Commuting is entering the reporting rulebook
Employee commuting is Scope 3 category 7 under the GHG Protocol, carried into ESRS E1. That framework is the same across the EU and EEA. The national mandates are not. Here is what applies where, with sources and dates.
One framework across the EU and EEA
Under CSRD, sustainability reporting follows the ESRS standards, and employee commuting sits in ESRS E1 as Scope 3 category 7. After the Omnibus simplification, the reporting duty applies to companies with more than 1,000 employees and more than 450 million euro in turnover, with the new thresholds applying from financial year 2027. Smaller companies meet the requirements indirectly, as suppliers asked for numbers. The method is the same in every EU and EEA country, so a commuting baseline measured once is comparable across borders.
Where national mandates apply
| Country | The rule |
|---|---|
| Netherlands | Employers with 100 or more employees must report commuting and business travel kilometres per mode of transport annually (WPM). In force since 1 July 2024. The headcount is taken on 1 January of the reporting year, an employee counts from 20 paid hours a month, and the deadline is 30 June for the preceding calendar year. A pending amendment would raise the threshold to 250 employees with retroactive effect from 1 January 2026, making 2025 the last reporting year below 250. As of August 2026 the draft is with the Council of State and not yet adopted, and the official guidance still states the 100 threshold. |
| Spain | Work sites with more than 200 employees (or more than 100 per shift) must have a negotiated workplace mobility plan (PMST) in place by 5 December 2026, communicate it within three months of the plan's approval to the authority designated by the region so it enters the national mobility data space (EDIM), and follow it up with a report every two years. Work sites with more than 1,000 employees in municipalities and metropolitan areas above 500,000 inhabitants carry an added requirement: the plan must also include measures that reduce peak-hour travel and promote shared and collaborative mobility. Failing to have the plan is a minor infringement carrying a fine of 101 to 2,000 euro, but the law conditions this on the failure harming the mobility system. The national rule is subsidiary: where a region or municipality has its own rules on workplace travel plans, those apply, and two regions have had such rules for years. Catalonia requires a company travel plan (PDE) for work sites with more than 500 workers, more than 250 per shift, or more than 200 in air quality exceedance zones, filed with the regional mobility authority. The Basque Country requires a transport plan where more than 100 people work per shift. |
| Belgium | Employers with more than 100 employees must run the federal commuting survey (diagnostic fédéral) every three years. The duty has been in force since 2005. The 2024 round closed on 28 February 2025 and the next one falls in 2027. The survey is done per work site with at least 30 employees. Separately, the mobility budget has been decided to become mandatory for employers offering company cars, at the earliest from 2027 and starting with employers of 50 or more employees. That legal text is not yet adopted. |
| Italy | Work sites with more than 100 employees must appoint a mobility manager and adopt a commuting plan (PSCL) by 31 December each year. The plan has to be sent to the municipality within 15 days of adoption. The duty applies where the site sits in a regional capital, a metropolitan city, a provincial capital or a municipality of more than 50,000 inhabitants, and where several group companies share a site their employees are counted together. The duty recurs every year, and it currently carries no sanctions. |
| France | Employers with at least 50 employees on the same site must draw up an employer mobility plan (plan de mobilité employeur). The plan has to contain an analysis of employee home to work travel and be sent to the competent local mobility authority (AOM). The duty sits in article L1214-8-2 of the transport code and has been in force since the 2019 mobility act (LOM). Commuting must also be tabled in the annual mandatory negotiations, and where no agreement is reached the employer draws up the plan alone. Private companies with more than 500 employees must in addition publish a greenhouse gas inventory (BEGES) every four years, with a fine of up to 50,000 euro. The forfait mobilités durables lets employers cover up to 600 euro per employee per year for sustainable commuting tax free, 900 euro combined when paired with public transport subscription coverage. |
| Sweden | No reporting mandate for private employers, and the energy audit act for large companies explicitly leaves employee travel to and from work out of scope. Commuter climate analysis is an established purchase (the CERO network reports 100+ member organisations), and municipalities such as Jönköping and Stockholm tie reduced parking requirements for new developments (a requirement on the developer) to an approved green travel plan. That requirement is carried by land allocation and development agreements, and Boverket itself describes the legal basis as unsettled. |
| Norway | No national duty on employers to measure or report commuting. Several large municipalities do require a mobility plan in planning and building cases under section 11-9 of the Planning and Building Act: Stavanger for every establishment or change of use with more than 50 employees and for developments above 1,000 square metres, Bergen for developments above 5,000 square metres or generating more than 50 workplaces, and Trondheim for all plan proposals. Those requirements bind the applicant in the individual case and trigger on establishment or change, not periodically. Public procurement must as a main rule weight climate and environment at a minimum of 30 percent, and the Eco-Lighthouse certification requires facilitating sustainable commuting. |
| EU cities | The TEN-T regulation requires member states to report urban mobility data, including modal split, for 431 European cities by 31 December 2027, and every four years after that. The Commission adopted an implementing regulation on 9 July 2026 setting out the indicators and how the data is submitted. |
What Lerka delivers, remotely
We turn an anonymous employee survey into an employer commuting report under GHG Protocol category 7 (distance-based method), ready for ESRS E1. Emission factors and travel data come from national sources in each country. Norwegian factors are never used in another country's report.
Pendlerscan is delivered remotely and priced in euro: 5,000 euro up to 200 employees, 12,000 euro for 201 to 1,000, from 20,000 euro above that, never more than 35,000 euro. Excl. VAT. Several sites are quoted per engagement.
Sources and status
| Claim | Source | Last checked |
|---|---|---|
| Scope 3 category 7 / ESRS E1 | GHG Protocol (Scope 3 Standard, category 7); ESRS E1 | 10 Aug 2026 |
| CSRD thresholds and first year | CSRD as amended by Omnibus (Directive (EU) 2026/470) | 10 Aug 2026 |
| Netherlands: WPM, headcount rule, 30 June deadline and threshold change | Besluit activiteiten leefomgeving articles 18.11 and 18.15 (Staatsblad 2023, 472); RVO; draft amending decree WGK028577 (Council of State advice requested 19 May 2026) | 18 Aug 2026 |
| Sweden: no national duty for private employers; the energy audit act excludes commuting | lag (2014:266) om energikartläggning i stora företag; Energimyndigheten guidance | 17 Aug 2026 |
| Sweden: legal basis for municipal mobility requirements is unsettled | Boverket, PBL kunskapsbanken (parking ratios and mobility measures) | 17 Aug 2026 |
| Spain: mobility plan deadline, EDIM notification, fines and subsidiary character | Ley 9/2025 de Movilidad Sostenible articles 26 and 106 to 107, deadline advanced by RDL 7/2026 | 17 Aug 2026 |
| Spain: regional duties in Catalonia and the Basque Country | Decret 132/2024 article 12 (ATM Barcelona); Ley 4/2019 de Sostenibilidad Energética de Euskadi articles 32 and 38 with Decreto 254/2020 | 17 Aug 2026 |
| Belgium: mobility budget (decided, not yet law) | federal decision of January 2026, phase-in from 2027 | 10 Aug 2026 |
| Belgium: federal commuting survey every three years above 100 employees | FPS Mobility and Transport, and the Central Economic Council (CCE-CRB), 2021 and 2024 editions | 17 Aug 2026 |
| Italy: mobility manager, annual PSCL deadline and filing with the municipality | DL 34/2020 article 229(4) (decreto rilancio), implemented by DM 179/2021, amended by DM of 16 September 2022, guidelines in decreto interdirettoriale 209/2021 | 17 Aug 2026 |
| France: employer mobility plan from 50 employees, with a commuting analysis, filed with the mobility authority | transport code article L1214-8-2 (law 2019-1428, LOM); service-public.gouv.fr F38002 | 17 Aug 2026 |
| France: commuting in the annual mandatory negotiations | labour code article L2242-17 point 8, introduced by LOM article 82, in force 1 January 2020 | 17 Aug 2026 |
| France: greenhouse gas inventory (BEGES) above 500 employees, fine up to 50,000 euro | environment code articles L229-25 and R229-47 | 17 Aug 2026 |
| France: forfait mobilités durables | French tax rules (FMD) | 10 Aug 2026 |
| Sweden: CERO and green travel plans | cero.nu; municipal parking guidelines (Jönköping, Stockholm) | 10 Aug 2026 |
| Norway: procurement weighting and Eco-Lighthouse | Norwegian Public Procurement Act section 5 b, in force 1 July 2026 (the rule applied from 1 January 2024 under procurement regulation section 7-9); Eco-Lighthouse common criteria | 19 Aug 2026 |
| Norway: municipal mobility plan requirements in planning and building cases | Planning and Building Act section 11-9; Stavanger KPA 2023 to 2040 section 1.13(3); Bergen KPA2018 section 16.2; Trondheim KPA 2022 to 2034 section 13.4 | 17 Aug 2026 |
| EU cities: TEN-T reporting | Regulation (EU) 2024/1679; Commission implementing regulation of 9 July 2026 on the collection of urban mobility data | 17 Aug 2026 |