How to Calculate Employee Commuting Emissions for CSRD

Introduction

Under the Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS E1), companies are expected to disclose greenhouse gas (GHG) emissions, including Scope 3 emissions from employee commuting.

For many SMEs, this can feel complex — but it doesn’t have to be. You don’t need GPS trackers or fuel receipts for every trip. A simple, transparent estimate based on staff commuting habits and distances is perfectly acceptable under both CSRD and VSME (Voluntary Sustainability Reporting Standard for SMEs) principles.

This guide explains step-by-step how to collect commuting data, apply emission factors, and document your assumptions in a way that’s proportionate, credible, and audit-ready.

If you’re still setting up your data collection system, see our overview on how to integrate CSRD data collection into existing workflows.

1. What Counts as “Employee Commuting” Under CSRD

Employee commuting covers all home-to-work travel that occurs regularly, regardless of transport type:

• Private car (petrol, diesel, hybrid, electric)
• Public transport (bus, tram, metro, train)
• Cycling or walking (usually counted as zero emissions)
• Company-provided transport (e.g. shuttle buses)

These emissions fall under Scope 3, Category 7 of the GHG Protocol, which CSRD and ESRS reference for consistency.

2. What Data You Need

You can collect commuting data in a simple employee survey or HR questionnaire. The minimum data you’ll need includes:

• Number of employees commuting regularly
• Average one-way distance (km)
• Days per week worked on-site
• Main transport mode(s)

Optional: Split by vehicle type (petrol, diesel, hybrid, EV) if known — this improves accuracy but isn’t mandatory.

Example data from a small company:

3. The Calculation Formula

A simple calculation formula for annual commuting emissions is:

Emissions (kg CO₂e) = Employees × Distance × 2 (return trip) × Days/week × Weeks/year × Emission factor

Assume 46 working weeks per year (allowing for holidays). Using the example data above:

Petrol car emissions: 12 × 18 × 2 × 3 × 46 × 0.180 = 107,136 kg CO₂e (≈107 tCO₂e)

Train emissions: 4 × 25 × 2 × 4 × 46 × 0.041 = 60,320 kg CO₂e (≈60 tCO₂e)

Total = 167 tCO₂e per year

Round results to one decimal place and document all assumptions clearly.

4. Finding Reliable Emission Factors

Use national or EU-recognised sources for emission factors, such as:

• EEA (European Environment Agency) – EU-27 transport emissions database
• ADEME (France) – Base Carbone for transport modes
• DEFRA (UK) – widely used international reference factors
• National energy agencies (e.g. Umweltbundesamt in Germany, ISPRA in Italy)

Be sure to note:

• Factor source and year
• Unit (e.g. kg CO₂e/km per passenger)
• Whether electricity or fuel mix reflects your country

If you don’t have national data, EU averages are acceptable — see our guide on using industry averages in CSRD reporting.

5. How to Document Your Assumptions

Transparency is crucial. Include a short disclosure in your sustainability statement such as:

“Employee commuting emissions were estimated using average travel distances from a 2025 employee survey and national emission factors (EEA 2024). The calculation covers 19 employees travelling 2–4 days per week. Active travel modes (walking, cycling) were excluded as zero emissions.”

This meets both CSRD and VSME Basic Module documentation standards.

6. Reducing and Reporting Improvements

Once you’ve calculated commuting emissions, you can identify ways to reduce them:

• Encourage hybrid or remote work policies.
• Promote carpooling or public transport incentives.
• Offer bike-to-work or EV charging programmes.
• Track participation year-on-year to show progress.

Report your improvement actions under ESRS E1-6 (Mitigation and Adaptation Plans) or VSME B7 (Energy and Emissions).

Frequently Asked Questions

Do I need to collect individual employee data?

No. Aggregated averages or survey data are fine. You don’t need to record individual names or trips — only patterns and averages.

Can I exclude remote workers?

Yes. If employees work primarily from home (e.g. <1 day/week on-site), you can exclude them from commuting emissions, but mention this in your disclosure.

How often should I update the data?

Once a year is sufficient. Many SMEs refresh commuting surveys every two years and apply the same data in between unless major changes occur.

What about business travel?

That’s separate — business trips count as Scope 3, Category 6, not commuting. See our guide on reporting fuel receipts and invoices for CSRD compliance for travel-related emissions.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
• Scope 3 – Indirect GHG emissions from value chain activities, including commuting.
• VSME Standard – Voluntary framework for SMEs to report sustainability data proportionately.
• Emission factor – The amount of CO₂e emitted per kilometre, unit of fuel, or passenger.
• Materiality – Relevance of an impact to a company’s operations or stakeholders.

Conclusion

Calculating employee commuting emissions doesn’t require complex systems or exact data — just logical estimates, clear documentation, and credible sources. Using surveys, average distances, and national emission factors will meet CSRD and VSME expectations and help you identify practical reduction actions.

To plan your data collection across the year, explore our annual CSRD reporting calendar for a month-by-month guide to gathering key metrics.

Use our emission estimator to quickly calculate your company’s employee commuting emissions based on your team size, travel distances, and transport modes:

This tool helps you get an accurate estimate using standard emission factors, saving you time on manual calculations.