WPM: what the duty asks, and where the numbers come from
Since 1 July 2024, larger Dutch employers must report their employees' commuting and business travel kilometres per mode of transport every year: werkgebonden personenmobiliteit, or WPM. The business travel side usually sits in systems you already run. The commuting side usually does not. This page covers what the duty requires, the threshold change that is pending but not decided, and how an annual employee survey produces the commuting numbers.
What the duty requires
The duty applies to employers with 100 or more employees. The headcount is taken on 1 January of the reporting year, and an employee counts from 20 paid hours a month. In scope are both commuting (woon-werk) and business travel (zakelijk) kilometres, broken down per mode of transport, for the preceding calendar year.
The deadline is 30 June each year, for the year before, submitted through the reporting platform administered by RVO. The legal basis is the Besluit activiteiten leefomgeving, articles 18.11 and 18.15, in force since 1 July 2024.
Note what the duty asks for: data, per mode, per year. Not a plan document and not a target. That is also why the hard part in practice is the collection, not the interpretation. Staffing agencies and parts of the healthcare sector have their own annexes in the ministry's handbook; the rules above are the general case.
The 250 threshold: proposed, not decided
The government has proposed raising the threshold from 100 to 250 employees, with retroactive effect from 1 January 2026 in the draft text, which would make 2025 the last reporting year for employers below 250. As of August 2026 that draft decree sits with the Council of State (Raad van State) and has not been adopted. RVO's guidance still states 100 as the applicable threshold.
If your headcount is between 100 and 249, the honest reading is therefore: the rule in force is 100, the change is proposed but not adopted, and 2026 data can only be collected in 2026: an employer who waits for the decree cannot collect them afterwards. We will correct this page the week the decree is published either way.
What happens if the deadline passes
Enforcement in practice runs through administrative law, and it starts slowly. The May 2023 guideline sets a sequence: an administrative warning, three months before the authority checks again, one month to submit a view on the proposed order, and two months to correct the breach once the order is final. That is roughly six months from the first letter.
The penalty in the guideline is 1,500 euro per month, up to 4,500 euro for a single order. That is a small amount, and we would rather say so than inflate it. But 4,500 euro is a starting point rather than a ceiling: the same guideline says the authority escalates with a new and higher order when the first one does not produce the report.
The stronger reason to act is that a passed deadline does not discharge the duty in the Besluit. The report is still owed, and it still has to describe a year that has already ended. Recall gets weaker with distance, so the same survey gives a firmer answer in February than in December. That is our judgement and not a rule from the handbook, and it is why the method question matters: we ask about a typical working week rather than a specific date, and the methodology chapter states that choice and its limits instead of assuming them away.
Three accepted ways to collect the data
The ministry's data collection handbook (Handreiking gegevensverzameling werkgebonden personenmobiliteit) describes three accepted collection methods, and an annual employee survey is one of them. For commuting, a survey is often the practical choice, because commuting kilometres sit in nobody's system: they sit with the employees.
The handbook sets no minimum response rate. It notes that 100 percent is rarely achievable and not required, that the employer is responsible for the reported picture being representative, and that stored documentation serves as evidence if the environment agency (omgevingsdienst) checks. The real requirement is therefore a representativeness case you can document: response rate, method, and what was left out.
What we deliver: the commuting part of WPM
Our report covers the commuting part of WPM, never the whole duty. An anonymous employee survey becomes a commuting baseline under GHG Protocol category 7, and the report carries a WPM data annex built for the form: commuting kilometres per mode of transport, car kilometres split per fuel, and lease kilometres separated out, ready to read into your own WPM report.
Business travel is not included. Those kilometres live in your own travel expense and lease systems, and stapling them to a survey would make both numbers worse. The methodology chapter states the split explicitly, and the report documents response rate and method the way the handbook expects your records to.
Two deviations we document rather than hide
First: the handbook suggests collecting PC6 postcodes to calculate distance. We never collect postcodes. Our surveys store nothing that could identify a respondent, and a full postcode combined with a department can point to one person. We ask for distance directly instead. That choice costs some precision, and it stands as a documented method choice in the methodology chapter, not as a silent difference.
Second: the handbook's mode table has rows for mopeds and scooters, including speed pedelecs, and two rows for the motorcycle. Our per-mode day table carries none of them, so days on those vehicles are a documented coverage gap in the methodology note. We would rather name a gap than pretend a table is complete.
See the proof before you decide: the example report shows the WPM data annex on real report pages, including the fuel split and the lease separation.
Sources and status
| Claim | Source | Last checked |
|---|---|---|
| Duty from 100 employees, headcount on 1 January, 20 paid hours rule, commuting and business travel per mode | Besluit activiteiten leefomgeving articles 18.11 and 18.15 (Staatsblad 2023, 472) | 18 Aug 2026 |
| Deadline 30 June for the preceding calendar year; reporting administered by RVO | RVO, WPM guidance | 18 Aug 2026 |
| Threshold change to 250: retroactive to 1 January 2026 in the draft text, with the Council of State, not adopted; RVO still states 100 | Draft amending decree WGK028577 (Council of State advice requested 19 May 2026); RVO | 18 Aug 2026 |
| Annual employee survey is one of three accepted collection methods; no minimum response rate; employer responsible for representativeness; documentation as evidence at inspection | Handreiking gegevensverzameling werkgebonden personenmobiliteit, Ministry of Infrastructure and Water Management, December 2025 (chapter 6) | 11 Aug 2026 |
| Enforcement runs through administrative law along a sequence of set periods (3 months to re-check, 1 month for a view, 2 months to correct). The dwangsom in the guideline is 1,500 euro per month up to 4,500 euro for a single order, and the authority escalates with a new and higher order if the first does not produce the report | IPLO, handhaving Besluit werkgebonden personenmobiliteit (leidraad handhavingsacties en termijnen, May 2023) | 19 Aug 2026 |