Carbon footprint in Belgium: costs, obligations and funding in 2026

In Belgium, no law requires an SME to assess its carbon footprint. The demand comes from elsewhere: clients subject to the CSRD questioning their suppliers, Flemish public tenders rewarding CO2-certified companies, banks and assessment platforms. In 2026, the framework has changed substantially: the CSRD's scope is narrowing, the CO2 ladder is extending to works contracts, and a large share of consultancy funding has been suspended or abolished.

This guide is for executives and CSR managers in Walloon, Brussels and Flemish companies. It reviews what concerns you, the cost of a carbon footprint assessment, funding still open as of 5 October 2026 and how we carry out the assessment with you.

1A voluntary carbon footprint assessment, but increasingly required

No requirement for an SME

Neither the federal government nor the regions require companies to produce a greenhouse gas emissions inventory. The Walloon "Carbon Neutrality" decree of 16 November 2023 sets regional targets and organises carbon agreements, but requires no company inventory. The Walloon Agency for Air and Climate (AWAC) also specifies that its GHG inventory guide is used "only as part of a voluntary exercise". Only installations subject to the European carbon market (EU ETS) report their direct emissions annually, which is not an organisational inventory.

What requires certain companies to act

A few rules target specific companies, often concerning energy rather than carbon:

• The CSRD, for large companies, with a sharply narrowing scope (see below).
• Energy audits for large companies, every 4 years in Wallonia and Flanders, where the rules depend on energy consumption, and in Brussels by an approved auditor when applying for or renewing environmental permits.
• Walloon carbon agreements, succeeding sector agreements: voluntary, but committing more than 200 industrial companies to a vision of carbon neutrality in 2050 and annual reporting.
• Brussels PLAGE, an energy action plan, for companies owning or occupying at least 100,000 m² of buildings in the Region.

Why SMEs are starting

Most SMEs assessing their carbon footprint are prompted by their clients. A principal subject to the CSRD must report its value chain emissions, scope 3, and sends questionnaires to its suppliers. Banks incorporate carbon into their credit analysis, and assessment platforms such as EcoVadis ask for quantified emissions. Finally, the assessment serves its intended purpose: identifying the main sources and reducing emissions, often alongside the energy bill.

2The CSRD in Belgium in 2026

The Act of 2 December 2024 and the 2-year postponement

Belgium transposed the CSRD through the Act of 2 December 2024 on the publication of sustainability information. Before the European reform, it covers companies exceeding 2 of these 3 criteria: 250 employees, €50 million in net turnover, €25 million in total assets, as well as public-interest entities. The Act of 12 December 2025 transposed the European "stop-the-clock" postponement: other large companies first report on the 2027 financial year, and listed SMEs on the 2028 financial year.

The Omnibus Directive: a 2026 exemption, with transposition still to come

Directive (EU) 2026/470, known as Omnibus, limits the CSRD to companies with more than 1,000 employees and more than €450 million in turnover. Belgium is applying it in 2 stages. The Act of 15 July 2026, published in the Belgian Official Gazette on 31 July 2026 (Chamber document 56K1596), exempts first-wave public-interest entities not exceeding one of these 2 thresholds from reporting on the 2026 financial year. Full transposition is the subject of a preliminary bill approved by the Council of Ministers on 18 July 2026, which still needs to be examined by the Council of State and then passed. The European deadline is 19 March 2027.

For an SME, the effect is twofold. It is even less likely to be subject to the CSRD itself, but its large clients remain required to report on their value chain. The preliminary bill also provides a protection regime for value chain companies, limiting the information a group subject to the CSRD can demand from suppliers outside its scope. Our article on carbon footprint assessments and the CSRD details what the ESRS E1 climate standard expects.

3Flemish public tenders: CO2 certification that helps win contracts

If your company bids for Flemish works contracts (roads, waterways, public transport), CO2 certification can help you win a contract without lowering your price. Since 2025, the Flemish Mobility and Public Works policy area has applied the CO2 Performance Ladder (CO2-prestatieladder): when comparing bids, it deducts 2 to 10% from certified companies' prices, according to their level from 1 to 5. The contract is still paid at the bid price.

An example: 2 companies bid for the same works. The first asks for €1,000,000 and has no certificate. The second asks for €1,040,000 and has a level 3 certificate. For comparison, the administration deducts 6% from the second bid, giving €977,600: it wins the contract and is paid €1,040,000.

Service order MOW/MIN/2024/02 of 25 April 2024 extends the rule in stages to 8 entities, including the Roads and Traffic Agency, De Vlaamse Waterweg and De Lijn:

• Since 1 January 2025: investment contracts of at least €5 million excluding VAT.
• Since 1 January 2026: investment contracts of at least €3 million.
• From 1 January 2027: investment and maintenance contracts of at least €1 million.

The level stated in the bid must be proved after award through a "CO2-bewust" certificate issued by an accredited certification body. This certificate rests on the company's emissions inventory, followed by reduction targets and, at higher levels, work with the value chain: the carbon footprint assessment is its foundation. The ladder's framework is moving to a new version, which could change these rules from 2027.

4How much a carbon footprint assessment costs

The price depends on the number of days

There is no public price schedule. The price of a carbon footprint assessment depends mainly on the number of working days, itself linked to the number of sites, data availability and scope 3 depth. Data collection alone takes 60 to 70% of the time: this is what determines the quote.

A senior climate consultant's daily rate is around €800 to €1,200 excluding VAT. For a single-site SME, a complete scopes 1, 2 and 3 inventory with an action plan generally costs €10,000 to €15,000 excluding VAT, and most consultant-led assessments cost between €10,000 and €30,000 excluding VAT, more for a complex industrial production site. Preparing collection with your teams can reduce the bill by 30 to 50%.

Free calculator, software or consultancy support

AWAC provides a free carbon calculator for micro-enterprises and SMEs. It gives an initial order of magnitude, but simplifies scope 3 and may underestimate emissions. Subscription software speeds up collection without guaranteeing result quality, which depends on the internal lead. Consultancy support costs more in the first year, but produces an inventory your clients and a certifier can review. We compare these options in our article on software or a consultancy.

The method: GHG Protocol, ISO 14064-1 or Bilan Carbone®

Belgian companies mainly use the GHG Protocol and ISO 14064-1, cited by AWAC; the CO2 ladder also draws on ISO 14064-1. The Bilan Carbone® method is also offered in Belgium. The 3 methods cover the same scopes; our GHG Protocol or Bilan Carbone® comparison explains their differences, and the right choice is often the one your client or certifier requests. Our answers to frequently asked questions add to this point.

5Funding in 2026: what remains, region by region

2026 has sharply reduced carbon consultancy funding. Here is what is still open as of 5 October 2026.

Wallonia: vouchers mainly focused on energy

Business vouchers cover 8 themes, but no voucher is dedicated to carbon footprint assessments. The Energy voucher funds 75% of an energy audit carried out by an approved auditor, with a €6,000 annual grant cap for a comprehensive audit. Growth vouchers, at 50% of the cost excluding VAT, cover "environmental management" (excluding sustainable development strategy), a category that could include a carbon footprint assessment: confirm this with Wallonie Entreprendre before signing.

These vouchers are reserved for SMEs with an operating establishment in Wallonia, and the provider must be approved; new approvals have been suspended since July 2025 for most vouchers, pending reform. Companies in a carbon agreement with a validated action plan can also access calls for projects: the July 2026 call, which closed on 25 September, made just over €39 million available for their investments.

Flanders: the end of the kmo-portefeuille

The kmo-portefeuille no longer funds sustainability consultancy since February 2026, and the Flemish Government has announced the scheme's closure. Strategische ecologiesteun can fund environmental studies, but only within an investment project of at least €1.5 million.

Brussels: consultancy grants suspended until the end of 2026

The consultancy grant for economic transition covered 50 to 80% of a consultancy assignment on strategy or environmental impact measurement, a category that could include a carbon footprint assessment. With no budget, the Region suspended its consultancy grants from 12 August 2026, for the whole 2026 budget year. The 2027 regime has not yet been set.

6How we carry out your carbon footprint assessment

Projet Celsius is a consultancy specialising in measuring and reducing organisations' and products' carbon footprints. Our consultants have carried out around twenty carbon footprint assignments for organisations such as Bacardi-Martini, Avanade, Institut Pasteur and Réseau Astre. Our method has 4 steps:

• Scope around what you are being asked for: a client questionnaire, an EcoVadis rating, CO2 certification for a Flemish tender. Scope and method follow from this, without unnecessary work.
• Organise collection with your teams: we prepare files and priorities so your leads provide only the data that matter. This step determines how the quote varies.
• Calculate and check: scopes 1, 2 and 3 under the GHG Protocol, ISO 14064-1 or the Bilan Carbone® method, with uncertainties documented.
• Present and decide: a presentation to management, a prioritised and quantified action plan, and a calculation model you keep to update the inventory in subsequent years.

An assignment takes 6 to 10 weeks when data have been gathered beforehand, or 3 to 4 months when collection needs to be organised in depth. We work remotely with your teams and visit the site for the launch and presentation. The assessment also prepares the next steps: a transition plan, an SBTi trajectory for an industrial SME, or a product life cycle assessment. Discover our carbon footprint service or contact us: a senior consultant responds within 24 working hours.

Where to start

• A client sends you a questionnaire: start with scopes 1 and 2 and the main scope 3 categories, using the method requested, then broaden the assessment; an annual inventory is not always useful.
• You are targeting Flemish works contracts: align the inventory with the CO2 ladder's requirements from the start so it serves certification.
• You are a Walloon SME consuming a lot of energy: first carry out the energy audit with the Energy voucher, then base the carbon footprint assessment on its data, which cover much of scopes 1 and 2.

7Key takeaways

• No law requires an SME to assess its carbon footprint in Belgium, but clients, tenders and funders increasingly ask for it.
• The CSRD is narrowing: a 2026 financial-year exemption for part of the first wave, with full transposition still to be passed.
• In Flemish works tenders, CO2 certification reduces your comparison price by up to 10%, and the rule extends to contracts of at least €1 million in 2027.
• An SME assessment generally costs €10,000 to €15,000 excluding VAT, depending on the number of days.
• Carbon consultancy funding has largely been suspended or abolished in 2026; mainly Walloon vouchers remain, focused on energy.

The right time to assess your carbon footprint is when a client, a tender or a funder requests it, ideally a little earlier. To put your figures in context, our article on what a carbon footprint assessment measures is a good starting point.

Further resources

Frequently asked questions

1Is a carbon footprint assessment mandatory in Belgium?

No. No federal or regional law requires companies to produce an organisational carbon footprint inventory; only installations subject to the European carbon market report their direct emissions annually. Companies subject to the CSRD publish their emissions in their sustainability report, and large companies must carry out an energy audit (or, in Flanders above 0.1 PJ, an energy plan) every 4 years, but an SME has no legal carbon footprint assessment requirement.

2How much does a carbon footprint assessment cost in Belgium?

There is no public price schedule. The price depends on the number of working days, with a daily rate of around €800 to €1,200 excluding VAT for a senior consultant. For a single-site SME, a complete scopes 1, 2 and 3 inventory with an action plan generally costs €10,000 to €15,000 excluding VAT, and most assessments cost between €10,000 and €30,000 excluding VAT.

3How long does a carbon footprint assessment take?

Allow 6 to 10 weeks when data have been gathered beforehand, and 3 to 4 months when collection needs to be organised in depth. Data collection takes 60 to 70% of the assignment's time.

4What funding is available for a carbon footprint assessment in Belgium in 2026?

It has become scarce. In Wallonia, no business voucher is dedicated to carbon footprint assessments: the Energy voucher funds 75% of an energy audit, and Growth vouchers could cover an assessment under environmental management, subject to confirmation with Wallonie Entreprendre. In Flanders, the kmo-portefeuille no longer funds sustainability consultancy and its closure has been announced. In Brussels, consultancy grants have been suspended since 12 August 2026 for the rest of the year.

5What is the CO2 ladder in Flemish public tenders?

It is CO2 certification with 5 levels, the CO2-prestatieladder, used by the Flemish Mobility and Public Works policy area. When comparing bids, a certified company's price is reduced by 2 to 10% according to its level, while it is paid the bid price. It applies to investment contracts of at least €3 million in 2026, then to investment and maintenance contracts of at least €1 million from 2027.

6Is my company subject to the CSRD?

Before the European reform, the Act of 2 December 2024 covered companies exceeding 2 of these 3 criteria: 250 employees, €50 million in turnover, €25 million in total assets. The Omnibus Directive now limits the CSRD to companies with more than 1,000 employees and €450 million in turnover; Belgium has already exempted first-wave public-interest entities not exceeding one of these thresholds for the 2026 financial year and is preparing full transposition, expected before 19 March 2027.

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