Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
Disclaimer: 2026 Omnibus changes to CSRD and ESRS
In December 2025, the European Parliament approved the Omnibus I package, introducing changes to CSRD scope, timelines and related reporting requirements.
As a result, parts of this article may no longer fully reflect the latest regulatory position. We are currently reviewing and updating our CSRD and ESRS content to align with the new rules.
Key changes include:
We continue to monitor regulatory developments closely and will update this article as further guidance and implementation details are confirmed.
There are many reasons why companies must disclose greenhouse gas (GHG) emissions across their value chain.
Beyond the Corporate Sustainability Reporting Directive (CSRD) and its European Sustainability Reporting Standards (ESRS), disclosures are also required or expected under the Science Based Targets initiative (SBTi), EcoVadis, the upcoming VSME standard, ISSB, and GRI.
On top of that, robust Scope 1–3 calculations can help companies access better financing terms from banks and investors.
One of the biggest questions sustainability managers face is how to calculate those emissions in practice: should you use an activity-based method, a spend-based method, or both?
This article explains the two approaches, their strengths and weaknesses, and how to decide which is right for your business. It also shows how a hybrid approach can support Scope 1–3 reporting that is both compliant and audit-ready.
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The activity-based method, as defined by the GHG Protocol, uses measured activity data (e.g. liters of fuel consumed, tonnes of waste generated, or kWh of electricity purchased) multiplied by an appropriate emission factor.
According to commonly used emission factor datasets such as DEFRA (UK), diesel combustion releases 2.68 kg CO₂e per liter. So, if your company buys 10,000 liters of diesel, you multiply this by the diesel emission factor (2.68 kg CO₂e per liter, per DEFRA) to get the associated emissions.
The spend-based method, also covered in the GHG Protocol’s guidance, calculates emissions by multiplying the financial value of a purchase by a sector-average emission factor from an economic input–output database.
If your business spends €100,000 on IT equipment, you multiply this by an emission factor for “manufacturing of computer and electronics” to estimate emissions.
Please note, the emission factor database allows one search and beyond that you need to make a free account.

Certain GHG Protocol categories lend themselves better to one approach than the other. For instance, Scope 1 fuel use and Scope 2 purchased electricity should always be activity-based, while purchased goods and services or capital goods often start as spend-based until supplier data matures.
The right choice depends on your business’ data maturity, supplier engagement, and reporting requirements:
Other decision factors include:
Yes. Both the GHG Protocol and ESRS E1 acknowledge that hybrid approaches are not only allowed but encouraged.
Example of a hybrid approach:
This ensures comprehensive coverage while focusing accuracy where it matters most. Businesses should also set a recalculation policy, updating spend-based estimates with activity data as supplier engagement improves.
CSRD requires companies to report in line with ESRS E1, which sets expectations for data quality, traceability, and auditability. Auditors will scrutinize whether emission factors are documented, data sources are consistent, and assumptions are transparent.

For finance teams preparing sustainability data, take a look at how to prepare accounting for sustainability reporting.
The choice between activity-based vs. spend-based carbon calculation isn’t binary. Most businesses will use both, applying spend-based for early coverage and activity-based for accuracy and audit-readiness. Under CSRD, the expectation is clear: move toward supplier-specific, traceable data wherever possible.
By starting with spend-based and building toward activity-based, sustainability managers can meet today’s reporting obligations while laying the foundation for credible, future-proof disclosures.

Most companies end up using a mix of spend-based and activity-based data, but managing that in spreadsheets is messy and tough to defend in an audit. Coolset applies TÜV-certified methodology to handle both in one place, so you stay CSRD-compliant without the stress.
Talk to Coolset about your carbon calculation needs today.
Let’s take a look at some of the most commonly asked questions when it comes to carbon calculation methods.
Activity-based is more accurate because it reflects supplier-specific data, while spend-based relies on averages.
Yes, but ESRS E1 expects companies to improve data quality over time. Spend-based is acceptable as a starting point but should be supplemented or replaced with activity data.
Yes, and this is encouraged by the GHG Protocol. Companies should set a clear recalculation policy to ensure comparability when methods change.
Auditors prefer activity-based because it provides transparency and traceability. Spend-based is harder to justify unless supported by robust emission factor documentation.
Both approaches require emission factors. Spend-based relies on input–output databases, while activity-based uses sector- or process-specific datasets such as DEFRA or ecoinvent.
A practical guide to scoping, sourcing and calculating scope data
