Which rules actually require a GHG inventory?

In short

• Only CSRD through ESRS E1-6 imposes a full greenhouse gas inventory by law, and only above both thresholds.
• The CO2-Prestatieladder demands an audited inventory and is not law at all. It is a bid price.
• EUDR, PPWR, the EU Taxonomy and Dutch WPM require no carbon inventory, and are routinely described as if they did.

Two instruments in this field actually require a greenhouse gas inventory, and only one of them is law. CSRD, through ESRS E1-6, requires a full inventory with limited assurance from undertakings above both EUR 450 million of turnover and 1,000 employees. The CO2-Prestatieladder requires an audited inventory and is a private certification scheme with no legal force. Everything else on the usual list either asks for a number that is not an inventory, or asks for no carbon data at all. Here is each one checked separately.

The reason this matters is cost. A company that thinks four regulations demand a footprint builds for four and negotiates from a weak position on all of them.

What counts as a GHG inventory, and why does the distinction matter?

An inventory is a stated organisational boundary, activity data with source records behind it, emission factors applied to that data, a base year, and a result in tonnes of CO2 equivalent that can be reproduced next year on the same basis.

A carbon number is not the same thing. Kilometres travelled are not an inventory. A product life cycle result is not an organisational inventory. An energy performance certificate is not carbon data at all. The test that separates them: could an auditor trace a reported tonnage back to a record? If the instrument never asks for a tonnage, there is nothing to trace and no inventory to build.

Which instruments actually require one?

Twelve checked, in the order they usually come up.

Two of twelve. That ratio is the point of the page.

What does the one legal requirement actually demand?

More than most in-scope companies expect, and in a specific shape.

ESRS E1-6 paragraph 44 requires disclosure, in metric tonnes of CO2 equivalent, of gross scope 1, gross scope 2, gross scope 3 and total greenhouse gas emissions. Scope 2 has to appear twice, location-based and market-based, and the total has to be presented on both bases. Scope 3 covers each significant category, meaning each category that is a priority for the undertaking, rather than all fifteen automatically. There is a greenhouse gas intensity figure per net revenue whose denominator has to reconcile to a line item or a note in the financial statements.

The boundary rule is where the work sits. The sustainability statement is prepared for the same reporting undertaking as the financial statements, and for greenhouse gases specifically, associates, joint ventures, unconsolidated subsidiaries and jointly controlled operations come in according to operational control, at 100 percent of the emissions of an entity you operationally control rather than at your equity share.

And you cannot simply omit what you cannot collect. Where the undertaking cannot get value chain information after reasonable efforts, ESRS 1 paragraph 69 requires it to estimate using reasonable and supportable information such as sector averages and other proxies. Estimation is the expected route, not the failure mode. The one-year omission of scope 3 and total emissions in Appendix C is limited to undertakings and groups at or below an average of 750 employees, and only for their first year.

Which ones ask for a carbon number without asking for an inventory?

Three, and each is misread in a different direction.

Dutch WPM. The employer submits kilometres by mode and fuel type, per KvK-registered entity, and the ministry converts them to CO2 to monitor a sector ceiling. No employer reports a tonnage. There is an emission limit value of 96 grams of CO2 per passenger-kilometre written into the decree, and it has never been brought into force. The data does overlap almost exactly with scope 3 categories 6 and 7, which is a real efficiency argument and not a compliance one.

Rijkswaterstaat and the MKI. In a single Dutch infrastructure tender the ladder scores the organisation and the MKI scores the project. The MKI is life cycle work against a prescribed protocol, delivering a value for a specific design. Carbon accounting software answers the first question, not the second, and contractors lose money confusing them.

EcoVadis. It does not require an inventory. What it does is make your inventory expensive to fake: greenhouse gas and energy data must cover 95 percent of the assessed scope to be credited at all, against 80 percent for other reporting. So boundary completeness matters more than precision, and a rougher complete footprint beats a tidy partial one. Read on 28 August 2026 from the published methodology disclosures.

Which ones are routinely misdescribed as carbon rules?

EUDR and PPWR, and it is worth being blunt about both.

EUDR creates no greenhouse gas accounting obligation of any kind. Nothing in the operative articles asks for a tonne of CO2 equivalent. Greenhouse gases appear in the recitals, as the policy rationale. What it asks for is plot geolocation, evidence of legal production, a documented risk assessment and a due diligence statement filed in the EU information system.

PPWR contains no carbon footprint, no emissions inventory and no product carbon footprint requirement anywhere. It is a materials and waste compliance regime that happens to land on the same desk as the carbon questionnaire.

Both share a dataset with carbon work, which is why the conflation happens. Ingredient traceability improves the emission factors you can defend, and packaging composition data is what a product footprint runs on. Those are efficiencies, not obligations.

What about the rules that are not rules?

Three entries on the list bind nobody, and one of them we removed from our own fact base.

The EU strategy for sustainable and circular textiles is a Commission Communication. It creates no obligation, sets no deadline and carries no penalty. It is correct to say it sets direction, and wrong to list it as a rule that applies to a brand.

Green Deal Duurzame Zorg is a voluntary covenant whose own text states that its commitments are not enforceable in court. Several hundred Dutch care organisations have publicly committed to reducing their footprint, which is why they ask suppliers for data. That is commercial pressure, not a rule you can be found in breach of.

Dutch education procurement was the one we had wrong. There is no dated procurement requirement obliging Dutch schools, MBO institutions, hogescholen or universities to measure or report CO2. What exists is a policy agenda and a voluntary manifest. We corrected our own fact base on 28 August 2026.

If nothing on the list applies to you, why build one anyway?

Because the demand for the data survived the narrowing of the duty.

A company inside CSRD still has to report value chain information, still has to include scope 3 for every significant category, and is told to estimate with sector averages where it cannot collect. That is why the supplier questionnaire outlived its own regulation. In the Dutch market the ladder converts an inventory directly into bid advantage, which is a better reason than compliance ever was. We cover that route in the CO2 Performance Ladder for SMEs.

If you are under 1,000 employees, aim the work at the voluntary standard rather than full ESRS. The VSME standard sets out the surrounding regime.

Where should you start?

With the boundary, because every instrument above that wants a number wants the same one, and rebuilding the boundary later is the expensive mistake.

Then activity data, then factors, then the second year on the same basis. You can do the first pass on a free account with no sales call. The platform serves 5,000+ users and covers more than 20,000 spend-based and activity-based factors. Carbon footprint consulting is for the first inventory and scope 3 consulting for the value chain half. If you are still choosing a tool, our software comparison for SMEs is the neutral version.

One limit to state before you plan the wider job. A Mid-Market reviewer rated us 3.5 out of 5 on G2 in June 2026 and said that as a broad ESG and CSRD reporting platform this one is less complete, with no data source management feature and no decarbonisation target monitoring. The emissions calculation is what we cover well.

Sources: Delegated Regulation (EU) 2023/2772 ESRS E1 and ESRS 1, Delegated Regulation (EU) 2025/1416, Directive (EU) 2026/470, Regulation (EU) 2020/852, Regulation (EU) 2023/1115, Regulation (EU) 2025/40, Besluit CO2-reductie werkgebonden personenmobiliteit, SKAO Handboek 4.0, Rijkswaterstaat procurement policy, COM(2022) 141 final, Green Deal C-238, PIANOo education procurement guidance, EcoVadis methodology disclosures. Verified 28 August 2026.

Facts on this page were last verified on 2026-09-17.