The CO₂ Performance Ladder outside construction: IT, healthcare, logistics and industry

Does the Ladder apply outside construction and to service providers?

Yes. The clearest statement sits in SKAO's Handreiking Aanbesteden 3.1, the procurement guidance for version 3.1, section 1.2 on page 8: "De Ladder kan in alle productcategorieën gebruikt worden om te sturen op CO2, klimaat, milieu, energie en circulariteit." The Ladder can be used in all product categories. The same paragraph names where that already happens: civil engineering, IT, facilities management, green maintenance, waste and healthcare.

Note the version. Those two sentences come from the 3.1 guidance. The Handreiking Aanbesteden 4.0 of September 2025 does not repeat that formulation. What the newer document does say, on page 38: "Projecten kunnen werken, diensten of leveringen zijn." Projects can be works, services or supplies.

The requirements themselves exclude nobody. Handbook 4.0, step 1 asks for an energy balance, an emission inventory, reduction targets, communication and a management system. None of that presumes a building site.

Where service providers do hit something different is the scoping of a project. The 4.0 guidance draws that line at the sector, not at the type of contract.

Source: Handreiking Aanbesteden CO₂-Prestatieladder 4.0, September 2025. A cleaning contract or a design commission inside the construction sector therefore follows EN 15804, not PEF. The confusion comes from readers splitting on contract type instead of on sector.

For how the steps themselves are built up, see why there are now three steps instead of five levels. That distinction is identical in every sector.

Which sectors actually use the Ladder?

SKAO's public register of certificate holders lets you filter by branche, the Dutch word for industry sector. On 11 August 2026 the filter listed 31 of them. Six are subdivisions of construction. The other 25 are not.

Source: the register on co2-prestatieladder.nl, consulted 11 August 2026. The same filter also covers version (3.1 or 4.0), step and country.

On the population itself, SKAO's own pages give two figures that are not the same. The Dutch page Wat is de Ladder says "ruim twee derde" of certificate holders are SMEs, ranging from civil engineering and transport firms to consulting and engineering practices. The English page What is the Ladder says "75% of certificate holders are small and medium-sized enterprises (SMEs)", alongside "around 8000 organisations" holding a certificate and "Over 300 public procuring authorities". Two thirds and 75 percent are not the same number. We publish both as they stand.

Why does the handbook still feel like a construction handbook?

Because the infrastructure around the standard is construction shaped, even though the standard is not. That shows up in three places.

That second point is countable. On 11 August 2026 the register held 1,206 published value chain analyses (ketenanalyses), spread over themes that overlap and therefore do not add up to the total.

Source: the value chain analysis register, consulted 11 August 2026. So a haulier has plenty to read. An IT company has 24 analyses. Healthcare has no theme of its own.

The practical consequence is that outside construction there is no template. One sustainability lead put it like this: "We now generate our own format. But I am not sure if it is in line with what the auditor expects." Outside civil engineering that is the normal situation. Because certification against version 4.0 has only been possible since 14 July 2025, there are barely any reference implementations to copy.

What does the Ladder mean for an IT services company?

Your scope 1 is small: usually the leased car fleet and perhaps a backup generator. Your scope 2 is electricity, and that is where a question sits that is easy to answer wrongly.

Public cloud and SaaS run on somebody else's hardware. That consumption sits in your scope 3 and only becomes mandatory from step 2. Colocation works differently. If your own equipment sits in rented space and the power is metered or sub metered and billed to you, that is your scope 2. The GHG Protocol Scope 2 Guidance states in section 5.2.1: "if a company is a tenant in a leased space or using a leased asset and applies the operational control approach, any energy purchased or acquired from another entity (or the grid) shall be reported in scope 2." Treating both cases the same way understates your scope 2.

Watch green electricity too. The Ladder uses a stricter definition than most market arrangements: only solar, wind, hydro and biomass generated in the same country where you consume it. A European certificate for a data centre across the border does not do on the Ladder what you expect it to do.

Hardware is the third. Laptops, servers and network equipment are the most obvious candidate for the top of your scope 3 ranking at an IT company, and there is no prescribed emission factor for any of them. See value chain analysis in practice for how to build that ranking.

How does the Ladder work out in healthcare?

Healthcare is named explicitly in SKAO's own list of product groups. Technically it is one of the easier sectors: gas for heating, electricity, an owned vehicle fleet, backup power. Meters that genuinely exist.

The difficulty is allocation. A campus has one gas meter and one main connection, while accountability sits with departments or operating companies. In practice people split 33/33/33, or 70/30, or 40/60, using headcount, floor area, a sub meter or an equal split as the basis. That is allowed, but it creates a number that cannot be traced one to one back to an invoice. As one practitioner said: "If you have an audit, how will you then keep track of it? And then we have a value which is not very traceable."

Two rules that work. Fix the allocation key once a year and leave it alone for changes under 5 percent. And collect at a finer level than you report: you can always add finely collected data up to a coarser level, you can never work backwards. More on this in group boundaries across multiple entities.

Refrigerants deserve separate attention in healthcare. Air conditioning, operating theatre cooling and cold storage are the first items to test against the materiality requirement for greenhouse gases other than CO₂.

What is different in transport and logistics?

This is where the instrument lines up most closely with what you already track. Three of the seven headings on the mandatory emission factor list are about transport: fuels for vehicles and vessels, passenger transport and freight transport. Your scope 1 is your fuel card. The register holds 177 analyses under the logistics and transport theme, more than under construction. SKAO also reports that the Ladder was named a best practice in the 2019 Sustainable Freight Procurement Guidelines from WBCSD and the Smart Freight Centre.

The trap is subcontracting. Loads driven for you by charter hauliers are not scope 1. They are scope 3, and only become mandatory from step 2, while your client already allocates them to you. Stay on step 1 and you report a number structurally lower than what customers put into their own scope 3.

What does a manufacturer run into?

For a manufacturing company the organisational boundary usually coincides with the site, which makes the emission inventory relatively simple. The meters are already there and consumption is large enough to see what a measure delivers. The reduction measures are technical, such as heat recovery and electrifying process heat.

Offsetting sits outside the Ladder's measurement scope, so you cannot buy your way up with certificates. The Ladder also replaces no existing obligation. It sits alongside them, and the gain is that the same dataset feeds your CSRD reporting under ESRS E1.

Industry is absent from SKAO's list of product groups where the Ladder is tendered, and Amsterdam limits itself to the physical domain. So establish first who is actually asking you for the number. If there is no tender behind it, the customer putting your intensity figure into their own scope 3 is the business case that remains.

What applies to waste, green maintenance and facilities?

All three are named in the Handreiking Aanbesteden 3.1 and all three have their own sector in the register. What drives the footprint is the same in each: diesel burned by plant and by vehicle movements, for clients that are frequently public bodies and already know the instrument. What the award advantage is worth is covered in tender advantage with the CO₂ Performance Ladder.

Waste has one thing the other two do not: methane. See the table further down.

Which sector are you if your group works across several?

A group working in several technical domains at once does not sit neatly under one industry code. A NACE code does not describe how such a business runs, and the same is true of the sector filter in the register.

Steer on activity. A business unit can work for two different legal entities and still perform the same activity. What stays stable is that activity. The entity doing the invoicing changes. Build your inventory at activity level, then aggregate up to whatever breakdown the report asks for.

Two warnings. The activity breakdown you inherited was often devised by someone who has since left the company, and nobody owns it now. "Overhead" is not an activity. And reporting a single average across all activities overstates the emission intensity of your cleanest work, which costs money the moment a customer feeds your intensity figure into their own scope 3.

Can a company with no tendered projects get certified?

Yes, and this is the point where the wrong conclusion gets drawn most often.

A CO₂ Performance Ladder project is defined in handbook 4.0 as "een aanbesteed project waarbij bij de inschrijving de CO₂-Prestatieladder een rol speelt en/of waarbij de opdrachtgever een voordeel verleent", a tendered project where the Ladder played a role in the bid or where the client granted an advantage for holding a certificate. If you have none of those, you do not have to produce a project footprint or a project communication plan.

What does not fall away is your ordinary work. Section 4.3 of the same handbook states: "Alle projecten moeten altijd onderdeel zijn van het energie- en CO2-managementsysteem van de organisatie." All projects must always form part of the organisation's energy and CO₂ management system. Only the additional documentation for CO₂ Performance Ladder projects is conditional.

Where are methane, nitrous oxide and refrigerants material?

Version 4.0 added an explicit materiality requirement for greenhouse gases other than CO₂. It appears in the handbooks as requirement 1.A.2, 2.A.2 and 3.A.2: assess whether non CO₂ greenhouse gases are material for scope 1 and scope 2, at a minimum frequency of "Voorafgaand aan iedere initiële audit en driejaarlijks", before every initial audit and every three years thereafter.

SKAO commissioned research in March 2022 into where this bites. Table 10 of that study gives no single ranking. It gives a verdict per gas, and that distinction is the reason the study exists, so we reproduce it intact.

Source: SKAO, Impact overige broeikasgassen, 31 March 2022, Table 10. For fluorinated gases (HFCs, PFCs, SF₆) the study makes no sector distinction and marks them relevant for all sectors.

Two things to know about this table. The study uses its own sector breakdown, which is not the register's filter: "Overheden, Waterschappen" exists in the study and not in the register, and the register lists "Bouw, Utiliteit" and "Installatietechniek" as separate sectors. And under 4.0 materiality remains an assessment you make yourself, per organisation. SKAO does not hand you a sector verdict to adopt.

The sources the study names are methane and nitrous oxide from earthmoving, dredged material and peat, from landfill, from wastewater treatment and from agricultural sources, plus fluorinated gases leaking from cooling and climate installations. For IT, healthcare, facilities and industry, refrigerant leakage is the item to assess in any case.

How to start, by sector

What certification costs is independent of your sector and depends on turnover and organisation size. See what the CO₂ Performance Ladder costs in 2026.

One note about people, because it applies in every sector. Colleagues who do not answer your data requests are rarely uninterested. They are embarrassed because they do not have the answer, and a field full of acronyms makes that worse. Finish one data point end to end first, and keep explanations short.

How Palau handles this

Palau records your inventory at activity level in Reef, the data layer, and lets the Organisational structure module do the aggregation to site, legal entity or certificate holder. That lets you collect finely and report coarsely without reinventing the allocation key for every report. Supporting evidence and allocation keys stay linked to the data point itself in Vault, so an allocation you created yourself can be traced back to a source during the audit. We support the CO₂ Performance Ladder, CSRD and VSME on the same dataset.

Want to see this on your own numbers? Request a pilot.

Frequently asked questions

Does the CO₂ Performance Ladder apply outside construction? Yes. The Handreiking Aanbesteden 3.1 states that the Ladder can be used in all product categories. The requirements in handbook 4.0 cover an energy balance, an emission inventory, reduction targets, communication and a management system, and none of them presumes a building site. The public register listed 31 sectors on 11 August 2026, 25 of them outside construction.

Which sectors actually apply the CO₂ Performance Ladder? SKAO names civil engineering, IT, facilities management, green maintenance, waste and healthcare explicitly in the Handreiking Aanbesteden 3.1. The register additionally covers industry, energy, education, food, retail, wholesale, government and transport and logistics.

Can a service provider with no tendered projects get certified on the CO₂ Performance Ladder? Yes. Without CO₂ Performance Ladder projects you do not need a project footprint or a project communication plan. Your ordinary contracts do remain part of your energy and CO₂ management system, because section 4.3 of handbook 4.0 states that all projects must always form part of it.

Why is the CO₂ Performance Ladder harder for IT companies? Because the largest items often sit outside scope 1 and 2 and no emission factors are prescribed for them. Public cloud and SaaS sit in scope 3. With colocation it depends on your contract: if you get a metered or sub metered bill for your own equipment, that electricity is scope 2. The Ladder also counts only solar, wind, hydro and biomass from the same country as green electricity.

Which sectors have material non CO₂ greenhouse gases under version 4.0? SKAO research from March 2022 assesses this per gas. For methane the impact is large for earthworks, hydraulic works, water authorities and the waste sector, and medium for road building and green maintenance. For nitrous oxide it is large for earthworks, hydraulic works and water authorities, and medium for road building. Fluorinated gases apply to all sectors. The requirement itself is 1.A.2, 2.A.2 and 3.A.2 and asks for an assessment before every initial audit and every three years thereafter.

Does a CO₂ Performance Ladder certificate earn tender advantage outside construction? Only if the contracting authority actually includes the criterion. Gunningvoordeel, the award advantage, is a notional discount applied to your bid price for evaluation purposes only; if you win you are still paid the full quoted price. The Handreiking Aanbesteden 4.0 states that projects can be works, services or supplies. In practice application stays mostly within the physical domain. The City of Amsterdam applies the Ladder to all multiple, national and European works tenders and to European service and supply tenders within the physical domain.