CO2 reporting on work-related mobility per 1 July 2024

26/05/23

Employers are required to annually provide data about the employees’ business travel and commuting (work-related mobility). This data should provide an insight into CO2 emissions, with a concrete reduction target of 1.5 megatons of CO2 in 2030. For more background on this reporting regulation, we refer to our previous article.

Meanwhile, a handout has been published on the website of the Netherlands Enterprise Agency (in Dutch ‘Rijksdienst voor Ondernemend Nederland’). This handout gives clarity on what data should be collected and reported, and how this should be done. We expect that your current administration is not fully in line with the new CO2 reporting obligation. As data must be collected from 1 July 2024 (this date has been postponed from 1 January 2024), you only have a few months left to make the adjustments. The handout on the website also provides several practical methods on how to collect the data.

This article was last updated on 26 October 2023.

Due to the new CO2 reporting obligation, it is important to have insight into the total number of work-related mobility, broken down into business travel and commuter travel. Business travel should be further subdivided into three categories; 1. business travel with a company car (lease and/or own fleet), 2. business travel with mobility services and 3. business travel via expenses.

The breakdown of business travel and commuter travel will be aligned with the Dutch payroll tax rules as much as possible. Commuter travel includes all employee travel between the place of residence and the place where the employee “usually” works. Business travel includes all other forms of work-related mobility.

The annual total travelled kilometres of the business and commuting travel must be split into the following groups of transportation and fuel types:

Car, petrol
Car, diesel
Car, hybrid
Car, 100% electric
Car, other fuel
Motorcycle, petrol
Motorcycle, electric
Moped/scooter, petrol
Moped/scooter, electric (incl. speed-pedelec)
(e-)bicycle and walking
Public transport

Practical solutions

The handout gives some practical solutions if your current administration does not allow you to collect all required data.

Business travel with company car (lease and/or own fleet)

If business travel with public transport is paid via expenses, you can fill in the total amount in euros for travel with public transport. This amount will be automatically converted to kilometres on the digital form.

In case your employees have a company (lease or own) cars) car, motorcycle, moped, (e-) bicycle, you may be able to collect the necessary data via a trip registration system.

Should you, or the lease company, only have the total number of annual kilometres driven without the possibility to break down into business and commuting travel, there are alternatives.

In that case, you can calculate the business travel by taking the total annual kilometres and deduct the commuting kilometres, as well as deduct a fixed average (flat rate) for private kilometres. A flat rate of 8,900 kilometres per vehicle per year applies to private use of the car or motorcycle, and a flat rate of seven percent private use per vehicle per year applies to private use by moped, bicycle or scooter.

If the number of (business) travel for moped, bicycle or scooter is being recorded but the number of travelled kilometres isn’t, calculations can be made with a given average distance per trip. For example, the average distance travelled per business trip by bicycle has been set at 3.6 kilometres per (single) trip.

Commuter travel

If your organisation uses a trip registration system which provides the commuting kilometres of your employees including the means of transport for the commuting kilometres, then you can use this data. In all other cases, an annual survey is recommended. With this survey, you ask all employees to specify how they travelled to work in the previous week and what their travel distance was. Based on the answers, you can convert this information into a total number of annual kilometres, which you can use for the commuting travel reporting obligation.

What does this mean for your organisation?

Your current administration is probably not yet fully aligned with this CO2 reporting obligation. You have until 1 July 2024 at the latest to adjust your administration accordingly. The first deadline for completing the digital form at the Netherlands Enterprise Agency is June 30, 2025. The data you enter will be immediately forwarded to the (regional) environment service, which monitors compliance with the reporting obligation and checks whether your data is correct. You must keep the underlying administration for a possible audit.

This CO2 reporting obligation provides the legal basis, as required by the General Data Protection Regulation (GDPR), which allows you to process employee data. As an employer, you don’t report the employee data to external parties.

An evaluation based on the data obtained through the reporting obligation is scheduled for 2026. If the evaluation shows that the CO2 emission was not kept within the ceiling, legislation will incorporate a maximum CO2 emission per travelled kilometre. Each employee will then be forced to adhere to the emission ceiling.

Having to adjust your administration to this CO2 reporting obligation is a great opportunity to take a closer look at your current mobility policy. Does this policy still meet the wishes of your employees? Is your company policy considered as a 'green employment condition' that achieves your goals in terms of sustainability ESG and employee health? Perhaps optimisations and changes are possible which allows your company to meet the (sustainable) goals.