CO₂e Attestation — Compliance
Compliance & Legal Limits Overview
Full legal, regulatory and compliance framework governing the CO₂e Attestation, including legal boundaries, CSRD / ESRS positioning, GDPR conformity, liability allocation, permitted and prohibited uses, data governance and institutional constraints.
1.Compliance Scope & Legal Boundaries
This section defines the exact legal perimeter of Certif-Scope. It clarifies what the system is allowed to do, what it cannot do, and under which regulatory constraints it operates. These boundaries prevent misinterpretation and ensure that the output remains an indicative, non-binding CO₂e estimate based solely on spend-based logic.
Certif-Scope does not replace mandatory regulatory reporting (CSRD, ESRS, EU Taxonomy), does not constitute an audit, and does not validate supplier-specific emissions. The tool provides a standardized indicative emission intensity for institutional screening where physical activity data is not available.
Defined Legal Scope
- • Provides indicative CO₂e estimations using spend-based factors only.
- • Complies with GHG Protocol Scope 3 Category 1–16 (spend-based approach).
- • Compatible with ISO 14064-1 and ISO 14083 methodological principles.
- • Delivers non-binding indicators suitable for procurement and banking workflows.
- • Fully independent from supplier-specific primary data.
Legal Framework Positioning
Financial spend → Category assignment → Reference factor → CO₂e estimate. The result does not express real operational emissions but an indicative intensity derived from economic activity benchmarks.
Explicit Exclusions (Legal and Methodological)
The following elements are outside the legal and methodological perimeter and must never be inferred or interpreted as included:
- • No CSRD-compliant reporting (not a sustainability statement).
- • No ESRS E1, E2, E3 primary-data verification.
- • No supplier-level or product-level carbon footprint.
- • No Scope 1 direct emissions or Scope 2 market-based accounting.
- • No LCA (ISO 14040/44) or cradle-to-grave lifecycle modelling.
- • No audit, no assurance engagement, no verification opinion.
- • No physical activity data (kWh, km, tCO₂e from operations).
Alignment With International Regulations
Certif-Scope aligns with internationally recognized frameworks for indicative emissions estimation but does not substitute legally binding disclosure standards.
- • GHG Protocol — spend-based Scope 3 method.
- • ISO 14064-1 — accounting relevance, consistency and transparency.
- • ISO 14083 — transport emissions calculation boundaries.
- • EEIO modelling — macroeconomic carbon intensity allocation.
- • EU Taxonomy — compatibility for indicative risk assessments only.
These alignments provide methodological legitimacy while maintaining clear separation from mandatory reporting obligations under CSRD and ESRS.
Liability & Responsibility Boundaries
Certif-Scope provides indicative results only. Responsibility for accuracy of financial inputs lies exclusively with the user or institution submitting the data. The system does not validate invoices, supplier data, operational metrics or regulatory filings.
- • Output is non-binding and must not be used as audited emissions.
- • No guarantee of equivalence to CSRD or ESRS deliverables.
- • No legal liability for downstream interpretation or use.
- • Institutions are responsible for contextual assessment and risk evaluation.
2.Regulatory Alignment & Non-Equivalence Statement
This section clarifies how Certif-Scope aligns with recognized international environmental accounting frameworks while explicitly stating that the output does not constitute a substitute for mandatory regulatory reporting. Regulatory alignment ensures methodological consistency without implying legal compliance equivalence.
Standards Used as Reference (Non-Substitutive)
Certif-Scope relies on established methodological references for structure and consistency. These frameworks inform the spend-based calculation logic but are not fully implemented, replaced, or reproduced.
- • GHG Protocol — Scope 3 spend-based methodology.
- • ISO 14064-1 principles of relevance, consistency and transparency.
- • ISO 14083 transport emission boundary logic (non-mandatory integration).
- • EEIO macroeconomic emission factor modelling as foundational reference.
- • ADEME / DEFRA published emission intensities as accessible baselines.
Non-Equivalence With Mandatory Regulatory Frameworks
The indicative output produced by Certif-Scope must not be confused with or used as a replacement for any mandatory reporting deliverables. The system does not generate compliant disclosures under:
- • CSRD European Sustainability Reporting Standards (ESRS).
- • EU Taxonomy eligibility/alignments assessments.
- • GHG Protocol full corporate inventory (primary data required).
- • National emission reporting schemes or carbon taxes.
- • ISO 14064 third-party verified greenhouse gas statements.
The Certif-Scope output is an indicative, non-binding estimate based on financial expenditure. It cannot be used in regulatory filings without independent review and methodological adaptation by accredited professionals.
Purpose of Regulatory Alignment
Alignment supports institutional confidence by ensuring that the methodology follows internationally recognized principles without misrepresenting itself as a full regulatory reporting solution.
- • Ensures methodological transparency.
- • Promotes compatibility with screening and risk-assessment workflows.
- • Facilitates institutional audits through fixed versioning and deterministic results.
- • Avoids regulatory ambiguity by clearly distinguishing non-binding indicators.
Legal Interpretation Restrictions
Certif-Scope outputs must not be interpreted as audited environmental disclosures, validated greenhouse gas inventories, or financial-regulatory evidence. All legal responsibility for regulatory usage belongs to the institution using the tool.
- • No regulatory assurance is provided.
- • No claim of equivalence to CSRD or ESRS reporting structures.
- • No suitability for compliance submissions without expert validation.
- • No inference of operational emissions or supplier accuracy.
3.Legal Boundary of Interpretation
This section establishes the explicit legal interpretation limits associated with Certif-Scope outputs. These boundaries ensure that institutions understand what the attestation can and cannot legally represent. It prevents misclassification of the indicative CO₂e values as verified environmental indicators or regulatory disclosures.
What the Output Legally Represents
The attestation represents a non-binding, indicative estimate of CO₂e generated using spend-based conversion logic. It is strictly an analytical screening tool built for institutional workflows where precise physical or supplier-specific data is unavailable.
- • A financial-to-emission conversion based on category-level factors.
- • A reproducible output grounded in deterministic computation.
- • A static report embedding the emission factor version used.
- • An indicative estimate suitable for preliminary ESG screening.
What the Output Does NOT Represent
Certif-Scope explicitly avoids misinterpretation by excluding any legal or regulatory equivalence. The indicative CO₂e result must not be construed as evidence of:
- • Verified GHG inventory compliant with ISO 14064-1.
- • ESRS/CSRD environmental disclosure or mandatory reporting.
- • EU Taxonomy alignment or eligibility validation.
- • Supplier-specific accuracy or upstream traceability.
- • Physical emission measurement or operational monitoring.
- • A certified carbon footprint suitable for regulatory filings.
These exclusions reflect regulatory integrity requirements and prevent the indicative estimate from being mistakenly treated as an audited environmental statement.
Institutional Duty of Interpretation
Institutions using Certif-Scope remain fully responsible for the interpretation, contextualization and downstream use of the indicative values. The tool does not assume liability for compliance decisions taken based on its output.
- • Users must contextualize indicative outputs using internal methodologies.
- • Professional judgment is required for regulatory applications.
- • Certif-Scope provides no regulatory assurances or compliance guarantees.
- • Institutions must validate suitability for use in their jurisdiction.
Legal Non-Reliance Clause
Certif-Scope outputs are inherently non-binding. They must not be relied upon for regulatory compliance, litigation, contractual commitments or public environmental declarations. Use of the output for such purposes requires independent verification by certified professionals or auditors.
- • Not admissible as audited evidence.
- • Not suitable for investor regulatory disclosures.
- • Not acceptable as standalone ESG documentation.
- • Not recognized as legal proof of environmental performance.
4.Regulatory Non-Equivalence & Misuse Prevention
This section formally establishes that Certif-Scope outputs cannot, under any circumstance, be considered equivalent to regulatory disclosures, mandatory environmental reports or certified calculations. It also defines the restrictions preventing incorrect or misleading usage by institutions, suppliers or auditors.
Non-Equivalence With Regulatory Frameworks
Certif-Scope provides indicative estimates only. They must not be used as legally required documentation under any of the following frameworks:
- • CSRD (Corporate Sustainability Reporting Directive)
- • ESRS (European Sustainability Reporting Standards)
- • EU Taxonomy mandatory disclosures
- • ISO 14064-1 certified inventories
- • ISO 14083 logistics accounting
- • Supplier-specific carbon declarations
Misuse Prevention Rules
To prevent incorrect interpretation or misleading communication, the following restrictions apply unconditionally:
- • Outputs cannot be labelled as “audited” or “certified”.
- • Results cannot be expressed as Scope 1 or Scope 2 emissions.
- • No equivalence can be claimed with regulatory filings.
- • No use in green claims or marketing claims.
- • No merging with supplier-specific primary data.
Responsibility Clarification
Certif-Scope does not validate, audit or correct user-provided financial data. Responsibility for input accuracy remains fully with the user or institution.
- • No liability for inaccurate, incomplete or misleading inputs.
- • No responsibility for third-party interpretations.
- • No obligation to align with future regulatory updates.
5.Data Boundaries & Prohibited Interpretations
This section clarifies what the Certif-Scope output represents, and more importantly, what it does not represent. These boundaries prevent incorrect interpretation of indicative CO₂e values and ensure that institutions handle the results within appropriate legal and methodological limits.
What the Data Represents
- • Indicative CO₂e values derived exclusively from financial expenditure.
- • Category-level estimates based on economic carbon intensity averages.
- • Spend-based modelling aligned with GHG Protocol guidance.
- • A reproducible, version-controlled calculation snapshot.
- • A non-binding indicator supporting high-level institutional screening.
What the Data Does NOT Represent
The output must not be treated as a precise measurement, verification or physical emission report. It specifically does not represent:
- • Actual operational emissions of a company.
- • Supplier-specific primary emissions data.
- • Activity-based or metered measurements (kWh, km, fuel, heat, etc.).
- • Lifecycle or cradle-to-gate assessments.
- • Official data accepted by CSRD/ESRS or ISO-certified audits.
- • Evidence for regulatory filings or environmental claims.
Prohibited Interpretations
To maintain legal integrity and avoid institutional risk, the following interpretations are explicitly prohibited:
- • Treating the value as certified, audited, or validated emissions.
- • Using the indicative value as proof of supplier compliance.
- • Inferring environmental performance or efficiency trends.
- • Assuming equivalence with mandatory regulatory disclosures.
- • Using the number to justify marketing or ESG claims.
- • Interpreting the estimate as a Scope 1 or Scope 2 measurement.
Why These Boundaries Are Mandatory
Spend-based models use economic averages and cannot capture physical emissions with accuracy. Regulatory frameworks require measurable, verifiable, activity-based data. Without strict boundaries, the risk of institutional misinterpretation would compromise compliance and expose organisations to enforcement actions.
Anti-Misrepresentation Warning
Any attempt to present Certif-Scope’s indicative values as verified emissions, regulatory-compliant disclosures, or certified environmental performance constitutes a misrepresentation. Institutions remain legally responsible for any incorrect interpretation or communication of results.
6.Legal Non-Equivalence With Regulatory Disclosures
This section defines the legal boundaries that prevent Certif-Scope’s indicative values from being treated as official, regulatory-grade emissions reporting. These limits protect institutions from non-compliance and ensure that results are interpreted only within authorised analytical contexts.
Key Distinctions From Mandatory Reporting
Certif-Scope results must not be confused with mandatory emission disclosures required by European or international regulatory frameworks. Critical distinctions include:
- • Output is indicative and derived from expenditure, not physical measurements.
- • No activity-based data (kWh, fuel burn, heat/cold, distances) is collected.
- • Results are not validated by accredited auditors or verification bodies.
- • Output is not compliant with CSRD, ESRS E1, ISO 14064-1 or GHG Protocol inventory rules.
Comparison With Regulatory Frameworks
The following frameworks require granular, traceable, physical emissions data that the spend-based model cannot produce:
- • EU CSRD — mandatory corporate sustainability disclosure.
- • ESRS E1 — requires activity-based Scope 1, 2 and 3 inventories.
- • ISO 14064-1 — demands quantifiable, verifiable emissions boundaries.
- • EU Taxonomy — technical screening criteria requiring measurable performance indicators.
- • EBA/Banking guidelines — risk assessments must rely on validated environmental data.
Prohibited Uses Under Law
Certif-Scope’s outputs may not be used in any circumstance where regulatory accuracy, certified verification or statutory reporting is required:
- • Not valid for CSRD/ESRS mandatory submissions.
- • Not valid for ISO 14064-1 certification workflows.
- • Not valid for EU Taxonomy green-asset classification.
- • Not valid for environmental claims or marketing communications.
- • Not valid for carbon offset or carbon market mechanisms.
Institutional Responsibility Disclaimer
Institutions remain fully responsible for verifying whether the indicative output is appropriate for their internal use cases. Certif-Scope is not a recognised reporting mechanism under any regulatory framework and does not replace mandatory compliance obligations.
Why Non-Equivalence Matters
Without explicit separation between indicative values and regulatory disclosures, institutions risk misreporting, non-compliance and legal exposure. These limits ensure correct usage and prevent regulatory enforcement risks.
7.Prohibited Claims & Misuse Prevention
This section establishes strict prohibitions to prevent misinterpretation, regulatory misalignment or unlawful communication of results. Certif-Scope values are indicative only and cannot be used for advertising, compliance filings, public ESG declarations or comparative performance benchmarking.
Forbidden Use in External Communications
Under EU consumer law and environmental marketing regulations, the values generated by Certif-Scope must not be presented in any context implying verified or certified emissions performance:
- • No ESG marketing claims or promotional statements.
- • No “carbon neutral”, “low carbon”, or similar claims.
- • No public comparison against competitors or industry averages.
- • No use in product environmental labeling or eco-design compliance.
- • No publication as audited or regulator-approved data.
Prohibited Regulatory Misuse
Certif-Scope output must not be submitted, referenced or implied in any legal, contractual or regulatory document requiring validated emissions accounting:
- • Not acceptable for CSRD or ESRS filings.
- • Not acceptable for ISO 14064-1 verification.
- • Not acceptable for EU Taxonomy classification.
- • Not acceptable for EU Green Claims Directive compliance.
- • Not acceptable for national regulatory emissions registries.
Legal Risk Prevention
Institutions must ensure that indicative values are not reinterpreted as factual emissions. Misrepresentation can trigger legal liabilities under:
- • EU Unfair Commercial Practices Directive (for misleading claims).
- • National consumer protection and advertising laws.
- • Banking and procurement due diligence misreporting risks.
- • Contractual liability for inaccurate ESG disclosures.
Why These Prohibitions Are Required
Without explicit restrictions, indicative values could be misrepresented as regulatory-grade data, exposing institutions to compliance breaches, sanctions or reputational risk. These prohibitions ensure legal clarity, protect users, and preserve the methodological integrity of spend-based estimations.
8.Disclaimers, Liability & Legal Safeguards
This section defines the legal disclaimers and liability limitations applicable to Certif-Scope outputs. It ensures that users, auditors and institutions fully understand the indicative nature of the estimations and the boundaries of responsibility, preventing misinterpretation or regulatory misuse.
Nature of the Output (Non-Binding Indicator)
- • Outputs are indicative estimates, not verified emissions data.
- • Values are generated using spend-based economic intensities.
- • Results are not equivalent to measured CO₂ emissions.
- • No guarantee of accuracy against real operational activity.
- • No suitability for regulatory filings or environmental claims.
User Responsibility
Users retain full responsibility for the accuracy, completeness and relevance of submitted expenditure data. Certif-Scope does not verify financial records or validate underlying accounting documentation.
- • Users must ensure correct categorisation of spending.
- • Users must validate financial accuracy before submission.
- • Certif-Scope cannot detect misreported or missing values.
- • Responsibility for interpretation remains exclusively with the user.
Platform Liability Limitations
Certif-Scope is provided “as is”, without warranties, and with strict limitations on liability. The platform is not responsible for downstream consequences or financial decisions based on indicative values.
- • No liability for institutional decisions made using indicators.
- • No liability for ESG scoring or risk modelling based on outputs.
- • No liability for commercial disputes involving indicative values.
- • No liability for regulatory sanctions resulting from misinterpretation.
Legal Safeguards Applied to All Outputs
- • Every output embeds dataset version and methodological constraints.
- • Outputs include explicit disclaimers on their indicative nature.
- • Outputs are non-comparable, non-audited and non-certified.
- • The attestation cannot be interpreted as regulatory evidence.
These safeguards prevent regulatory misunderstanding, protect users from misinterpretation risks and maintain compliance integrity across all use cases.
9.Auditability & Independent Verification Boundaries
This section establishes the exact conditions under which Certif-Scope outputs may be independently verified by third parties. It defines verification scope, boundaries, reproducibility requirements, and limitations. It ensures accuracy of interpretation while preventing improper use as regulatory audit evidence.
Scope of Independent Verification
Third-party reviewers may verify the internal consistency of an attestation using only the embedded metadata and the emission factor version referenced in the output. This verification is limited to structural and mathematical reproducibility:
- • Correct application of category-specific emission factors.
- • Correct multiplication of spending by emission factors.
- • Correct aggregation of category-level results into totals.
- • Correct dataset version alignment with embedded metadata.
Boundaries of Verification
Verification is strictly limited to mathematical consistency. Reviewers cannot:
- • Validate the accuracy of user-submitted financial inputs.
- • Confirm whether spending amounts are exhaustive or correct.
- • Assess supplier-specific carbon intensity or real emissions.
- • Use the attestations as a proxy for CSRD/ESRS reporting.
Requirements for Successful Reproduction
For an attestation to be reproducible independently, the following conditions must be met without exception:
- • Input values must be identical to those submitted originally.
- • Category mapping must follow the published definitions.
- • The same emission factor dataset version must be used.
- • No post-processing, scaling or reinterpretation is allowed.
Explicit Verification Limits
Verification cannot extend beyond the deterministic scope of the model. Certif-Scope does not store financial inputs, therefore independent reviewers cannot re-access or revalidate user data. No metadata exists beyond what is embedded in the final attestation file.
Forbidden Interpretations of the Verification Process
- • Treating indicative values as audited or certified emissions.
- • Using the attestation as regulatory reporting evidence.
- • Assuming data quality validation of user inputs.
- • Comparing outputs across years as if operationally consistent.
- • Using results as a substitute for primary LCA or Scope 1/2/3 reporting.
10.Liability Framework & Legal Responsibilities
This section defines the legal responsibility boundaries associated with Certif-Scope outputs and clarifies the obligations of all involved parties. The attestation is an indicative CO₂e result derived from user-provided expenditure data and must not be interpreted as audited emissions, environmental certification, or a substitute for regulatory reporting. Liability is strictly limited to deterministic computation using the inputs supplied by the user.
Legal Nature of the Attestation
The CO₂e attestation generated by Certif-Scope is not an environmental certificate, not a compliance report, and not an audited measure. It is a deterministic calculation based solely on:
- • user-submitted expenditure data,
- • published category definitions,
- • a fixed emission-factor dataset version.
Responsibility Allocation Between Parties
Responsibilities are clearly separated to avoid misinterpretation:
- • The user is responsible for the accuracy and completeness of financial inputs.
- • Certif-Scope is responsible for deterministic processing of validated values.
- • Third-party reviewers are responsible for independent verification of the computation.
- • No party may extend the attestation’s meaning beyond its defined scope.
Explicit Liability Exclusions
Certif-Scope does not assume liability for interpretations or uses outside the strictly defined methodology. Explicit exclusions include:
- • No guarantee regarding accuracy of user data.
- • No validation of supplier-specific carbon performance.
- • No compliance guarantee for CSRD, ESRS, EU Taxonomy or ISO audits.
- • No suitability for regulatory fines mitigation or legal defence.
- • No verification of operational emissions (Scope 1/2/3 activity-based).
Prohibited Legal Interpretations
The CO₂e attestation must not be interpreted as:
- • proof of real emissions,
- • environmental certification or compliance approval,
- • confirmation of supplier ESG performance,
- • a guarantee of completeness or data accuracy,
- • a substitute for mandatory disclosures under EU regulation.
Institutional Safeguards
To avoid misuse by institutions or third parties, the attestation embeds a legal disclaimer and version metadata. It explicitly states that results are indicative, non-binding, and not validated against physical operations or real-world emissions.