Simple gives European companies, ESG consultants, and ERP partners EPD-first, activity-based Scope 3 infrastructure — ESRS E1-aligned, EU ETS MRV-aware, and CBAM-ready.
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EU ETS allowance price: ~€65/tonne (2024)
EU ETS2 (buildings and road transport fuels): from 2027/2028
CBAM certificates: aligned with EU ETS price from January 2026
For a company with 10,000 tCO2e Scope 3, a spend-based estimate carries ±5,000 tCO2e of unaccounted exposure. At €65/tCO2e in EU ETS, that is ±€325,000 in potential carbon cost. ESRS E1 requires companies to disclose methodology quality — spend-based data must be justified. EPD-first, activity-based calculation delivers <10% uncertainty and meets CSRD assurance expectations.
Most European companies still rely on spend-based Scope 3 estimates — EEIO proxies with ±50% uncertainty. ESRS E1 explicitly requires companies to disclose what percentage of Scope 3 is based on primary data versus spend-based proxies, and to justify lower-quality data. Activity-based calculation from invoices, EPD-first, is what CSRD limited assurance demands.
| Wave / Framework | Who | Key obligation |
|---|---|---|
| CSRD Wave 1 | Large public-interest entities (500+ employees, EU-listed) | ESRS E1 Scope 1, 2 & 3 — FY2024 data, filed 2025. Scope 3 may be omitted for <750 employees until FY2026 |
| CSRD Wave 2 | All large EU companies (size thresholds: 250+ employees, >€50M revenue or >€25M assets) | Full ESRS E1 under limited assurance — FY2025, filed 2026. Reasonable assurance by 2028 |
| CSRD Wave 3 | Listed SMEs | ESRS E1 with opt-out until 2028 — from FY2026 |
| CSRD Wave 4 | Non-EU groups with more than EUR 150 million EU revenue | Full ESRS E1 Scope 1–3 — from FY2028 |
| EU ETS + CBAM | ETS operators (power, steel, cement, maritime, aviation) and EU importers of CBAM-covered goods | ETS: annual MRV and allowance surrender. CBAM: embedded-emissions certificates required from January 2026 |
Built on globally recognised standards, ensuring every calculation is defensible, transparent, and ready for audit. Underpinned by industry-leading datasets including GHG Protocol and ecoinvent — ensuring accuracy and trust in every calculation.




ESRS E1 explicitly requires companies to disclose the percentage of Scope 3 emissions based on primary data (EPDs, PCFs, or activity-based calculation) versus secondary data (spend-based proxies) — and to justify the use of lower-quality data. Simple's EPD-first hierarchy means your methodology quality disclosure is built in, not assembled after the fact.
EPDs and supplier PCFs come first — where suppliers provide verified product-level data, Simple ingests it and ties it directly to the invoice line. For CBAM-covered goods (steel, cement, fertilisers, aluminium), supplier PCFs replace default embedded-emissions values and reduce CBAM certificate costs.
Where no EPD exists, Simple applies activity-based calculation using ecoinvent and recognised European LCA databases, with geography- and technology-specific factors. For EU ETS facilities, invoice-level activity data is mapped to ETS source categories — generating MRV-compatible data exports alongside ESRS E1 Scope 3 figures.
Every factor is versioned for period-consistent CSRD re-calculation. As factor databases update, Simple's re-mapping automatically improves historical and future calculations — supporting the shift from limited to reasonable assurance.
Spend-based estimates are never silently applied — any lower-precision proxy is flagged explicitly in the output with the reason noted, satisfying ESRS E1's methodology quality disclosure requirement.
Large EU companies must disclose full ESRS E1 Scope 3 under assurance — limited from Wave 2 filings in 2026, reasonable by 2028. Simple builds the EPD-first, activity-based infrastructure that makes every ESRS E1 disclosure defensible and auditor-ready.
Deliver client ESRS E1 reports without rebuilding the data infrastructure each engagement. EPD-first, GHG Protocol-compliant output — methodology quality documented for every Scope 3 category, auditor-ready.
Embed ESRS-aligned carbon calculation into SAP, NetSuite, or Oracle workflows. Your clients get CSRD-compliant Scope 3 data as a native output — EU ETS MRV and CBAM embedded-emissions included.
ESRS E1 requires companies to disclose the percentage of Scope 3 emissions based on primary data versus spend-based proxies — and to justify the use of lower-quality data. Simple builds this methodology quality documentation automatically for every category, every line item, every CSRD filing.
From raw invoices & quotations to carbon intelligence — report the past, see the now, plan the future.
Invoices, BOMs, quotations, energy bills — past purchases for compliance reporting, open offers for forward planning.
Each line item is classified and matched to the most specific emission factor available — manufacturer PCF, EPD, or recognised background database. Geography-specific, version-logged, auditable.
Compliance reports from invoices. Indicative carbon exposure from quotations. Supplier benchmarks to act on — not just numbers to file.
Compliance reporting from past documents. Carbon exposure forecasting from quotations. Both, from the same platform.
Full Scope 1, 2, and 3 — plus forward-looking carbon exposure from supplier quotes. Automated vendor consolidation keeps your supplier data clean.
Enable your SME borrowers to deliver emissions data automatically — at no meaningful burden to them. Better portfolio data for financed emissions and SLL covenants.
Your large customers need your emissions data to complete their own reporting. Simple gives you the answer — no Excel, no specialist knowledge, no heavy process.
Deliver Scope 3 data collection across your client portfolio faster — with multi-entity management and white-label options. Simple scales with your practice.
Carbon decisions happen at tender stage. Simple processes quotations and BOMs to put indicative CO₂e — including ETS cost exposure — into every bid comparison before you commit.
Embed carbon intelligence directly into your invoicing or accounting product via API. Your users get GHG Protocol-compliant CO₂e data on every document they process — automatically, with no added workflow.
Resources
Curated research on CSRD, PCAF, and supply chain emissions — updated regularly.
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