CO2 (mobility) reporting requirement delayed to 1 July 2024


The CO2 (mobility) reporting requirement for employers with 100 employees or more will be postponed from 1 January 2024 to 1 July 2024. As of that date, employers will be required to keep and report data on employees' business travel and commutes between home and work. The concrete goal is a reduction of 1.5 megaton CO2 by 2030.

The Council of State has requested some clarifications to be included in the explanation regarding the environmental decision in relation to limiting carbon dioxide emissions from work-related personal mobility. As a result, the mandatory reporting date of 1 January 2024, has shifted to 1 July 2024. However, it is still allowed to choose to start reporting from 1 January 2024. The advice from the Council of State does not affect the decision itself.

CO2 reporting requirement

The 2019 climate agreement includes agreements on reducing CO2 emissions. One of the agreements is that by 2030, work-related (individual) mobility will emit 1.5 megaton of CO2 less. The government’s main goal is to encourage employers to make conscious choices on how (individual) mobility can be made more sustainable. For now, the government has only imposed an obligation to report data on business travels and commutes between home and work. Based on this reported data, it will be monitored whether the goal of 1.5 megaton CO2 reduction will be achieved. 

Data to be reported

As of 1 July 2024 you will be required to report certain data, in case you are an employer with 100 employees or more. This data includes all business trips and commutes between home and work by your employees in the Netherlands, although exceptions apply. In principle, the reporting obligation concerns travels for which you provide your employees financial compensation or for which you provide e.g. a car or a transport ticket. You need to report on (the annual totals of) the number of kilometres, the means of transport used and the type of fuel. In other words, you do not provide data on actual CO2 emissions. The corresponding emissions are automatically calculated. 

For 2024 you will only need to report over the second half of the calendar year. You should submit this data no later than 30 June of the following calendar year (thus, the first reporting should ultimately be done by 30 June 2025). The Rijksdienst voor Ondernemend Nederland will make a digital platform available for this purpose.

Further guidance

The State Secretary also explained that currently, when declaring business or commuting travels, employees often do not have to indicate how they travelled and what fuel they used. According to the State Secretary, this can be solved in the case of business mobility by adding this additional information to existing records (such as lease, business declarations and so on). There will be further guidance with more details on possible solutions.

For the additional information on commutes, it is not possible to connect to already existing administrations. Therefore, alternatives are being worked out. For example, it would be possible to request this data by means of a survey.

Purpose and evaluation of the measure

At present, there is no individual standard for employers, but only a collective ceiling to achieve the 1 megaton CO2 reduction. An individual standard may come into effect if the evaluation in the second half of 2025 shows that CO2 emissions have exceeded the emission ceiling or if no downward trend is visible. Whether this then applies only to business travels or also to commuting between work and home remains to be seen. Such a future standard could also take into account differences that might exist between sectors and areas.

What does this mean for you?

As an employer, the ministry wants you to become more sustainable. The liberty to choose how you will execute this is an essential part of this goal. Therefore, as an employer you can determine which measures best suit your organisation. 

One possibility could be to (partially) phase-out the fossil fuel vehicles within your organisation and to replace these with electric vehicles. Promoting hybrid (home) working or encouraging the use of bicycles could also lead to improved sustainability and could also save costs for your organisation. 

Finally, this new measure is expected to increase your administration burden.

Your PwC advisor is more than happy to discuss potential solutions to make your organisation more sustainable. Furthermore, please feel free to reach out to your PwC advisor to discuss how you may report the required data most efficiently in the future.

Contact us

Daniël Sternfeld

Daniël Sternfeld

Partner, PwC Netherlands

Tel: +31 (0)61 089 28 89

Maaike Damen

Maaike Damen

Director, PwC Netherlands

Tel: +31 (0)65 117 61 13

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