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ESG alert: CO2 registration obligation for large employers
1 March 2023

Large employers (>100 employees) will be required to report data on work-related mobility as part of the Climate Agreement in the Netherlands. The objective of the Climate Agreement is to reduce at least 1 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 registration 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 by mid-2025 at a collective level does not (appear to) be sufficient, the government will consider imposing an individual standard for large employers’ CO2 emissions from 1 January 2026.

The registration obligation explained
The entry into force of the registration obligation has been postponed from 1 January 2023 to 1 July 2023. The registration obligation applies to commuting and business travel, although a few exceptions apply. Air travel, for example, is not covered by the registration obligation.

The starting point is that for commuting and business travel, for which a reimbursement or a means of transport/card is provided, large employers report annually how many kilometers were travelled. They also report by which means of transport and what fuel was used by the employees. Based on that data, the Netherlands Enterprise Agency (Rijksdienst voor Ondernemend Nederland) will calculate CO2 emissions via a digital calculation tool.

It is therefore important for large employers to set up their administration timely before 1 July 2023 to include the data to be reported. Further guidelines are expected to follow for the set-up of the administration. By 30 June 2024, data for the period 1 July 2023 – 31 December 2023 must be reported.

It is estimated that about 8,000 employers (roughly 60%) in the Netherlands will be bound by the registration obligation. The registration obligation also applies to large employers with headquarters abroad and branches in the Netherlands with >100 employees.

No specific sustainability measures will be imposed until mid-2025. 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 mid-2025 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 Donny Buisman.

ESG alert: CO2 registration obligation for large employers