CO2 registration obligation for large employers
As part of the Climate Agreement, large employers (at least 100 employees) are obliged to report data on work-related mobility as of 1 July 2024. The objective of the Climate Agreement is to reduce at least 1.5 megaton of CO2 emissions by 2030 through a collective cap. Work-related mobility now accounts for about 20% of total CO2 emissions.
With the CO2 reporting obligation, the government wants to monitor CO2 emission reductions and encourage large employers to make their work-related mobility more sustainable as they see fit. If progress in 2026 at a collective level is not sufficient, the government will consider imposing an individual standard for large employer’s CO2 emissions from 1 January 2027.
Reporting obligation as of 1 July 2024
The reporting obligation, which had previously been postponed from 1 January 2023 to 1 July 2023 and then to 1 January 2024, has now actually come into effect on 1 July 2024. The reporting obligation applies to commuting and business travel, although a few exceptions apply. Air travel, for example, is not covered by the reporting obligation.
The starting point is that large employers report annually the number of kilometres travelled, the means of transport used and the fuel used, for commuting and business travel for which they provide a reimbursement or a means of transport/card. The data must be entered digitally on the website of the Netherlands Enterprise Agency (Rijksdienst voor Ondernemend Nederland or RVO). Based on that data, the RVO will calculate CO2 emissions via a digital calculation tool.
It is therefore important for large employers that the administration is adjusted in such a way that the data to be reported is included. To assist employers with the reporting obligation, the responsible Ministry of Infrastructure and Water Management has drawn up a Guide to Data Collection for Work-related Mobility of Persons (guide). The guide provides tips on how employers can collect data and indicates for each form of mobility which information must be provided digitally. In any case, this concerns:
- the total number of kilometers travelled by employees in a calendar year for business and commuting; and
- the annual total of kilometers divided into type of transport and fuel type.
The guide states the emission value per kilometer used for each means of transport and type of fuel.
Data for the year 2024 must be reported by 30 June 2025.
It is estimated that about 8,000 employers (that is about 60% of all employers) in the Netherlands will be bound by the reporting obligation. The reporting obligation also applies to large employers with headquarters abroad and branches in the Netherlands with at least 100 employees.
Continuation
No specific sustainability measures will be imposed until 2026. This means that, for the time being, large employers are free to decide which measures they take. However, if the collective threshold for CO2 emissions is still exceeded in 2026 or the downward trend is insufficient, an individual standard for CO2 emissions may follow. We therefore advise large employers to start working on this ESG topic and determine which sustainability measures are appropriate to be implemented within their organization. This can be done, for instance, by providing electric lease vehicles, encouraging hybrid or home working, and introducing mobility policies that make the use of other means of transport (such as train, bus or bike) more attractive.
Want to know more? Feel free to contact Niels van Boekel or Puck van Genuchten.
