An HR lead at a German insurer describes the problem like this. From the current office it is a 20-minute walk to the nearest bus stop. The bus runs every 20 to 40 minutes depending on whether schools are in session. Reaching the nearest suburban rail station takes considerably longer. Most employees commute 30 to 50 kilometres in from surrounding villages, almost all of them by car. Introduce a mobility budget at that company that consists mainly of a Deutschlandticket subsidy, and the outcome is predictable: most of the people entitled to it cannot use it, because the public transport on their doorstep does not work.
This is the most common form of the equal treatment objection that works councils raise against mobility benefits. Someone working in Munich, Berlin, or Hamburg who receives a Deutschlandticket subsidy is better off. Someone working in a small town or a rural district is left watching. Where HR does not address this before the first works council meeting, introduction typically slips by months, or the benefit reaches only part of the workforce.
This guide shows how to configure a mobility budget so that it delivers real value at sites without usable public transport: the four components that actually work at rural locations, a logic for site-specific configuration, and a worked comparison HR can take into any works council meeting.
Context for readers outside Germany: the Deutschlandticket is a nationwide monthly public transport pass, priced at €63 per month in 2026. Employers frequently subsidise it as a Jobticket. It is the default building block of most German mobility budgets, which is exactly why rural sites can be challenging.
Conceptually, a mobility budget is an inclusive benefit. Unlike a company car, which is usually available to one level of the hierarchy, it is meant to reach everyone equally. In practice that promise meets a reality many HR teams underestimate: German public transport infrastructure is highly uneven, and the share of the population with a genuinely usable connection is smaller than commonly assumed.
However, there are underlying structural challenges that make the urban-rural argument a legitimate concern.
Even at inner-city office locations, many employees commute in from suburbs or rural areas. An office in Berlin does not mean the workforce can use public transport. Commuters from the surrounding region are often dependent on a car because regional connections do not support a daily commute.
In chemicals, metalworking, construction, and the public sector, § 75 BetrVG applies to every new voluntary benefit. The works council checks whether the benefit reaches all employee groups. A mobility budget consisting mainly of a Deutschlandticket subsidy fails that test where a large share of the workforce cannot realistically use the ticket.
§ 75 BetrVG obliges employer and works council to ensure every person in the establishment is treated according to principles of law and equity, which includes not disadvantaging groups without objective justification.
Where a mobility budget is introduced and only a third of those entitled use it because the configuration does not match the commuting pattern, the benefit becomes an investment without effect. HR then has to explain internally why the project missed its targets. In a group context that explanation loop usually matters more than the direct financial impact.
The answer is not to leave rural sites out. It is a configuration that supports commuting by car as well as it supports commuting by public transport.
"No public transport" is a rough simplification. Three site types can be distinguished in practice, and each needs a slightly different budget configuration.
Groups with distributed sites in Germany normally have all three types at once. A group-wide mobility budget has to cover all three without separate contracts per location, or it does not work in practice.
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At suburban and rural sites, different components can reflect car commuting sensibly while staying tax-efficient.
For tax purposes the card can run either inside the €50 monthly benefit-in-kind exemption limit under § 8 Abs. 2 Satz 11 EStG, or through flat-rate taxation. Which route fits depends on whether other benefits in kind already exist and which construction suits the payroll setup. For employees commuting 60 to 100 kilometres a day, the fuel and charging card is the economically most relevant part of the budget.
The tax treatment of home charging changed fundamentally at the start of 2026. The previous flat rates of €15 to €70 per month ended on 31 December 2025. Since 1 January 2026 settlement is per kWh, using either the employee’s individual electricity price or the statutory flat electricity rate (2026: €0.34 per kWh). The choice has to be exercised uniformly for the whole calendar year.
The volume charged always has to be evidenced by a separate meter, which can be stationary or mobile and expressly includes the vehicle’s internal meter. The flat rate concerns the price only, never the quantity.
For employees with an electric company car at a rural site, home charging is often the only practical option, because the public charging network outside cities is still thin, and public charging is normally considerably more expensive than charging at home.
For employees who need a car from time to time without owning one or holding a company car, a car subscription can be taken out through the employer, with the monthly rate funded partly or fully through salary conversion. Companies that do not want to commit to multi-year leases, because of uncertain turnover, project durations, or site changes, find a bridge here.
Company bike leasing for the last mile
Bicycle leasing is often underestimated at rural sites but works well for the stretch between home and the station or bus stop. An e-bike closes typical gaps in rural public transport connections and lets a meaningful group of employees combine rail and bike. Where the bicycle is provided on top of salary, § 3 Nr. 37 EStG applies, subject to the additionality requirement in § 8 Abs. 4 EStG, so it can be configured alongside the fuel and charging card.
The Deutschlandticket remains a sensible supplementary component at rural sites, because many employees value nationwide public transport access for occasional trips to the nearest city or at weekends. It is simply not the lead component there.
A central mobility policy with site-specific budget tiers is the most pragmatic way to cover the urban-rural spectrum. The policy defines the overarching rules (permitted components, tax construction, eligibility), and the site-specific layer sets the actual configuration per location. Different implementation use cases have worked in practice.
Employees receive the same monthly budget, say €100. At urban sites the platform configures it by default as a Deutschlandticket subsidy plus a bicycle component. At rural sites as a fuel and charging card plus a bicycle. The total stays the same; the split matches the location.
Where the underlying cost logic differs, since rural sites carry higher commuting costs per employee, the budget level itself can be differentiated per site. That has to be justified explicitly to the works council, or employees at the lower-budget sites will read it as unequal treatment. An objective derivation, for example from average commuting distances, helps.
Everyone receives the same budget and the same set of components, and decides individually which to use. This is administratively the simplest and the easiest to defend to a works council, because it requires no site-specific differentiation at all. It works well provided the platform front end is good enough that employees find the configuration that suits their location without HR support.
Which of the three fits depends on the group culture and the works council structure. Where a group works council is strong, options one and three are usually preferable. Where site-level works councils are decentralised, option two is sometimes the more pragmatic route.
Companies wonder regularly if carpooling or a works shuttle can replace an individual mobility budget. The honest answer is that they rather work as a supplement and rarely as a substitute.
Carpooling works where employees have similar commutes and comparable working hours. At rural sites that is frequently not the case. One insurer’s HR lead described the problem: the workforce is spread across several villages, everyone arrives at slightly different times, and matching is organisationally demanding. An internal ride-sharing platform can help, but it does not replace the individual budget.
Works shuttles make sense where a site sits far from a public transport hub and a large share of the workforce commutes in from the same direction. The typical case is an industrial or insurance site with a shuttle to the nearest station. Here the shuttle closes the last-mile gap and can suddenly make the Deutschlandticket usable, including for commuters from the wider region.
Sustainability matters in both cases. Carpooling and works shuttles both reduce CO₂ emissions per employee against solo car commuting, which is relevant in the CSRD context because Scope 3 emissions from employee commuting are among the reportable categories. A platform should therefore structure its data so that carpooling and shuttle use can be captured separately.
What deliberately does not work is a sustainability argument as the justification for a rural configuration. Employees at a site 25 kilometres from the nearest station will not be argued onto a bus by a reference to CO₂ targets. The configuration has to reflect the actual commuting reality first; the sustainability logic can then serve as an additional rationale.
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Get infoA comparison across three realistic profiles shows how the budget lands across site types. This can also be brought up in works council meetings as it makes the inclusiveness concrete.
The point is that all three employees receive the same budget. What differs is not the level of subsidy but the split across components. That makes the equal treatment argument to the works council clean. Nobody is disadvantaged because public transport does not work on their doorstep; each person picks the configuration that matches their own commute.
In practice employees choose their components through the platform front end. HR does not have to decide centrally who gets which configuration. The platform makes the permitted components available and employees configure their budget to fit their situation.
NAVIT covers all four components in one platform. That matters in the urban-rural context, because a platform that only handles public transport structurally cannot work at rural sites. Deutschlandticket, fuel and charging card, car subscription, bicycle leasing, and home charging run in one consistent data model, with a single payroll handover and unified reporting.
For site-specific configuration the platform supports both the uniform setup with employee choice and the site-differentiated setup managed by HR. Different components can be enabled or excluded per subsidiary, site, or employee group.
Deloitte manages approximately 9,700 Deutschlandticket subscriptions across 16 German locations with around one hour of HR effort per month, working from a single consolidated payroll report rather than one per site.
For the home charging component from 2026, employees submit their per-kWh evidence through the app, the system checks plausibility, settles at either the individual electricity price or the statutory flat rate, and hands the correctly taxed reimbursement to payroll. That removes the manual spreadsheet work the new per-kWh requirement would otherwise create.
Does a mobility budget work at all at sites without public transport?
Yes, provided the configuration matches the reality of the site. At rural locations the budget consists primarily of a fuel and charging card, supplemented by bicycle leasing, a car subscription, and home charging for those with an electric company car. The Deutschlandticket is a supplementary component there rather than the lead one.
How do works councils react to site-differentiated configuration?
Usually positively, provided the differentiation is objectively justified. A configuration that reflects each site’s commuting pattern is clearly more inclusive than a rigid group-wide public transport solution. What matters is that the total budget per employee stays the same, or that differences can be justified objectively.
How is home charging for electric company cars settled since 2026?
The previous flat rates of €15 to €70 per month ended on 31 December 2025. Since 1 January 2026 settlement is per kWh. Employees can use either their supplier’s individual price or the statutory flat electricity rate (2026: €0.34 per kWh), applied uniformly for the calendar year. The volume charged always has to be evidenced by a separate stationary or mobile meter, which expressly includes the vehicle’s internal meter. Tax-free treatment under § 3 Nr. 50 EStG applies to company vehicles only; for a privately owned car the same payment is taxable wages.
Can the mobility budget be combined with a fuel and charging card?
Yes. The card is one of the core components of the budget. For tax purposes it runs either inside the €50 exemption limit under § 8 Abs. 2 Satz 11 EStG or through flat-rate taxation. The €50 figure is an exemption limit rather than an allowance: exceed it and the whole amount becomes taxable.
How can carpooling or shuttle schemes be included?
Carpooling works as a supplementary component, for example through an internal ride-sharing platform. Shuttles make sense where the site is far from the nearest station and a large share of the workforce commutes from the same direction. Neither replaces the individual mobility budget.
What is the tax treatment of each component?
It differs by component and has to be set per benefit rather than for the budget as a whole. Fuel and charging card: § 8 Abs. 2 Satz 11 EStG, or flat-rate taxation. Home charging for an electric company car: per-kWh settlement as tax-free Auslagenersatz under § 3 Nr. 50 EStG, company vehicles only. Bicycle: § 3 Nr. 37 EStG, subject to the additionality requirement in § 8 Abs. 4 EStG. Deutschlandticket: § 3 Nr. 15 EStG, which reduces the employee’s commuting allowance. Car subscription: depends on the construction, broadly as for a company car. A binding ruling under § 42e EStG from the tax office for the place of business creates certainty in more complex cases.
Disclaimer: NAVIT accepts no liability for the accuracy of the information provided. The content on our website is for general information purposes only and does not constitute tax or legal advice. It cannot and is not intended to replace individual, binding tax and legal advice addressing your specific circumstances. All information is provided without warranty as to accuracy or completeness.
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