Scope 3 Emissions from Employee Commuting: The Complete Guide for Companies
With the CSRD, greenhouse gas emissions reporting becomes mandatory for many companies – including the often underestimated emissions from employee commuting. This article explains the legal requirements, calculation methods, and practical implementation strategies.
1. The Legal Framework: CSRD, ESRS, and Supply Chain Laws
The European Union's Corporate Sustainability Reporting Directive (CSRD) is revolutionizing sustainability reporting. It replaces the previous Non-Financial Reporting Directive (NFRD) and significantly expands both the scope of companies required to report and the extent of disclosures needed.
Key Legal Frameworks
- CSRD – Directive (EU) 2022/2464
- ESRS E1 Climate Change – Delegated Regulation (EU) 2023/2772
- GHG Protocol – Corporate Value Chain (Scope 3) Standard
The specific reporting requirements are defined by the European Sustainability Reporting Standards (ESRS). For greenhouse gas emissions, ESRS E1 "Climate Change" is particularly relevant, which aligns with the internationally recognized GHG Protocol.
Under ESRS E1-6, companies must disclose their gross Scope 3 emissions, broken down by significant categories. Offsetting emissions with carbon credits is explicitly prohibited – these must be reported separately under ESRS E1-7.
2. What is Scope 3 Category 7?
The GHG Protocol distinguishes three "scopes" of greenhouse gas emissions:
Scope 1
Direct emissions from company-owned facilities and vehicles
Scope 2
Indirect emissions from purchased energy (electricity, heat)
Scope 3
All other indirect emissions in the value chain – 15 categories
Category 7 "Employee Commuting" covers all emissions from employee travel between home and workplace in vehicles not owned or operated by the company.
What Belongs to Category 7?
- ✓ Private car, motorcycle, e-bike trips
- ✓ Public transportation (bus, train, subway)
- ✓ Carpooling
- ✓ Walking and cycling (effectively 0 emissions)
- ✓ Optional: Home office emissions (energy consumption)
- ✗ Company cars → Scope 1 or Scope 3 Category 6
- ✗ Business travel → Scope 3 Category 6
According to the National Household Travel Survey, the average American commutes about 13 miles to work – one way. At 220 working days and an average car emission of 400g CO₂e/mile, that's over 2.3 tons of CO₂e per employee per year – just for commuting. (See our article on how employees can reduce their individual emissions.)
3. Who Must Report? Timeline and Thresholds
The CSRD introduces reporting obligations in phases:
| Fiscal Year | First Report | Affected Companies |
|---|---|---|
| 2024 | 2025 | Large PIEs (previously under NFRD), >500 employees |
| 2025 | 2026 | Large companies meeting 2 of 3 criteria: • >250 employees • >€50M revenue • >€25M total assets |
| 2026 | 2027 | Listed SMEs (opt-out possible until 2028) |
| 2028 | 2029 | Non-EU companies with >€150M EU revenue |
Important: Double Materiality
The CSRD requires a "Double Materiality" analysis: companies must assess whether climate topics are material – both regarding their environmental impact and financial risks to the company. For most companies, ESRS E1 (Climate) will be classified as material, requiring full Scope 3 reporting.
4. Calculation Methods According to GHG Protocol
The GHG Protocol Scope 3 Standard (Chapter 7) defines several calculation methods:
1. Distance-Based Method (Recommended)
Capture actual commute distances and transportation modes per employee.
CO₂ = Σ (Distance × Emission Factor per Mode × Working Days)Data sources: Employee surveys, commuter apps, HR systems
2. Fuel-Based Method
Calculate based on fuel consumed by employees for commuting.
CO₂ = Fuel Consumption (gallons/liters) × Emission Factor per Fuel TypeLess accurate as other transport modes are not captured
3. Average-Data Method
Use national average values for commuting behavior.
CO₂ = Number of Employees × Avg. National Commute Emissions per PersonSimplest method but least accurate – recommended only as starting point
Emission Factors (US/UK Typical Values)
| Transportation Mode | g CO₂/passenger-km |
|---|---|
| Car (gasoline, average) | 170–210 |
| Car (diesel) | 150–180 |
| Electric car (avg. grid mix) | 50–120 |
| Public transit (bus) | 80–100 |
| Public transit (rail, intercity) | 30–50 |
| Public transit (subway/metro) | 50–70 |
| E-bike | 5–10 |
| Bicycle / Walking | 0 |
5. Data Collection Challenges
The biggest hurdle for Scope 3 Category 7 is data collection – it touches on employee privacy:
Common Problems
- • Privacy concerns (home address = sensitive data)
- • Low survey participation (often <30%)
- • One-time surveys quickly become outdated
- • Hybrid work changes commute patterns
- • Lack of data auditability
CSRD Requirements
- • Clear audit trail from source to report
- • Initially "limited assurance"
- • Moving toward "reasonable assurance"
- • Consistent methodology over years
- • Documentation of data sources
Many companies rely on one-time employee surveys. The problem: participation rates are often low, data becomes outdated quickly (especially since hybrid work increased), and continuous data collection is nearly impossible.
This is where the idea behind commute.coach comes in: Instead of forcing employees to share data, create intrinsic motivation – through tools that provide personal value to them.
6. Practical Recommendations
1. Conduct Materiality Assessment
Determine if your company falls under CSRD and whether ESRS E1 is material for you. Document the analysis – it's part of the report.
2. Establish Baseline with Average Data
Start with the average-data method for an initial estimate. Use census data on average commute distances and modal split in your region.
3. Develop Data Strategy
Plan the transition to distance-based methodology. Options: annual surveys, integration with HR systems, incentives for voluntary participation.
4. Review Mobility Benefits
Transit passes, bike-share programs, EV charging infrastructure – such measures not only reduce emissions but also facilitate data collection (e.g., through usage data).
5. Account for Remote Work
The GHG Protocol recommends optionally including emissions from remote work (energy consumption) in Category 7. Document your decision and methodology.
6. Leverage Intrinsic Motivation
Tools like commute.coach can help employees optimize their own commute decisions – by time, cost, CO₂, or fitness. As a side effect, voluntarily shared data emerges.
7. Conclusion and Outlook
The reporting requirement for Scope 3 Category 7 is not just a compliance exercise – it offers the opportunity to reduce mobility costs, increase employee satisfaction, and make a real contribution to climate protection.
The biggest challenge remains data collection. Companies that start building systems and processes now will have an advantage in 2025/2026.
Working on Scope 3 reporting and looking for solutions to capture employee commuting data?
At Octily, we've been working with HR and HR-IT teams of large organizations since 2016. Reach out – we understand the challenges.