The CSRD is here: what HR and Sustainability need to know about the commute

The Corporate Sustainability Reporting Directive, the CSRD, is already a reality for thousands of European companies and for any company that is part of their value chain, including Brazilian suppliers. Among the points that raise the most questions is the treatment of commuting emissions, the trips employees make between home and work.

Why commuting entered the CSRD

The directive requires sustainability reports aligned with the European Sustainability Reporting Standards, the ESRS, which include detailed requirements on Scope 3 emissions. Within that category, commuting appears as an expected data point, even if it is laborious to collect. Companies that cannot present this number risk incomplete reports, which directly affects relationships with European clients, investors, and partners.

The practical challenge for HR and Sustainability

Unlike office or fleet emissions, commuting depends on individual data from each employee: where they live, how they get to work, and how often. Many HR teams still do not have this structured survey in place, and the Sustainability team has no way to report what was never measured. It is common to see companies relying on generic estimates, which weakens the report under audit.

How to structure the response

The safest path is to build a recurring collection process: a simple form applied to all employees, updated whenever a relevant change happens, such as switching to remote work or moving house. With that data in hand, it becomes possible to apply recognized emission factors and reach an auditable number that supports the CSRD report and demonstrates real diligence.

A step beyond compliance

Companies that take this survey seriously discover opportunities that go beyond the report: reviewing transport policy, incentivizing low-carbon modes, and even redesigning offices with the average distance to employees’ homes in mind. Compliance becomes the starting point for operational efficiency.

If your company needs to report commuting emissions to meet the CSRD or any other ESG requirement, Ecomilhas can help structure this diagnosis from start to finish. Talk to our team and see how to turn a regulatory requirement into a strategic advantage.