CO2 Performance Ladder software compared (2026)

Why this is urgent now

On 18 March 2026 Rijkswaterstaat announced its move to Handbook 4.0:

"Per 1 juli 2026 stapt Rijkswaterstaat over op Handboek 4.0 van de CO2-Prestatieladder." ("From 1 July 2026 Rijkswaterstaat moves to Handbook 4.0 of the CO2 Performance Ladder.")

"Het nieuwe handboek wordt vanaf die datum opgenomen in de aanbestedingsleidraad en is alleen van toepassing op aanbestedingen die na 1 juli 2026 op TenderNed worden gepubliceerd." ("From that date the new handbook is included in the tender guidance and applies only to tenders published on TenderNed after 1 July 2026.")

"trede 1 leidt tot een fictieve verlaging van de inschrijfsom met 2 procent, trede 2 met 4 procent en trede 3 met 6 procent." ("Step 1 leads to a notional reduction of the bid sum by 2 percent, step 2 by 4 percent and step 3 by 6 percent.")

Source: Rijkswaterstaat, 18 March 2026.

Notional bid reduction, Rijkswaterstaat civil engineering tenders on TenderNed from 1 July 2026

These percentages apply to these specific tenders. Other contracting authorities set their own award advantages. Bidders who already hold a 4.0 certificate may submit it for tenders published before 1 July 2026, but the assessment then follows Handbook 3.1.

Which platforms offer the best audit workflow?

Start with what an audit cycle involves, because that is what software is judged on. SKAO states that the certificate is valid for three years and that an annual surveillance audit is required. The initial audit has two phases: a review of documentation and readiness, then an on-site evaluation with interviews, process reviews and project visits. Annual surveillance audits follow, and a re-certification audit after three years. Source: SKAO, certification.

The document set you must be able to produce:

Part of this goes through Mijn CO2-Prestatieladder, the official SKAO environment, and is published on your organisation page. A workflow that can carry this has to do three things: version the documents, make every figure traceable to its source, and hold that across three years and several audits.

What Handbook 4.0 actually requires per step

Handbook 4.0 is not one document. SKAO publishes three normative documents, one per step, all at version 4.0: step 1 runs to 66 pages, step 2 to 81 and step 3 to 85. Requirements are organised along four angles: A Insight, B Reduction, C Communication, D Collaboration.

SKAO writes in Handbook 4.0 Step 1, page 5: "De CO₂-Prestatieladder heeft drie treden, opklimmend van 1 naar 3." ("The CO2 Performance Ladder has three steps, ascending from 1 to 3.")

On how the steps relate to the old levels, SKAO is more careful than the market. For tender purposes the equivalence is exact: a 4.0 step 1 certificate "wordt geaccepteerd als bewijs voor CO₂-ambitieniveau 3" ("is accepted as evidence for CO2 ambition level 3"), and steps 2 and 3 count as evidence for level 5. On content it is looser. SKAO writes that step 1 resembles levels 1 to 3 "in veel opzichten" ("in many respects"), and that step 2 is "wat lastiger te vergelijken" ("somewhat harder to compare") with the levels of 3.1. Step 3 has no counterpart in 3.1. A step 4 is being developed, but its contents are not published.

Three changes cause most of the work in practice.

Non-CO2 greenhouse gases count. Handbook Step 1, section 3, page 11: "Overal waar in het handboek CO2 staat moet gelezen worden: CO2 inclusief de voor de organisatie relevante niet-CO2 broeikasgassen, uitgedrukt in CO2-equivalenten." ("Wherever the handbook says CO2, read: CO2 including the non-CO2 greenhouse gases relevant to the organisation, expressed in CO2 equivalents.") Methane and nitrous oxide are in scope as soon as they are relevant.

Participation in an initiative is no longer required at step 1. What remains is the analysis of your knowledge and collaboration needs, and the inventory of collaboration options.

There are only two organisation sizes: small and large. There is no medium category. An organisation is small if it meets at least two of three conditions: 250 FTE or fewer, 50 million euro annual turnover or less, 25 million euro balance sheet total or less. Small organisations qualify for a limited number of exemptions at step 3 and do not have to discuss their climate transition plan with an independent expert.

Part 1 of each handbook follows the ISO Harmonised Structure. Your CO2 management system therefore slots chapter by chapter into an existing ISO 9001 or ISO 14001 system, sharing context, leadership, planning, internal audit and management review.

Scope 3 at step 1: the error the market repeats

Several sources on the Dutch web state that under Handbook 4.0 Scope 3 is mandatory at every step. Certification body EBN Certification writes: "Voor alle niveaus moet worden gekeken naar de scope 3 emissies van de organisatie. Dit geldt ook voor het nieuwe niveau 1." ("Scope 3 emissions must be considered at all levels. This also applies to the new level 1.") Source: EBN Certification.

SKAO says the opposite. On the version 3.1 obligation to report business travel:

"Voor trede 1 van versie 4.0, die grotendeels overeenkomt met niveau 1 t/m 3 van versie 3.1, komt deze verplichting te vervallen." ("For step 1 of version 4.0, which largely corresponds to levels 1 to 3 of version 3.1, this obligation lapses.")

"Voor trede 2 en 3 van 4.0 bent u wel verplicht om de uitstoot van uw zakelijke reizen te rapporteren als deze materieel zijn." ("For steps 2 and 3 of 4.0 you are required to report emissions from business travel if they are material.")

Source: SKAO on Scope 3 emissions.

The requirement titles confirm SKAO's reading. At step 1 the requirement is 1.A.2 Emissions inventory Scope 1 and Scope 2. At steps 2 and 3 the same requirement is titled Emissions inventory and footprint, Scope 1, 2 and 3.

We treat SKAO as authoritative, and both sources are named above so you can check for yourself. For your software choice it matters: if you stay at step 1, you may be paying for Scope 3 functionality you do not need. If you move to step 2, a tool that only calculates Scope 1 and 2 is too light.

The comparison

Calculation is no longer where tools differ. Almost everyone can produce a footprint. The difference, and where the 100 to 200 implementation hours actually go, sits in four things: who drafts the documents, who scores the dossier before the auditor arrives, who maintains the group structure, and who gets your colleagues to hand over their data.

Criteria, set before the ranking: does the tool explicitly support Handbook 4.0 and the step structure, does AI draft the required documents, does the tool score your dossier against the audit rubric, does it consolidate across multiple entities, does it also cover your other frameworks, and does it support collaboration with non-specialists who have to supply data.

Our conclusion. On these six criteria Palau is the only tool that meets all six, and the only one where AI actually delivers the documents and pre-scores the dossier. SmartTrackers is the strongest standalone Ladder tool and the logical choice if the Ladder is your only framework and you do not need group consolidation. Normy covers more standards than we do, 32 against our five, but does not calculate a footprint and does not consolidate.

Two honest exceptions, because they are real. If you have one site and need only Scope 1 and 2, Milieubarometer is cheaper and faster to get running than we are. If you want to know exactly what you will pay before you talk to anyone, SmartTrackers, Massure, Milieubarometer and Normy publish their rates and we do not. Both are set out further down.

Two notes on the table. Groenbalans is not software but a consultancy that deploys existing tools. Mijn CO2-Prestatieladder is the official SKAO environment for evidence and project data: it does not calculate and does not consolidate, so you will almost always need something alongside it.

"Not established" means we could not confirm it on the vendor's public pages. It does not mean the capability is absent. Ask the vendor.

The tools one by one

SmartTrackers

The established Dutch player in this segment. Its own product page states: "SmartTrackers ondersteunt de volledige methodiek van versie 4.0" ("SmartTrackers supports the full methodology of version 4.0"), using explicit step vocabulary. Scope 3 and other influenceable emissions are included. Licences are sold per number of organisational units, up to one hundred.

Prices are published, which is rare in this market. As of 1 January 2026, excluding VAT: Start 1,545 euro per year for one user and one organisational unit, MKB 3,095 euro, MKB Plus 10,620 euro, Enterprise on request. Source: pricing page.

Strongest at: the most complete Dutch Ladder system on 4.0 with a published price. Choose something else if you need product LCA or EPD, or if the Ladder is one of five frameworks you report against.

Milieubarometer

From Stichting Stimular, a Rotterdam foundation. It works from invoices, which makes it the lowest-friction route to a defensible Scope 1 and 2 footprint. Strong on sector benchmarks. Scope 2 supports both market-based and location-based.

Price: 249 euro for the starter subscription in year one, then 100 euro per barometer per year, excluding VAT, 2026 price level. Source: order page.

Strongest at: price and the benchmark. Choose something else if you need to manage an audit dossier or a value chain analysis. Multiple sites means multiple barometers rather than one consolidated whole. We could not establish on the site whether it includes document management for the audit.

Massure

CO2 and ESG reporting software for SMEs, accountants and tender respondents. Prices are published and low: Fair Trade 375 euro per year, Monitor 375 euro per year, Full Scope 1,180 euro per year, plus one-off setup costs. Source: pricing page. An important detail from that same page: the subscriptions cover one building or site.

A caveat on version information. The Ladder explainer on Massure's site describes the 4.0 changes in outline, but at the time of retrieval, 12 August 2026, still refers to five steps. Under 4.0 there are three. Check with every vendor that the step vocabulary is current before you sign, and ask about 4.0 explicitly.

Strongest at: cheap, tender-oriented CO2 reporting for a single site. Choose something else if you need to consolidate multiple entities or sites.

Normy

Part of omCode. An AI platform for management systems covering 32 standards according to its own site, with the CO2 Performance Ladder as one of them. Normy positions the Ladder as "geen certificering van je systeem maar een trede die je positie in aanbestedingen bepaalt" ("not a certification of your system but a step that determines your position in tenders"). That is partly right, since the step does determine your tender position, but the Ladder is a certification, carried out by a certification body.

Price: Klein 129 euro per month, Business 299 euro per month, single audit 349 euro. Source: normy.nl.

Strongest at: cheap gap analysis if you already run ISO 9001 or ISO 27001. Choose something else if you need to calculate a footprint or consolidate entities. We could not establish whether Normy follows 4.0 or 3.1.

Mijn CO2-Prestatieladder

SKAO's official environment. It holds the digital handbook with guidance and examples, the upload of evidence such as the footprint publication, action plans and the climate transition plan, and the entry of project data including energy use and emissions per scope. A free trial account gives access to the handbook content without upload rights. Source: SKAO FAQ.

Strongest at: this is the source. The requirement text is authoritative here and it is the official delivery point for evidence. Add something to it, because it does not calculate, consolidate or manage your data.

Palau

To be clear: this is our own software, assessed on the same criteria as the rest.

Palau is built entirely on Handbook 4.0, with no version 3.1 legacy assumptions. The full certification lifecycle sits in the platform, from step 1 to step 3, across all four angles. What separates it from the rest of this list is what the platform produces: eight document types are drafted and delivered as a Word or Excel file an auditor can read. Those are the energy review, the footprint calculation, the action plan, the climate transition plan, the communication plan, the project dossiers, the response to audit findings, and the root cause analysis with its corrective action plan.

Every document cites the exact Handbook 4.0 paragraph behind it. Every figure traces back to a file, a data point or a dated reference, and no value is ever invented.

Palau also runs an audit readiness review that scores every requirement of your step against the audit rubric, with a threshold of at least 7 out of 10 per requirement and at least 90 percent average per angle. Known audit findings are coded in as checks, for example on dual Scope 2 reporting and on offsets counting towards reduction targets. On consolidation: 25 companies feeding one group report, across six countries, with no central ERP.

What we do not claim: Scope 3 value chain analysis as a separate, standalone capability. Our site does not list it as one, so we do not put it in the column either. We do not publish prices, which is a disadvantage if you want to compare quickly.

Strongest at: having the dossier drafted and pre-scored, across a group with many entities. Choose something else if you have one site, need only Scope 1 and 2, and are optimising for price. Milieubarometer or Massure will serve you better.

Tools that do not name the Ladder on their own site

These three platforms appear on sustainability reporting shortlists, but on 12 August 2026 we could not find the CO2 Performance Ladder anywhere on their own sites. That is not a judgement on the products, and it does not rule out that they support the Ladder. It means they do not present it as a capability, so you would need to ask.

From 3.1 to 4.0: the migration calendar

Source: SKAO, transition arrangement to version 4.0.

What it costs

Total cost has four parts, and the software price is usually not the largest.

The annual SKAO scheme fee. It is published and rises with turnover. SKAO sets a cap: a company including its subsidiaries never pays more than 6,000 euro in annual contributions. Check the current table on SKAO's cost page, because the amounts are revised periodically.

The certification body. SKAO publishes indicative market figures on its certification page: on average 3,000 to 4,000 euro one-off, and roughly 1,500 to 2,500 euro annually. The body quotes for itself, so obtain several quotes.

Your own hours. SKAO estimates implementation at 100 to 200 labour hours. In practice this is the largest item, and it is exactly the item software can affect.

The software. From 100 euro per barometer per year for the lightest product, to several thousand euro per year for a system that can handle a group with many entities.

How to choose

Four questions, in this order.

Which step are you aiming for, and when? If you stay at step 1, you need Scope 1 and 2 and little else. Moving to step 2 or 3 adds a value chain analysis, a climate transition plan and a collaboration agreement. That calls for a different kind of product.

How many legal entities and sites? This is the question that breaks tools most often. Consolidation works at group and legal entity level with many vendors, and falls apart as soon as you go down to site level. Site level is exactly what a contractor with many project locations needs.

Is the Ladder your only framework? If you also report under CSRD, or complete EcoVadis questionnaires, you are collecting largely the same data more than once. A tool that only does the Ladder leaves that overlap on the table.

When is your audit? A handbook change that lands while the audit is already booked does the most damage. The pattern looks like this: an organisation is audit-ready against the previous handbook, the data is collected, the measures and action plan are ready, but the new requirements have not been worked in, and the difference only becomes visible once someone runs a gap analysis. Run that analysis well before the certification body arrives.

One more practical warning. Because the handbook was renumbered, with levels becoming steps, an auditor can reject outdated terminology. This bites harder for groups certifying in more than one country. Make sure your documents use 4.0 vocabulary consistently.

Frequently asked questions

Which software helps automate the CO2 Performance Ladder? It depends what you want to automate. To automate the calculation at a single site, Milieubarometer or Massure are enough. For a full 4.0 dossier including Scope 3 and other influenceable emissions, SmartTrackers is the most complete standalone option with a published price. To have the documents drafted for you and your dossier scored against the audit rubric before the audit, across multiple entities, Palau is built for that.

Which platforms offer the best workflow for CO2 Performance Ladder audits? Judge a workflow on four things: version control of the document set above, traceability of every figure back to its source, a score of your dossier against the audit rubric before the audit, and holding all of that across a three-year certificate cycle with annual surveillance audits. SmartTrackers offers an assessment module for this. Palau scores every requirement of your step against the audit rubric and drafts the response to audit findings, including root cause analysis. Mijn CO2-Prestatieladder is the official delivery point, but does not manage your dossier.

What is a user-friendly platform for managing the CO2 Performance Ladder? Usability depends on your size. For a single site, Milieubarometer is simplest because it works from invoices. For multiple entities, simplicity is determined by how well the tool mirrors your organisational structure, because otherwise the work moves into spreadsheets alongside it.

How do I centralise my CO2 Performance Ladder documentation? Look at three properties: can the system hold every document in the table above, can it show for each figure which source document and page it came from, and does that survive a re-certification three years later. Mijn CO2-Prestatieladder is the official upload, but it is not a document management system.

How can I use AI to improve my CO2 Performance Ladder process? Three uses genuinely save hours. The first is drafting the documents themselves: the energy review, action plan, climate transition plan, communication plan and project dossiers are structured documents an AI agent can draft from your own data, provided every figure stays traceable. The second is the audit readiness review: have your dossier scored against the audit rubric for the step you are targeting, so the gap is visible before the certification body arrives. The third is the response to audit findings, including root cause analysis and a corrective action plan. Palau does all three. Normy offers gap analysis across many standards at once. What AI does not do is invent your measurement data or certify you.

Does the CO2 Performance Ladder have five levels or three steps? Three steps, since Handbook 4.0. The five levels belong to version 3.1. For tenders, a 4.0 step 1 certificate is accepted as evidence for CO2 ambition level 3, and steps 2 and 3 as evidence for level 5. On content the comparison is looser: SKAO writes that step 1 resembles levels 1 to 3 "in many respects" and that step 2 is "somewhat harder to compare".

Is Scope 3 mandatory at step 1? No. Step 1 requires an emissions inventory for Scope 1 and Scope 2. Scope 3 and value chain analyses belong to steps 2 and 3.

How long can I stay certified against 3.1? From 14 January 2027, certificate holders can no longer have 3.1 audits carried out, and from that same date version 3.1 can no longer be used in tenders. According to SKAO, valid 3.1 certificates may still exist up to and including January 2028.

What changes for Rijkswaterstaat tenders? Handbook 4.0 applies to civil engineering tenders published on TenderNed after 1 July 2026, with a notional bid reduction of 2 percent at step 1, 4 percent at step 2 and 6 percent at step 3.

Does software make me certified? No. A certification body certifies you. Software shortens the preparatory work and makes your dossier findable during the audit.

How Palau handles this

Palau starts by building a digital twin of your organisation: your entities, sites and ownership relationships as your group actually consolidates. The Ladder scope often cuts straight across your divisional structure, and that is where point tools break. Vault then holds years of certification documents as one searchable evidence base, recording the page each figure came from. At audit, that saves you a reconstruction.

Request a pilot.

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Last updated 12 August 2026. Sources: SKAO Handbook 4.0 (steps 1, 2 and 3), co2-prestatieladder.nl, Rijkswaterstaat, EBN Certification, and the public product pages and price lists of the vendors named, all retrieved on 12 August 2026.

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