An international staffing group running a fleet of roughly 1,500 vehicles has committed to full electrification by 2030. Its ESG lead needs a data structure that cleanly separates Scope 1 emissions from the remaining combustion share, Scope 3 emissions from employee commuting, and eventually Scope 2 emissions from home charging. In a different department, HR is introducing a mobility budget, because younger employees prefer flexible mobility to a fixed company car. Two projects, two owners, and the same underlying data, with neither side knowing what the other actually needs.
That situation is unremarkable, which is the problem. HR is buying a benefit, ESG is sourcing a reporting input, and fleet sits between them holding operational responsibility for the vehicles. Left uncoupled, the company builds two parallel data streams and merges them by hand later, which produces precisely the spreadsheet consolidation an auditor marks as a control weakness.
What follows covers who is still in scope after the 2026 Omnibus revision, how the mobility budget maps onto ESRS E1, and what a platform has to be able to show before the first report goes to assurance.
The CSRD is the Corporate Sustainability Reporting Directive, the EU rulebook for sustainability reporting. ESRS are the reporting standards written under it, and ESRS E1 is the climate standard. VSME is a lighter voluntary standard for smaller companies. Non-EU parents with EU subsidiaries can fall in scope through those subsidiaries.
The EU Omnibus process moved the scope of the CSRD substantially. Directive (EU) 2026/470 was adopted by the Council on 24 February 2026 and published in the Official Journal on 18 March 2026. What had been designed as a staggered three-wave rollout became something simpler and considerably narrower: higher thresholds, and a later start.
Two criteria now decide, and both have to be met.
The word "and" is doing the work here. A company with 1,500 employees and €300 million in turnover is out. So is a company with €600 million in turnover and 800 employees. The Commission estimates that roughly 80 % of the companies originally captured now fall outside the obligation.
Timing splits the remaining population in two. Companies that were already reporting under the old NFRD regime, meaning large listed groups above 500 employees, continued to report for financial year 2024. Everyone else who meets the new thresholds begins with financial year 2027 and files a first report in 2028.
Groups below the new thresholds are not off the hook in practice. Their large customers remain in scope and keep sending data requests down the supply chain. There is a protection written into the rules for that: such requests may not go beyond the content of the voluntary VSME standard, and anything further can be refused with legal effect.
ESRS E1 is the climate standard, and in practice almost every reporting group concludes that it is material. The double materiality assessment asks both whether the company affects the climate and whether the climate creates risk for the business, and for nearly any business model at least one of those is true. Concluding otherwise is possible, but it has to be justified in detail, which is more work than reporting.
Once E1 is material, all three GHG Protocol scopes have to be captured, and mobility appears in every one of them. Scope 1 covers direct emissions from sources the company controls, which in a mobility context means combustion vehicles in the owned fleet. Scope 2 covers indirect emissions from purchased energy, which is where electricity for electric company cars sits, including the electricity drawn from an employee’s home connection. Scope 3 covers everything else along the value chain, and two of its fifteen categories are relevant here: category 7 for employee commuting and category 8 for leased assets the company uses itself.
A mobility budget rolled out across a group touches all three. A fuel and charging card produces Scope 1 data when the vehicle belongs to the fleet, and Scope 2 data for the electricity drawn at a public charge point. Home charging through an employee’s wallbox is Scope 2. The Deutschlandticket, bicycle leasing, and a car subscription all land in Scope 3.
That overlap is the argument for coupling the two projects. A mobility budget introduced with an ESRS-aware data structure does not add a data source. It removes the manual consolidation that the spreadsheet alternative requires.
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ESRS E1 is more precise on method than most people expect. An auditor reviewing mobility emissions will not start with the total tonnage. They start with how the number was produced, and the questions come in a predictable order.
Where did the emission factors come from?
Every calculation of emissions per kilometre or per euro spent has to rest on documented emission factors. In Europe the IPCC factors are the reference point, differentiated by mode of transport and geography. An undocumented or outdated factor gets challenged, not because the number is necessarily wrong, but because the auditor cannot reconstruct how it was reached. The source has to be recorded systematically, not remembered.
Can you show which version was used when?
Factors change. Without versioning, nobody can tell whether a year-on-year drop in emissions reflects employees actually travelling differently or a methodology update that shifted the baseline. That distinction is the whole point of the exercise, and an auditor will keep pulling at it until the versioning answers it.
Is Scope 2 reported both ways?
ESRS E1 requires Scope 2 emissions in two parallel figures: location-based, using the average grid mix, and market-based, using the actual tariff the electricity was bought under, such as a renewable contract. This is not a refinement to add later. For home charging it means the platform needs the employee’s individual tariff alongside the regional grid mix, or one of the two required figures cannot be produced at all.
Does every figure trace back to a transaction?
An auditor needs to be able to walk from an aggregate back to a single booking: who received which subsidy, when, over which commuting distance, on which mode, calculated with which factor. On top of that, E1 asks for the breakdown by geography, so the same trail has to carry site and cost centre. A platform that only exposes aggregated totals cannot support an audit opinion, however accurate those totals happen to be.
Beyond the historical numbers, E1 also asks where the company is heading. Modelling how emissions would move if the electric share of the fleet went from 20 % to 50 % belongs to the transition pathway the standard asks about, and it is considerably easier if the underlying data already sits in one structure rather than being exported and rebuilt each time.
The threshold change was the headline, but the revision also softened several substantive requirements. None of them removes the obligation to produce structured data; they mostly buy time in the first years.
For the first reporting year, Scope 3 reporting is limited to groups above 750 employees. Since the CSRD threshold now sits at 1,000, that relief rarely bites in practice: anyone still in scope is automatically above it. The more useful concession is the explicit permission to lean on estimates, secondary data, and simplified methods early on. A group that does not yet capture commuting distances precisely may derive them from postcode-based estimates, provided the method is documented.
The transition plan is no longer mandatory as a standalone document. A group without one does not have to write one. A group that has one, or is developing one, still has to disclose it. Climate strategy, targets, and reduction pathways remain disclosable where they have material effects, so in practice most groups still describe their pathway. What changed is the format, not the substance.
Double materiality survived untouched. It remains the starting point that determines which topics get reported at all. Financial risks arising from climate scenarios may be described qualitatively rather than quantitatively for the first three years where the data to quantify them does not yet exist.
One thing worth watching: EFRAG is currently revising the ESRS standards themselves, aiming to cut complexity and make them more workable. The revised version is expected as a delegated act in the second quarter of 2026. Groups building their reporting structure now should track that, because individual data points can still move before the first reporting year.
The mapping below is what makes a shared data structure possible. Once each building block has a known scope assignment, the benefit project and the reporting project are working on the same ledger rather than two.
The home charging line is worth dwelling on. Because German tax rules have required per-kWh evidence since 2026, the underlying measurement is already happening for a completely different reason. Capturing the employee’s tariff alongside it turns a compliance obligation into both required Scope 2 figures at no extra effort, which is the rare case where two regimes point the same way.
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Get infoWhen HR and ESG evaluate a provider together, a short set of questions separates the field quickly. They belong in the RfP, before any demo, so that providers without the substance behind them do not reach a shortlist.
Which methodology do you use for the emissions calculation, and who maintains it?
A good answer is specific: which IPCC or other recognised factors, how they are differentiated by mode and geography, and who updates them when the methodology changes. A provider that cannot name the methodology has not given you a basis an auditor can validate.
Are the emission factors versioned and documented?
This is the follow-up that catches vague answers to the first question. Versioning is what lets anyone reconstruct which calculation ran on which factor base, and it is what separates a genuine change in employee behaviour from a methodology update.
Do you distinguish market-based from location-based for Scope 2?
A single grid-mix figure does not satisfy E1. The platform has to be able to capture both the employee’s individual electricity tariff and the regional grid mix, ideally straight out of the home charging data it is already collecting.
How deep does the audit trail go per subsidy?
Ask to see one booking end to end: person, timestamp, amount, mobility provider, commuting distance, and the factor used. If that walk-through is not possible in a demo, it will not be possible in an audit either.
NAVIT works with SQUAKE, a partner specialising in carbon calculation, for the emissions methodology. Factors are configured per mode of transport and geography and are held per mobility provider, either per kilometre or per euro spent. Each transaction is connected to the actual journey, so the emissions figure is derived from the trip rather than estimated from a category average.
That methodology is documented, which is what makes the versioning workable: because factor maintenance sits with SQUAKE, retrospective calculations on historical factors remain possible. The market-based and location-based Scope 2 figures can both be derived from the home charging data, since the platform captures the employee’s individual tariff. The audit trail runs the full calculation chain, from the booking through the commuting distance to the factor applied.
MERKUR PRIVATBANK KGaA reduced administrative effort for mobility administration by around 90 % after introduction. The documented comparison basis is the previous receipt process: employees submitted receipts for Deutschlandtickets they had bought themselves, which then had to be checked, settled, archived, and reimbursed through payroll.
Who is still subject to the CSRD after Omnibus?
Groups above 1,000 employees and above €450 million in net turnover, with both thresholds crossed. Companies already reporting under the previous NFRD regime continued for financial year 2024. Everyone else meeting the new thresholds starts with financial year 2027 and reports in 2028.
Which Scope 3 categories matter for a mobility budget?
Category 7, employee commuting, is the main one, with category 8, upstream leased assets, relevant for leased vehicles and car subscription models depending on who holds operational control. The remaining categories are not usually touched in a mobility context.
How do we combine the HR benefit project with the ESG reporting project?
By evaluating the provider jointly and putting the methodology, versioning, Scope 2 and audit trail questions into the RfP. A shared data architecture removes the manual spreadsheet consolidation and avoids maintaining the same data twice.
What does the platform have to deliver for an auditor to sign off?
An audit trail per subsidy covering person, timestamp, amount, mobility provider, commuting distance, and the emission factor used. Factors have to be documented and versioned, and Scope 2 has to be reported market-based and location-based in parallel.
What applies to suppliers below 1,000 employees?
They are no longer in scope themselves but still receive data requests from larger customers. Those requests may not go beyond the voluntary VSME standard, and anything further can be refused with legal effect.
Is ESRS E1 mandatory for every group in scope?
It is subject to the double materiality assessment, but in practice almost every group concludes that climate is material, because almost every business activity causes emissions. Concluding otherwise requires a detailed justification.
What did Omnibus actually make easier?
Scope 3 relief in the first reporting year, more room for estimates and secondary data, no mandatory standalone transition plan, and qualitative rather than quantitative description of financial climate risks for the first three years. Double materiality was left unchanged.
Disclaimer: NAVIT accepts noliability for the accuracy of the information provided. The content on ourwebsite is for general information purposes only and does not constitute tax orlegal advice. It cannot and is not intended to replace individual, binding taxand legal advice addressing your specific circumstances. All information isprovided without warranty as to accuracy or completeness.
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