Measure the machine, not the invoice.

$5 billion a year. That is what SMEs in enterprise supply chains collectively spend producing carbon estimates no auditor will defend.

The estimates come from spend-based calculations. Take procurement spend, multiply by an industry-average emission factor, output a number that gets presented with the same false certainty as a real measurement. 62% of organisations reporting Scope 3 cite internal data quality as a major barrier. 79% say supplier data availability is the top challenge. In one documented case, two reputable methodologies produced figures 72% apart for the same organisation, same year.

The EU did not water CSRD down because Scope 3 stopped mattering. It watered it down — from roughly 50,000 companies to roughly 5,000 — because the infrastructure to actually fulfil the obligation was not there. The simplified ESRS is still being released through 2026. The voluntary standard for sub-1,000-employee suppliers is being finalised by July 2026. The Commission asked enterprises to use the delay to build out their data infrastructure.

That gap is the opportunity. When the regulations re-tighten — and they will — the bottleneck will once again be the measurement infrastructure capable of producing process-level, auditable numbers. torch0’s bet is to be that infrastructure, built and battle-tested by the time the next tightening lands.

In the meantime: a competitive advantage at procurement. About 10,000 enterprises are now in scope for Scope 3, each with around 150 material suppliers — half a million SMEs under procurement pressure to hand over credible carbon data. Each enterprise contract on the line is $100k to $1m in ARR. The supplier with a defensible receipt closes it. The supplier with an estimate doesn’t.

The fines and litigation are already landing. Shein, €1m from Italy’s AGCM in 2025 for unsubstantiated targets. Volkswagen, tens of billions for Dieselgate. Fiat Chrysler, $110m settlement. Compass Minerals, $12m for misleading environmental reports. KLM, ruled in 2024 to have made carbon-offsetting claims without verifiable evidence. TotalEnergies, found by the Paris Judicial Tribunal in October 2025 to have engaged in misleading environmental advertising. Apple, named in a 2025 class action over carbon-neutrality claims for the Apple Watch. The fine lands on the enterprise. The bad data came from upstream.

torch0 produces a verifiable carbon receipt the supplier hands alongside the product or service it ships. The receipt is signed and traceable to source. The methodology is published openly so an auditor at the buyer’s end can verify the calculation independently. Each receipt carries a confidence score on every input, so the user can see exactly where the number rests on directly-measured ground truth and where it leans on modelled defaults — transparency about the limits of the number itself, which is what auditors and procurement teams actually need.

We measure the machine doing the work, not the invoice. The time a process runs. The grid intensity at the location it runs in, at the moment it runs. The amortisation of the equipment involved. Numbers built from physical reality, not from spend multipliers.

We are not writing the standards. The standards already exist — CSRD, UK SRS, IFRS S2, ISO 14067, GHG Protocol, PACT, ISO 14064-3 — being released and consolidated through 2026. We are building the infrastructure that sits on top of them. The system that takes whatever framework regulators put out and makes it operationally trivial for a company to produce numbers that comply.

Watershed and Persefoni sell to the enterprise and push questionnaires down to suppliers. torch0 sells to the supplier. That is the empty seat.

Will and Yoel, co-founders, torch0