CO2 Performance Ladder level 3

Level 3 is the level at which most companies enter the CO2-Prestatieladder (CO2 Performance Ladder). You show that you know the CO2 emissions of your own organisation (scope 1 and 2 plus business travel), that you have ambitious reduction targets, that you communicate internally and externally twice a year, and that you actively take part in a sector or supply chain initiative. Level 3 belongs to handbook 3.1. New audits under 3.1 are possible until 14 January 2027, according to the SKAO transition arrangement . After that, tier 1 of handbook 4.0 takes over. The difference between the two classifications is set out in levels and tiers.

Short answer: for level 3 you need an energy review, an emission inventory under ISO 14064-1, reduction targets for scope 1 and 2 with an energy management action plan, a completed measure list, a communication plan with at least two internal and two external communications per year, active participation in an initiative, and an annual internal audit and management review.

Requirements of the CO2 Performance Ladder level 3 per perspective

At level 3 you must also meet all the requirements of levels 1 and 2. The requirements are divided across the four perspectives of the requirements of the ladder. The table below follows the SKAO Practical Guide part 1 . The numbers refer to the requirements in handbook 3.1.

Perspective	What you do	Requirements (3.1)	Document
A Insight	Map energy flows and the largest consumers	1.A, 2.A.1, 2.A.2	Energy flow overview
A Insight	Energy review: where are the opportunities?	2.A.3	Energy review
A Insight	Emission inventory under ISO 14064-1, including business travel	3.A	Emission inventory with CO2 footprint
B Reduction	Ambitious targets for scope 1 and 2, with a base year	2.B, 3.B	Energy management action plan
B Reduction	Test the ambition with the SKAO measure list	3.B	Completed measure list
C Transparency	Determine stakeholders and draw up a communication plan	2.C.2, 2.C.3, 3.C.2	Communication plan
C Transparency	Communicate at least twice a year internally and twice externally	1.C, 2.C.1, 3.C.1	Communications
D Participation	Actively take part in a sector or supply chain initiative, with time or budget invested	1.D, 2.D, 3.D	Survey and choice of initiative, reports
General	Annual internal audit and management review	ALG	Audit report, management review

Which emissions count? Under 3.1, the footprint for level 3 consists of scope 1 (gas and fuel), scope 2 (purchased electricity and heat) and business travel: flights, public transport and claimed kilometres in private cars. Other scope 3 emissions only apply from level 4. More explanation is at scope 1, 2 and 3.

“Ambitious” is not a non-binding word. The certification body compares your targets with your starting position and with sector peers, using the completed measure list as a tool. If you have mainly taken standard measures (category A), the auditor expects a higher level of ambition in your plans.

Documents and publications for level 3

The result of your process is a portfolio: the file the auditor assesses. Part of it you must also publish.

Document	In portfolio	Publish on own website	On SKAO platform
Organisational boundaries	Yes	No	No
Energy review	Yes	No	No
Emission inventory with footprint	Yes	Via communications	No
Energy management action plan	Yes	Yes	No
Communication plan and communications	Yes	Communications: yes	No
Participation in initiatives	Yes	Yes	Yes
Internal audit and management review	Yes	No	No
CO2-bewust certificate (CO2-conscious certificate)	After the audit	Yes	Via the certification body

Do you have projects with CO2-related tender advantage? Then you must give insight into the emissions per project. Under 3.1 you may do this with allocation, for example pro rata to turnover. You also communicate at the start and on completion of such a project.

Example: reaching level 3 as an SME contractor

A fictional civil engineering (GWW) contractor with 35 employees wants level 3 for a tender. The management starts in June.

Month	Activity	Who
June	Project team, choice of certification body, record the audit date	Management, CO2 coordinator
June	Determine organisational boundaries and submit them to the certification body	CO2 coordinator
July	Collect invoices and fuel card data, energy review	Administration, CO2 coordinator
August	Draw up the footprint: diesel equipment 78%, vans 12%, electricity 7%, gas and business travel 3%	CO2 coordinator
September	Targets: -15% CO2 per million euro of turnover in three years, through an HVO pilot, electric vans and limiting idling	Management
September	Complete the measure list and establish the energy management action plan	Management, CO2 coordinator
October	Communication plan, first internal toolbox talk and website page	Communications
October	Join a sector initiative on zero-emission equipment	Management
November	Second internal and external communication, internal audit, management review	CO2 coordinator, internal auditor
December	External audit phase 1 and 2	Certification body

The footprint split in this example is fictional, but typical for civil engineering: the equipment determines the picture. Office measures deliver little, except as awareness.

What does the auditor want to see at level 3?

In phase 1, the auditor assesses your portfolio. In phase 2, they visit and speak with employees. For example, they ask a site manager which measure applies to their project. If that person does not know, the internal communication is not effective.

Auditor’s question	Evidence
Is the footprint complete and traceable?	Source data, emission factors, check by a second person
Are the targets ambitious and set by management?	Management report, justification with the measure list
Do employees know what is expected of them?	Interviews, toolbox talk records
Has communication taken place twice a year, internally and externally?	Communications with date
Is participation in the initiative active?	Reports, hours invested, own contribution

Use the audit checklist to organise your evidence.

Level 3 or tier 1: what do you choose in 2026?

From 14 January 2027, no new audits under handbook 3.1 are possible. Existing 3.1 certificates remain valid until January 2028 at the latest. In tenders, tier 1 counts as equivalent to level 3, but in substance tier 1 is stricter: you must also show that you actually reduce.

Situation	Advice
You already have a level 3 certificate under 3.1	Keep it, and plan the move to 4.0 at your next recertification
You start now and your audit can take place before 14 January 2027	Level 3 is still possible, but you will need to move soon anyway
You start now and the audit takes place in 2027	Choose tier 1 directly
The tender explicitly requires 4.0	Tier 1

At tier 1, the footprint changes, among other things: business travel no longer needs to be included in scope 1 and 2, scope 2 is calculated both location-based and market-based, and the energy review must cover 90% of your consumption instead of 80%. This is set out in the SKAO change list .

Next step

First calculate your CO2 footprint, and look at what the process costs in costs and timeline. Want to grow later? Level 4 requires a supply chain analysis, and level 5 a quantitative approach to your whole chain.