CO2 mobility reporting: the new employee-data obligation for employers in the Netherlands

Employers in the Netherlands with 100 or more employees must report the CO2 emissions of employee travel. This rule is the werkgebonden personenmobiliteit (WPM) reporting obligation. It covers commuting and business trips. The Netherlands Enterprise Agency (RVO) collects the data every year. This guide explains who must report, which deadlines apply, and how international employers stay compliant.

What is the WPM CO2 reporting obligation in the Netherlands?

The WPM is a mandatory annual report on work-related travel. Employers submit the kilometres their staff travel for commuting and business trips, split by transport mode and fuel type. RVO then calculates the CO2 emitted automatically. The obligation took effect on 1 July 2024. It forms part of Dutch climate change policy under the Environment Act.

The data works as a national CO2 monitor for work-related mobility. According to RVO, business traffic and commuting account for more than 50% of the kilometres driven in the Netherlands. Therefore, employee travel is a logical place to reduce Netherlands CO2 emissions.

Who must report CO2 emissions in the Netherlands?

Every employer with 100 or more employees on 1 January of the reporting year must file a WPM report. An employee counts when they have a contract for at least 20 paid hours per month. Smaller organisations may report voluntarily. The rule also covers international companies that employ 100 or more people through a Dutch entity.

One change is pending. The government plans to raise the threshold to 250 employees, with retroactive effect from 1 January 2026. However, parliament has not yet adopted this amendment. Until it becomes law, mid-sized employers should keep collecting their travel data.

Key deadlines for Netherlands CO2 emissions reporting

The WPM follows calendar years. You collect travel data during the year and file it with RVO before 30 June of the next year. The deadline for 2025 data was 30 June 2026. Late filers should still submit as soon as possible, because enforcement is active. Plan your data collection early, because payroll and lease systems often hold the numbers you need.

Reporting year	Who must file	Deadline
2024 (second half or full year)	Employers with 100+ employees	30 June 2025 (closed)
2025	Employers with 100+ employees	30 June 2026 (closed)
2026	100+ today; possibly only 250+ if the pending change passes	30 June 2027

What data does the CO2 monitor require from employers?

You report annual kilometres for commuting and business travel, broken down by transport mode and fuel type. You never calculate the CO2 footprint yourself. Instead, the online RVO form converts the kilometres and returns a report on the CO2 emitted by your workforce.

In practice, you need four data sets:

• Total commuting kilometres per transport mode
• Total business-travel kilometres per transport mode
• Fuel type per mode, for example petrol, diesel, or electric
• Your employee count on the 1 January reference date

You submit the form through the RVO portal. For access, your organisation needs eHerkenning at level 2+ or higher.

Why does the Netherlands track CO2 emitted by commuting?

The Netherlands tracks work-related travel because its climate targets are under pressure. Statistics Netherlands (CBS) reports that Netherlands CO2 emissions reached 145.6 megatonnes of greenhouse gasses in 2025. That total was 0.8% higher than in 2024. Mobility caused roughly a fifth of it. The country aims for 55% fewer greenhouse gasses by 2030 than in 1990. However, current projections show that goal is out of reach without extra measures. As a result, the government wants hard data on employee travel.

The global picture adds urgency. Fossil fuels pushed worldwide emissions to a record 38.1 billion tonnes in 2025, according to the Global Carbon Budget. Every ranking of CO2 output by country shows the same trend, and global warming continues while totals rise. Comparing the CO2 footprint by country explains why the EU expects members to act. Moreover, the Dutch government has planned an interim review. If collective progress falls short, an individual emissions ceiling per employer could follow from 2027.

What happens if you miss the WPM deadline?

Regional environment agencies enforce the WPM. They check whether you filed on time and whether your data looks credible. If you fail to report, the agency can take enforcement measures, including a non-compliance penalty. Filing late is therefore always better than not filing at all. In some cases, agencies also ask follow-up questions or inspect your records.

How Octagon supports compliant talent mobility

Moving talent across borders always creates local data and compliance duties, and the WPM is a clear example. Octagon Professionals has enabled organisations to build teams in the Netherlands and across Europe since 1987. As an employer of record, Octagon becomes the legal employer of your team. Consequently, employment compliance, payroll, and statutory reporting sit with a partner that knows the Dutch system.

This reduces concrete risks: missed statutory deadlines, non-compliant contracts, and penalties from Dutch authorities. At the same time, Octagon works as an extension of your team, with full transparency at every step. You keep complete control over salary, benefits, and working arrangements. Ready to grow in the Netherlands with confidence? Talk to Octagon Professionals today.

Frequently asked questions

Do I have to report CO2 emissions in the Netherlands with fewer than 100 employees?

No. The WPM obligation only applies to employers with 100 or more employees on 1 January of the reporting year. Smaller organisations may submit data voluntarily through the RVO form. The government also plans to lift the threshold to 250 employees, but parliament still needs to approve that change.

What is the deadline for the WPM report in 2026?

Employers had to submit their 2025 travel data to RVO by 30 June 2026. If you missed this date, file as soon as possible, because environment agencies can impose a penalty. Data for 2026 must be reported by 30 June 2027, unless new legislation changes the threshold first.

How is CO2 calculated in the Dutch WPM report?

Employers never calculate emissions themselves. They only enter annual kilometres into the RVO online form, split by travel purpose, transport mode, and fuel type. The system converts those kilometres into CO2 automatically. Afterwards, the employer receives a results report with suggestions for more sustainable mobility.

Does the WPM apply to foreign companies with employees in the Netherlands?

Yes, the rule applies when a foreign company formally employs 100 or more people in the Netherlands. Staff hired through an employer of record are employed by that legal employer instead. For tailored guidance on your reporting duties, Octagon’s consultancy team can support you.