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Reporting requirement work-related personal mobility

We would like to inform you of an important development regarding the reporting requirement for work-related personal mobility, which will come into effect on July 1, 2024. This is not a tax regulation, but rather a regulation related to the commuting policy within your organization. Below is a brief explanation of the regulation and the obligations it entails for your organization.

Background

In 2019, the Netherlands entered into the Climate Agreement with the goal of reducing CO2 emissions. One of the agreements in this accord is that employers with more than 100 employees must reduce their annual CO2 emissions from work-related personal mobility by at least 1.5 megatonnes by 2030. The reporting obligation was established to gain insight into CO2 emissions from work-related personal mobility in the Netherlands.

What does this obligation entail?

Annually, a report must be submitted on the total number of kilometers traveled by employees, specified by means of transportation, fuel type and whether it is for business or commuting trips. This only includes trips with a start and/or end point in the Netherlands. This report is submitted using a digital form on the website of the Rijksdienst voor Ondernemend Nederland (RVO). Employees traveling in vehicles registered on a gray license plate are excluded from this obligation. Air travel and travel by vessel are also excluded from the scope and do not have to be reported.

When to report?

Data on both business travel and commuting by employees, must be reported by June 30, 2025, at the latest. Until 2026, there is no specific standards, it relates solely to collecting data. Additional requirements may be introduced starting 2026. In 2023, every employer may voluntarily report data for 2022. Similarly, in 2024, voluntary reporting can still be done for 2023. Although the date of mandatory reporting is July 1, 2024, employers may choose to start reporting on January 1, 2024. For employers who choose to only start on the day that the obligation comes into effect, i.e. July 1, 2024, the six-monthly outcome of 2024 will be extrapolated to the entire year.

What if the reporting requirement is not met?

An employer who does not meet the reporting requirements will first be urged to comply. If, after these reminders, the reporting requirement is not met in a timely manner, a penalty may be imposed. This could occur if no report is submitted or if the report does not meet basic requirements.

A manual on how to report has been published on the website of the RVO. Of course, we are happy to think along with you on this subject.

Questions?

If you have any questions regarding this newsletter, please don’t hesitate to contact us.

Peter Karman

Of-counsel

Audrey Mol

Associate
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