CSRD Reporting for Transport SMEs: Fleet & Scope 3

Small and growing transport businesses (SMEs) run on tight margins and are now asked to evidence climate and workforce performance for CSRD reporting. Compliance can feel built for large fleets with sustainability teams, yet your clients expect the same rigour from the subcontractors who deliver their Scope 3 data.

This guide helps you move from basic fuel tracking to an implementing-stage system. You will learn how to convert invoices into energy and emissions metrics, package data for customers, implement route optimisation, and show how you safeguard drivers and warehouse staff.

With a clear structure and a steady cadence, CSRD reporting becomes a practical tool to win and retain transport contracts.

What CSRD Expects From Transport SMEs

Transport operators act as direct emitters under ESRS E1 and as value-chain partners for clients’ Scope 3 disclosures. CSRD and VSME ask you to provide:

• Annual fuel and energy data in MWh and litres.
• Scope 1 emissions in tCO₂e for owned or leased vehicles.
• Scope 2 emissions where you charge electric vans or forklifts.
• Evidence that you manage driver welfare, working time, and safety.

Meeting these asks requires clear fleet boundaries, reliable energy conversion, and repeatable documentation you can share with customers during audits.

Step 1 – Map Your Fleet and Responsibilities

List every vehicle, trailer, refrigerated unit, and on-site tank you control. Categorise each asset as Scope 1 (owned or leased) or Scope 3 (third-party hauliers and subcontractors). Record vehicle class, fuel type, annual kilometres, and where data is stored.

Clarify subcontractor expectations in contracts. Request monthly fuel statements or telematics exports so you can reference their data when clients ask for indirect emissions evidence.

Step 2 – Collect and Convert Fuel Data

Fuel cards, supplier invoices, and telematics downloads provide the raw data. Align them with a single reporting year, check for gaps, and convert to energy figures using EU coefficients accepted by ESRS E1. For a detailed workflow, use our guide to reporting fuel receipts and invoices.

Document the factors you use and store the reference (e.g. EU Commission energy statistics). That evidence satisfies VSME B3 for total energy use and provides an audit trail when procurement teams request proof.

Step 3 – Deliver Emissions Metrics Clients Can Trust

Apply recognised emission factors to generate annual Scope 1 totals and intensity metrics. Keep the calculation logic in a simple spreadsheet or fleet system that you can export to customers.

• Use EU or member-state emission factors (e.g. 2.68 kg CO₂e per litre of diesel).
• Multiply electricity use by the grid factor for the country where charging takes place.
• Create one-page summaries showing energy, emissions, and intensity per tonne-kilometre or per delivery lane.

Share a packaged data set with clients each quarter: headline metrics, methodology statement, and the contact person responsible. This satisfies VSME requirements and positions your business as a reliable Scope 3 partner—see the broader context in CSRD and Scope 3 emissions for SMEs.

Step 4 – Optimise Routes and Energy Use

Route optimisation proves that you act on the data. Focus on achievable actions and link them to measurable outcomes:

• Deploy telematics reports to monitor idling time, harsh acceleration, and empty kilometres.
• Plan multi-drop routes with load consolidation to raise vehicle fill rates by at least 5% per quarter.
• Introduce ECO-driving training with refresher sessions every six months; track before-and-after fuel performance.
• Trial alternative fuels or EVs on predictable urban routes and compare energy cost per kilometre.
• Add a quarterly review with operations, finance, and safety leads to sign off progress and next actions.

Summarise the programme in your CSRD narrative: target, activity, result, and next step. That language maps cleanly to ESRS E1 and ESRS E5 disclosures.

Step 5 – Protect Drivers and Logistics Teams

CSRD expects SMEs to report how they manage their own workforce. Build a short control framework that covers drivers, warehouse teams, and subcontracted labour, drawing on practices from CSRD workforce reporting for HR managers.

• Track hours, rest periods, and night shifts to demonstrate compliance with EU driving time rules.
• Provide safety briefings for loading, manual handling, and refrigeration unit maintenance; record attendance and incident follow-up.
• Offer wellbeing support such as occupational health checks or confidential helplines.
• Audit labour agencies to confirm fair pay, legal contracts, and access to grievance channels.

Summarise workforce outcomes with metrics such as incident frequency, driver turnover, and training completion. These feed ESRS S1 requirements and reassure clients that logistics work is carried out safely.

Implementation Checklist

Frequently Asked Questions

How often should we refresh our emissions data?

Monthly fuel consolidation with a quarterly validation keeps data current and gives you time to correct anomalies before client audits. Annual reporting alone makes it harder to spot errors when CSRD assurance teams review your files.

What do clients need for their Scope 3 reporting?

Most shippers request a short methodology, annual totals, and proof that you control data quality. Provide the conversion factors you use, a named contact, and any reduction initiatives so they can integrate the figures into their value-chain reports.

Do subcontracted drivers count in our Scope 1 emissions?

No. Owner-drivers and subcontractors sit in Scope 3, but CSRD still expects you to gather their fuel data where possible and to explain how you oversee safety, working conditions, and ethical standards. For more on contractor disclosure rules, see whether freelancers count in workforce reporting.

How do we evidence workforce safety in CSRD disclosures?

Keep records of training, incident investigations, rest-break monitoring, and engagement surveys. Short dashboards with leading and lagging indicators satisfy ESRS S1 and show clients that logistics work is managed responsibly.

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024)
• ESRS: European Sustainability Reporting Standards that specify CSRD disclosures
• Scope 1 emissions: Direct emissions from owned or controlled sources such as company vehicles
• Scope 2 emissions: Indirect emissions from purchased electricity or heat
• Scope 3 emissions: Indirect emissions from your value chain, including subcontracted transport
• GHG intensity: Emissions per operational unit, for example tCO₂e per tonne-kilometre
• Telematics: Digital tools that track vehicle performance, routes, and driver behaviour

Conclusion

By mapping fleet boundaries, converting fuel data, and sharing clear evidence, transport SMEs can meet CSRD and VSME requirements while becoming trusted Scope 3 partners for clients. Combine emissions monitoring with route optimisation and workforce safeguards, and your business can offer the transparency procurement teams now expect.

With structured data, regular reviews, and consistent communication, sustainability reporting becomes an advantage rather than an obstacle for your fleet.