Dutch employers will need to report employee's work-related CO2 emissions from July
Published on 16th May 2024
A time-consuming search for data at the time of the reporting deadline can, however, be avoided
Large employers in the Netherlands will be required to report all mileage travelled by their employees from 1 July. The reporting requirement applies to employers with 100 or more employees on 1 January of the relevant reporting year.
The new obligation applies if an employer provides financial compensation for commuting or business travel; or provides the opportunity to use a bicycle, moped, motor vehicle or ticket for public transport or other mobility facilities; or both.
What data should be provided?
Each year, an employer must provide the total number of kilometres travelled for all employees, broken down by mode of transport and fuel type. There are some exceptions. For example, air travel and employees that work less than 20 hours per month are excluded from the reporting requirement.
There is no need to track, calculate or enter the CO2 emissions. Based on the annual kilometres per vehicle and fuel type, the digital form automatically calculates the total CO2 emissions.
The data must be submitted to the Netherlands Enterprise Agency (de Rijksdienst voor Ondernemend Nederland or RVO) by using a digital form in Dutch.
What are the reporting period and deadlines?
For the period from the 1 July to the 31 December 2024, the deadline is 30 June 2025. The next deadline is 30 June 2026, covering the whole of 2025, and so on.
What happens after the reporting?
Once the data have been completed, the employer receives a report on its CO2 emissions, which: gives an insight into the sustainability of the employees' mobility and provides general tips and advice on how to improve sustainability.
The environmental service (omgevingsdienst) checks whether the employer complies with the reporting requirement and whether the data are correct.
An administrative sanction can be imposed in the form of an order subject to a penalty (last onder dwangsom) to enforce the submission of the data.
In 2026, the Ministry of Infrastructure and Water Management will review whether the combined CO2 emissions of all employers in the Netherlands have remained below the CO2 emissions ceiling.
Osborne Clarke comment
Employers should modify their existing commuting, travel and declaration system so that the data can be tracked correctly and reported efficiently for the next reporting period. A survey can be carried out on the annual kilometres travelled by (e-)bicycle, or on foot.
The employment team at Osborne Clarke can help clients with further advise on whether, what and how, as an employer, they are obliged to report to the RVO.
