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Dutch government mandates accounting for employee mobility

29 September 2023

The European Union (“EU”) serves as a driving force for sustainable policy and regulatory change, but it's not the only catalyst for change: independent EU member states are also initiating policies to drive the green agenda within their national boundaries, aspiring to go further than the bloc’s overarching legal bodies.

The reporting obligation Work-related Mobility of Persons  ("WPM”), known as “Werkgebonden Personen Mobiliteit” in Dutch, is one example in which a European member state—the Netherlands— is striving to surpass the prescribed EU regulatory frameworks in propelling the green transition.

The WPM regulation mandates companies in the Netherlands with over 100 employees to monitor and report transportation data for both employee commuting and business travel.  According to Statistics Netherlands, approximately 8,000 employers meeting the 100+ employee threshold is expected to be subject to this regulation. 1 Furthermore, smaller companies may voluntarily choose to comply with this reporting obligation.

Starting from January 1, 2024, companies under the WPM scope must provide a comprehensive account of all their employees’ business travel and commuting. This includes employee distance travelled by means of transport and fuel type. A report, which should provide aggregated annual data, must be submitted to “Rijksdienst Voor Ondernemend Nederland” (“RVO”) no later than six months after the end of the respective calendar year.

If by 2025, emissions associated with business travel surpass the predetermined emission cap established by the Dutch government in the Climate Accord (“Klimaatakkoord”) or if a decline in emissions is not evident, an emissions-based levy on business travel might be imposed for the relevant companies. In other words, companies will be allocated an emission budget for their business travel. Any emissions exceeding this budget will incur levies. The legal foundation for implementing such an emissions levy is already embedded in the draft decree and can be swiftly enforced if required. Additionally, a similar levy will likely be introduced for employee commuting, although no regulations for this emission category have been formulated at present.

In the upcoming months, companies have a valuable window to prepare for the impending 2024 reporting. This preparation phase could entail actions like conducting employee surveys to monitor commuting patterns and business travel or exploring new software solutions for precise tracking of distance-travel data. We understand the challenges management teams might face during this phase—and we're fully committed to assisting you at every stage, from data collection to final reporting. Take action.

To find out more, please contact the team.


1Working on Sustainable Mobility 09 (2022). Draft decision on CO2 reduction in work-related personal mobility. Available at:


Reference list:

Netherlands Enterprise Agency (2023). Reporting obligation work-related mobility of persons. Available at: https://english.rvo.nl/information/reporting-obligation-work-related-mobility-persons.

Netherlands Enterprise Agency (2023). Reporting obligation on work-related personal mobility. Available at: https://www.rvo.nl/onderwerpen/rapportage-wpm.


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