The CO₂ Performance Ladder and VSME: can you combine them?

What is the CO₂ Performance Ladder, and what is gunningvoordeel?

The CO₂ Performance Ladder (CO₂-Prestatieladder) is a Dutch certification scheme run by SKAO and used in Belgium as well. Around 8,000 organisations hold a certificate and more than 300 contracting authorities use it in tenders (SKAO).

The commercial mechanism is called gunningvoordeel, tender advantage. A contracting authority uses your certificate as an award criterion. Your bid price is notionally reduced for evaluation only, often as a fictieve korting, a fictitious discount. If you win, you are paid the full quoted price. That is why contractors treat the certificate as a commercial instrument.

Handbook 4.0, published on 14 January 2025, replaced the old five levels (niveaus) with three steps (treden). Step 1 covers scope 1 and 2. Step 2 adds the material part of scope 3 and requires a climate transition plan. Step 3 targets zero emissions across scopes 1, 2 and 3. The detail sits in why handbook 4.0 has three steps instead of five levels.

What is VSME, and is it still called that?

VSME stands for the Voluntary Sustainability Reporting Standard for non-listed SMEs. EFRAG delivered it to the European Commission on 17 December 2024. The Commission adopted a recommendation on 30 July 2025 for voluntary use (C(2025) 4984 final, later Recommendation (EU) 2025/1710), explicitly as an interim measure until a delegated act existed.

That delegated act arrived on 3 July 2026: C(2026) 5011, a regulation "establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap". The word VSME does not appear in that text. The standard is called the standard for voluntary use there. EFRAG and the market keep saying VSME, and that is still the term your customers search for. According to the Commission's press release, the measures apply once "the scrutiny period of 2 months, which can be prolonged by a further 2 months" by Parliament and Council is over. Article 3, which sets the value chain cap, applies under Article 4 to financial years beginning on or after 1 January 2027.

So two live texts exist, and that matters practically, because the paragraph numbers differ. If you report on financial year 2025 or 2026, you are working from the 30 July 2025 recommendation. The structure is identical in both versions.

For anyone holding a Ladder certificate, two datapoints are about climate: B3, energy and greenhouse gas emissions, in the basic module, and C3, GHG reduction targets and climate transition, in the comprehensive module.

Why does this question come up now?

SKAO publishes two different numbers about the same population. The English page about the Ladder says "75% of certificate holders are small and medium-sized enterprises (SMEs)" (SKAO, What is the Ladder). The Dutch SME page says that "ruim twee derde", more than two thirds, of all certified organisations are SMEs (SKAO). We publish both, because both come from the scheme owner. Either way, most of the roughly 8,000 certificate holders are exactly the population VSME was written for: non-listed companies outside the CSRD obligation that still receive questionnaires from customers and banks.

A contractor with a Ladder certificate therefore gets two kinds of question on the same desk. The contracting authority asks for a step. From the client or the bank, the request is ESG data in VSME format. The meter readings underneath both answers are the same.

Where do Step 1 and VSME actually overlap?

Step 1 of handbook 4.0 requires a footprint over scope 1 and 2, short-term targets (roughly up to three years), explicit energy-saving ambitions, and since 4.0 also non-CO₂ greenhouse gases such as methane and nitrous oxide (SKAO on the three steps). If you still work under handbook 3.1, the 3.1 to 4.0 migration guide sets out what survives the change.

VSME B3 asks for energy consumption in MWh plus estimated gross scope 1 and location-based scope 2 in tCO₂eq. The July 2025 recommendation adds an intensity ratio on top of that. The July 2026 delegated act dropped it.

Paragraph numbers in the table below follow the delegated act of 3 July 2026. In brackets is the number in the recommendation of 30 July 2025, because that is the text you are working from for financial years 2025 and 2026. The right column is our estimate of the work still sitting between the two.

If you work in construction, you fall under that C3 condition. EFRAG's own supporting guide for C3 counts NACE v2.1 section F, Construction, among the high climate impact sectors (EFRAG, supporting guide on disclosure C3). For a contractor at Step 2 that works in your favour: the climate transition plan that handbook 4.0 makes mandatory there covers most of what C3 wants to see on this point. The Ladder builds the same bridge to ESRS E1, as set out in the CO₂ Performance Ladder and CSRD.

Which VSME datapoints does the Ladder not touch?

The table below is about what sits in your Ladder file. Where we write "no", we mean the datapoint cannot be derived from that file and has to be collected separately.

Of the eleven datapoints in the basic module, a Ladder file in practice fills three: B1 partly, B2 largely and B3 largely. The other eight you start from zero.

That differs from what the scheme owner writes. In its article on CSRD, SKAO states: "Door te voldoen aan de eisen van CO₂-Prestatieladder versie 4.0, dekt een organisatie een deel van de ESRS-set af, namelijk ESRS E1, klimaatverandering", that by meeting the requirements of version 4.0 an organisation covers part of the ESRS set, specifically ESRS E1 on climate change. The very next sentence reads: "Dit geldt ook voor de VSME.", this also applies to the VSME (SKAO on the relationship between CSRD and the Ladder). Reading the normative texts, we reach a different conclusion. For the climate part of VSME the statement holds. For the basic module as a whole it does not, because eight of the eleven datapoints are about pollution, biodiversity, water, waste, workforce and corruption.

Where do the calculation rules clash?

Even inside the climate part the two frameworks are not identical. Five differences that will actually reach you.

The offsetting rule is spelled out in EFRAG's supporting guide for C3: removals, avoided emissions and offsetting through carbon credits "shall not be counted when calculating GHG emissions or setting the undertaking's gross GHG emission reduction targets" (EFRAG). The Ladder lands in the same place by a different route, because offsetting measures sit outside its measurement scope (Exergie on the GHG Protocol and the Ladder). On this point you do nothing twice.

The assurance difference weighs heaviest and is underestimated most often. A VSME report is satisfied by a declaration from the company itself (C(2025) 4984), whereas a CO₂-bewust certificate carries an audit and, in a tender, a sum of money. If you use one dataset for both, the Ladder sets the level of evidence you have to reach.

What does the value chain cap mean for you?

The delegated act of 3 July 2026 caps what large reporters may ask for. Article 1 defines the value chain cap as "the upper limit of sustainability information which undertakings subject to Articles 19a and 29a of Directive 2013/34/EU may require from undertakings in their value chain which do not exceed, on their balance sheet date, an average number of 1 000 employees during the preceding financial year" (C(2026) 5011). The press release puts it shorter: "companies subject to the CSRD cannot require companies in their value chains to provide more information than what is covered by the voluntary standard" (European Commission).

Two consequences follow, and they get confused with each other constantly.

As a supplier you are the protected party. From financial year 2027, if a customer that is itself subject to mandatory reporting under Article 19a or 29a sends you a questionnaire, your Ladder footprint plus the rest of the basic module is a complete answer. You owe nothing beyond it.

As a buyer you are bound only if you yourself fall under Article 19a or 29a. Your step on the Ladder plays no part in this. If you sit at Step 2 and need chain data, that certificate places no limit at all on what you may ask your partners. If you are a mandatory reporter, your requests to partners with 1,000 employees or fewer stay within the datapoints of the voluntary standard and you close the gap with your own calculation. If you are not, you may ask what you like, though a supplier can still hold the standard up as a boundary. Turning that chain data into an approved analysis is covered in the value chain analysis in practice.

Should an SME start with the Ladder or with VSME?

That depends on who is asking.

The underlying rule is the same one that governs consolidation. Collect at the finest level you can manage and report at the coarser level afterwards. A dataset that survives an audit can always be simplified into a self-declaration. The reverse means collecting again a year later, with people who by then are doing something else. What the Ladder route costs is set out in what the CO₂ Performance Ladder costs in 2026.

What goes wrong in practice?

Three patterns that keep coming back.

The entity lists do not line up. VSME B1 asks whether you report individually or on a consolidated basis, plus a list of subsidiaries with address, NACE codes and the locations of your sites. Your Ladder certificate hangs on an organisational boundary that rarely coincides with that exactly, because most groups run two structures at once: statutory accounting on legal entities and operational steering on business units. A document written for the group therefore has to be renamed or rewritten per certified entity. That is covered at length in organisational boundaries across multiple entities. The NACE codes B1 asks for chafe as well: a company doing several kinds of work rarely fits one code neatly, and that single choice then sits in your report for years.

Two frameworks find different gaps in the same document. An organisation running a Ladder audit and an ESG questionnaire at the same time gets two lists of shortcomings against the same text, and they overlap only partly. Write one plan that satisfies both in a single pass, and track per section which framework needs it.

The people who hold the data stay quiet. Rarely out of unwillingness. One practitioner put it this way: "They seem to be not engaged, but in truth they are embarrassed because they do not have the answers." Sustainability makes that easy, with acronyms in every sentence. VSME adds eight datapoints that sit with colleagues who have never dealt with your footprint. Short, targeted instruction per datapoint works best there. Finish one datapoint end to end before you roll out the rest.

How Palau handles this

Palau supports the CO₂ Performance Ladder and VSME as separate reports on the same underlying dataset in Reef, so one meter reading or fuel card receipt fills both without being entered twice. Vault manages the evidence and the documents behind those figures. For the chain data Step 2 requires, the contributor portal collects information from partners across your value chain. The organisational structure module maintains the entity list that VSME B1 asks for and that bounds your Ladder certificate. There is more background on the CO₂ Performance Ladder solution page.

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Frequently asked questions

Can you combine the CO₂ Performance Ladder and VSME? Partly. The scope 1 and 2 footprint from Step 1 fills VSME datapoint B3 almost directly, and your reduction targets fill C3. VSME also asks for water, waste, biodiversity, workforce and governance, which the Ladder does not touch. No official mapping between the two frameworks exists.

Does CO₂ Performance Ladder 4.0 cover the VSME requirements? Not fully. Of the eleven datapoints in the basic module, a Ladder file in practice fills three: B1 partly, B2 largely and B3 largely. The other eight, on pollution, biodiversity, water, waste, workforce, health and safety, remuneration and corruption, you start from zero. SKAO writes in its CSRD article "Dit geldt ook voor de VSME." Reading the normative texts, we reach a different conclusion.

What exactly does VSME datapoint B3 ask for? B3 asks for total energy consumption in MWh, split into renewable and non-renewable for electricity and fuels, plus estimated gross scope 1 emissions and location-based scope 2 emissions in tCO₂eq. In the delegated act of 3 July 2026 those are paragraphs 32 and 33. In the recommendation of 30 July 2025 those are paragraphs 29 and 30, with a GHG intensity ratio in paragraph 31 that the delegated act dropped. Scope 3 is not required in the basic module and may be disclosed voluntarily.

Do I need an auditor for VSME? No. In its recommendation of 30 July 2025 the European Commission states that there is no assurance obligation and that a self-declaration by the SME is sufficient. The CO₂-bewust certificate of the Ladder does require an audit by an accredited certification body, valid three years with annual surveillance.

What is the value chain cap and who does it bind? The value chain cap binds only undertakings that are themselves subject to Article 19a or 29a of Directive 2013/34/EU, meaning mandatory sustainability reporting. Those undertakings may not require more information than the voluntary standard contains from value chain partners averaging 1,000 employees or fewer. Your step on the CO₂ Performance Ladder plays no part in it. Article 3 of C(2026) 5011 applies to financial years beginning on or after 1 January 2027.

Should an SME start with the Ladder or with VSME? An organisation bidding for public contracts in the Netherlands or Flanders starts with the CO₂ Performance Ladder, because it converts directly into gunningvoordeel with more than 300 contracting authorities. An organisation mainly receiving ESG questionnaires from customers and banks starts with the VSME basic module. If you do both, start with the Ladder, because the audited figure carries the heaviest burden of proof and can be simplified afterwards.

Is there an official mapping between the CO₂ Performance Ladder and VSME? No. SKAO mentions VSME in two sentences in its CSRD article and publishes no mapping. EFRAG never refers to the CO₂ Performance Ladder. Any comparison placing the two side by side, including Palau's, is an unendorsed practical analysis.