

What is meant by ‘including non-CO₂ greenhouse gases in the footprint’?

If an organisation concludes that non-CO₂ greenhouse gases are relevant, it must quantify them separately and convert them to CO₂.

The conversion factors to CO₂ (referred to as CO₂ equivalent) are listed in the latest IPCC report. The organisation then adds up all emissions per scope (scope 1, 2 and possibly 3) so that a total footprint is obtained for all greenhouse gases. Non-CO₂ greenhouse gases can also play a role in other controllable emissions (OBE).