Scope 3 Emissions Estimator
Belgium

Scope 3 emissions reporting in Belgium: CSRD transposition via Belgian federal and regional legislation; Belgian federal Climate Plan; Flemish Energy and Climate Plan (VEKP); Walloon Air-Climate-Energy Plan (PACE)

Belgium's CSRD transposition brings sustainability reporting obligations to entities across its three regions (Flanders, Wallonia, Brussels-Capital) and two main language communities, creating a compliance environment where federal, regional, and EU requirements intersect. Belgium hosts the headquarters of major multinationals (AB InBev, UCB, Solvay, Umicore) alongside thousands of SMEs that serve as suppliers to larger EU entities, meaning Belgian companies appear both as CSRD reporters and as data providers in their customers' Scope 3 calculations. The Port of Antwerp-Bruges (Europe's second-largest port by cargo volume, handling approximately 290 million tonnes in 2023) and the extensive Belgian motorway network make logistics and transport emissions a defining feature of the Belgian economy. For Belgian entities subject to CSRD, ESRS E1-6 requires Scope 3 disclosure that captures these supply chain and logistics emissions.

Regulatory context: Financial Services and Markets Authority (FSMA); Institut des Réviseurs d'Entreprises / Instituut van de Bedrijfsrevisoren (IRE/IBR) for assurance; Federal Public Service Health, Food Chain Safety and Environment for climate policy

The FSMA supervises financial reporting for Belgian listed entities and will enforce CSRD sustainability reporting requirements. The IRE/IBR (Institute of Registered Auditors) oversees the statutory audit profession and will supervise sustainability assurance under CSRD. Belgium's federated structure means that environmental policy (including climate and emissions) is split between federal and regional competences. The Flemish Energy and Climate Agency (VEKA) administers Flemish environmental regulations, including the Flemish ETS allocation for installations not covered by the EU ETS. The Walloon Air and Climate Agency (AwAC) performs the equivalent function in Wallonia. The Brussels Environment agency (Bruxelles Environnement / Leefmilieu Brussel) handles environmental regulation in the Brussels-Capital region. This fragmented structure means that Belgian entities with operations in multiple regions may encounter different environmental reporting requirements at the regional level, though CSRD reporting follows a single federal transposition. Belgium's national GHG inventory is compiled by the National Climate Commission, drawing on regional data.

Practical guidance for Belgium

Belgian entities estimating Scope 3 should use a combination of Belgian-specific and European emission factor databases. Belgium does not maintain a single national emission factor database equivalent to DEFRA or ADEME's Base Carbone, but several sources provide Belgian-specific data. The Belgian Federal Public Service for the Environment publishes the national GHG inventory, which provides sectoral emission intensities. For electricity, Belgium's grid emission factor is approximately 0.135 kg CO2e per kWh (2023 location-based), reflecting a generation mix that includes nuclear (approximately 40%), natural gas (approximately 25%), wind (approximately 15%), and solar (approximately 8%). Belgium's nuclear power stations (Doel and Tihange) are scheduled for partial lifetime extension under the government's 2023 decision, which affects the grid emission factor trajectory. For transport, Belgium's high motorway density and position as a transit country for north-south European freight create significant road freight emissions. The Belgian Federal Public Service Mobility and Transport publishes transport statistics including vehicle-km by road type. For the Port of Antwerp-Bruges, port-specific emission data is available from the port authority. For Category 1, Belgian entities in the chemicals sector (Antwerp hosts Europe's largest integrated chemical cluster) can use sector-specific emission factors from Essenscia (the Belgian chemical industry federation) or the European Chemical Industry Council (Cefic).

Audit expectations

Belgian réviseurs d'entreprises / bedrijfsrevisoren performing CSRD assurance apply ISA-based standards adapted by the IRE/IBR alongside ISAE 3000 (Revised). Belgium has a relatively concentrated audit market, with the Big Four and mid-tier networks performing the majority of listed entity audits. The FSMA expects consistency between the financial statements and the sustainability statement, particularly where emission-related provisions, carbon credit accounting, or EU ETS allowance valuations appear in the financial statements. For Scope 3, Belgian assurance providers focus on the completeness of category screening (all 15 categories assessed), the appropriateness of emission factors for the Belgian context, and the consistency of organisational boundaries between financial and sustainability reporting. Belgian entities that are subsidiaries of larger EU groups must ensure their Scope 3 figures can be consolidated by the parent without double counting.

Belgium-specific considerations

Belgium's grid emission factor of approximately 0.135 kg CO2e per kWh sits between France's very low nuclear-driven factor and Germany's higher coal-influenced factor. The partial lifetime extension of Belgium's nuclear fleet (Doel 4 and Tihange 3 extended to 2035) provides grid stability but the long-term energy mix remains uncertain. Belgian entities should monitor RTE/Elia (the Belgian transmission system operator) publications for updated grid emission factors. Belgium's company car culture is distinctive: Belgium has one of the highest company car penetration rates in Europe, driven by tax-favourable salary sacrifice schemes. This inflates Category 7 (employee commuting) relative to countries where commuting is primarily by public transport or cycling. The 2023 Belgian federal budget included measures to accelerate the transition to zero-emission company cars (100% electric or hydrogen) by 2026, which will progressively reduce commuting emissions. The Antwerp chemical cluster (approximately 50 km of interconnected pipelines linking chemical plants) creates opportunities for supplier-specific emission data exchange. Belgian entities in this cluster should use direct data from neighbouring plants rather than generic emission factors. Belgian chocolate and food industry entities should use Belgian-specific agricultural input emission factors from the Flemish Institute for Agricultural and Fisheries Research (ILVO) rather than generic European averages.

Common inspection findings

The FSMA's 2024 review of sustainability disclosures by BEL 20 companies found that Scope 3 disclosure quality varied significantly, with some companies providing detailed category-level breakdowns and others reporting only total Scope 3 without methodology transparency.

Belgian assurance providers reported that entities with operations in multiple regions frequently used a single set of emission factors without adjusting for regional differences in energy mix or waste treatment methods.

The IRE/IBR noted that Belgian entities in the financial sector disclosed financed emissions (Category 15) using PCAF methodology but with data quality scores predominantly at Level 4 or 5, indicating limited progress in obtaining reported data from portfolio companies.

The Flemish VEKA found inconsistencies between energy audit data (required under the Energy Efficiency Directive) and emission figures in sustainability reports for the same Flemish installations, suggesting errors in one or both data sets.

Belgian entities in the food sector frequently omitted upstream agricultural emissions from their Scope 3 Category 1 calculations, despite agriculture being a major contributor to embodied carbon in food products.