How to Report Fuel Receipts and Invoices for CSRD Compliance
For small and medium-sized enterprises (SMEs) in transport and logistics, fuel consumption is the most critical data point in sustainability reporting. Whether you operate a fleet of delivery vans, trucks, or mixed vehicles, your fuel invoices and receipts are the foundation for calculating energy use and greenhouse gas (GHG) emissions under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME).
This guide shows how to organise, verify, and report fuel data in a way that meets CSRD and VSME expectations — without complicated tools or consultants.
Why Fuel Data Matters
The VSME Standard (Basic Module, B3) requires SMEs to disclose:
- Total energy consumption (MWh)
- Scope 1 GHG emissions (direct emissions from fuel use) - see our step-by-step guide to reporting Scope 1 and 2 emissions
- Scope 2 GHG emissions (if electricity is purchased, e.g. for EVs or offices)
- GHG intensity (emissions per turnover or per activity unit)
For transport SMEs, fuel receipts and invoices provide almost all the information needed for these metrics.
Reporting this data helps:
- Build transparency with clients subject to full CSRD reporting.
- Support ESG-friendly financing and leasing.
- Identify operational inefficiencies and cost savings. For a complete overview, see our CSRD guide for transport SMEs.
Step-by-Step: How to Report Fuel Receipts and Invoices
Step 1 – Collect All Fuel Records
Gather all available fuel data for the reporting year, including:
- Supplier invoices for bulk fuel deliveries (if you refuel on-site)
- Fuel card statements (Shell, BP, Total, etc.)
- Credit card receipts for ad-hoc refuelling
- Driver fuel logs, where available
Ensure each record includes:
- Date of purchase
- Supplier name
- Quantity (litres)
- Type of fuel (diesel, petrol, LPG, etc.)
- Total cost (optional, for internal analysis)
Tip: Most fuel card systems allow CSV or PDF exports by vehicle or driver.
Step 2 – Check for Duplicates and Gaps
To ensure data quality:
- Remove duplicate entries from card and invoice systems.
- Check for missing months or vehicles.
- Compare total litres with average mileage (rough check: if a van drives 40,000 km/year at 8L/100km → ~3,200 litres expected).
This step helps ensure completeness and verifiability, both core CSRD reporting principles.
Step 3 – Categorise Fuel by Type and Use
Group the data into clear categories for reporting:
| Category | Example | Scope |
|---|---|---|
| Diesel (road transport) | Trucks, vans | Scope 1 |
| Petrol | Cars, small vehicles | Scope 1 |
| LPG / Natural Gas | Specialist or refrigerated units | Scope 1 |
| Electricity | EV charging | Scope 2 |
This structure mirrors the VSME energy breakdown table (renewable vs non-renewable).
Step 4 – Convert Litres to Energy (MWh)
Use standard EU conversion factors:
| Fuel | Conversion | Example |
|---|---|---|
| Diesel | 1 litre = 0.010 MWh | 25,000 litres → 250 MWh |
| Petrol | 1 litre = 0.009 MWh | 5,000 litres → 45 MWh |
| LPG | 1 litre = 0.007 MWh | 2,000 litres → 14 MWh |
Total energy use = sum of all fuel types in megawatt hours (MWh).
Step 5 – Calculate GHG Emissions (tCO₂e)
Apply standard emission factors (EU or national datasets such as DEFRA, ADEME):
| Fuel | Emission factor (kg CO₂e/litre) | Example |
|---|---|---|
| Diesel | 2.68 | 25,000 × 2.68 = 67 tCO₂e |
| Petrol | 2.31 | 5,000 × 2.31 = 12 tCO₂e |
| LPG | 1.51 | 2,000 × 1.51 = 3 tCO₂e |
Total Scope 1 emissions = 82 tCO₂e
If you use electric vehicles, calculate Scope 2 emissions based on electricity purchased (kWh × grid emission factor).
Step 6 – Prepare a Reporting Summary Table
Use a simple VSME-style disclosure table (under B3 – Energy and GHG Emissions):
| Indicator | Unit | 2024 | 2025 (target) |
|---|---|---|---|
| Diesel use | litres | 25,000 | 22,000 |
| Petrol use | litres | 5,000 | 4,000 |
| Total energy use | MWh | 309 | 280 |
| Scope 1 GHG emissions | tCO₂e | 82 | 74 |
| Scope 2 GHG emissions | tCO₂e | 5 | 4 |
| GHG intensity | tCO₂e/€1,000 turnover | 0.014 | 0.013 |
Narrative:
“Fuel use decreased by 12% through improved route planning and driver eco-training. The company aims to add two electric vans by 2025.”
Step 7 – Keep Receipts as Evidence
The CSRD emphasises verifiability. Retain all source records for five years, including:
- PDF copies of invoices or fuel statements
- Excel spreadsheets or exports
- Calculation sheets showing energy and GHG conversions
You don’t need to publish the receipts — only the aggregated results — but you should be able to show them if a verifier or client requests evidence.
Step 8 – Add Qualitative Information (Optional)
Under VSME B2 – Practices and Policies, include a short section about how fuel data supports sustainability management:
Example:
“Fuel use is monitored monthly using supplier card data. The company introduced a driver awareness programme in 2024 and targets a 5% reduction in fuel consumption annually.”
Integrating Fuel Data into CSRD and VSME Reporting
| Requirement | CSRD / VSME Reference | SME Action |
|---|---|---|
| Energy and GHG data | VSME B3 | Report total fuel use and emissions |
| Policies and practices | VSME B2 | Explain fleet efficiency actions |
| Pollution (air) | VSME B4 | Mention compliance with Euro standards |
| Double materiality | CSRD Art. 19a | Link emissions to financial and environmental impact |
By linking operational data (fuel receipts) with sustainability disclosures, you demonstrate both accountability and data reliability — two CSRD essentials.
Common Mistakes to Avoid
- ❌ Reporting fuel costs instead of litres — costs fluctuate, emissions don’t.
- ❌ Ignoring on-site fuel tanks — include all company-controlled fuel.
- ❌ Mixing Scope 1 and Scope 2 — keep vehicle fuel separate from electricity use.
- ❌ Forgetting to keep receipts — verifiers need an audit trail.
Frequently Asked Questions
Do transport and logistics SMEs need to report fuel use for CSRD?
Most small transport and logistics companies are not directly required to report under CSRD, which applies to large companies (250+ employees, €40M turnover, or €20M assets). However, many transport companies need to provide fuel and emissions data to large clients, corporate customers, or investors who are CSRD-compliant. The VSME Standard offers a simplified, voluntary framework for transport companies to meet these supply chain requirements efficiently.
Check if CSRD applies to your business →
How do I track fuel use if I have multiple vehicles or drivers?
Track fuel use from each vehicle separately using fuel receipts, fuel card statements, or fleet management systems. Aggregate the totals across all vehicles for your annual report. Record fuel types (diesel, petrol, LPG), quantities (litres), and convert to energy (MWh) and emissions (tCO₂e) using standard factors. Many transport companies use fuel card systems or fleet management software to automate this tracking.
See the complete transport guide →
Can I use fuel costs instead of litres for reporting?
No, you should report fuel quantities (litres) rather than costs, as costs fluctuate with prices while emissions are based on fuel volume. Convert litres to energy (MWh) and emissions (tCO₂e) using standard conversion factors. Keep all fuel receipts and invoices as evidence for verification. The VSME Standard requires actual fuel quantities, not cost-based estimates.
How accurate does my fuel data need to be?
For VSME reporting, reasonable accuracy is expected, not perfection. Use actual data from fuel receipts, invoices, or fuel card statements where available. If you need to estimate (e.g., for vehicles without detailed tracking), document your methodology and be transparent about assumptions. The key is consistency year-over-year so you can track improvements and demonstrate progress to clients and lenders.
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
- VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024)
- Scope 1 emissions: Direct GHG emissions from owned or controlled sources (e.g. vehicle fuel)
- Scope 2 emissions: Indirect emissions from purchased energy (e.g. EV charging)
- MWh: Megawatt hour – energy unit equal to 1,000 kWh
- tCO₂e: Tonnes of carbon dioxide equivalent
- GHG intensity: Emissions divided by turnover or activity unit
While fuel receipts relate to Scope 1 emissions, you may also need to identify which Scope 3 categories apply to your transport business:
Identify Your Scope 3 Categories
Upstream Activities
Does your company engage in these upstream activities?
Raw materials, components, office supplies, professional services, etc.
Buildings, machinery, vehicles, IT equipment, etc.
Upstream emissions from energy production and distribution
Transportation of purchased goods to your facilities
Landfill, recycling, incineration, wastewater treatment
Flights, trains, rental cars, hotels
Personal vehicles, public transport, cycling
Only if emissions are not already in your Scope 1 or 2
This tool will help you understand the full scope of emissions reporting for your transport operations, including indirect emissions from your value chain.