Transport and logistics occupy a peculiar position within ESG legislation. Most of the reporting obligations that fall on this sector do not arise because a transport company is itself the biggest polluter, but because the company is part of the chain of another company that is subject to reporting obligations. A shipper, retailer or producer that falls under the CSRD must include the emissions of its transport in scope 3. This means that transport companies must supply data to customers, without automatically falling under the same rules themselves. Those two positions, being subject to reporting obligations yourself and being a supplier of reporting data, are regularly confused with each other in practice.
In addition, transport is not a homogeneous sector in regulatory terms. Road transport, aviation, shipping and rail each have their own sectoral regimes alongside the generic ESG legislation, and those regimes often originate internationally (IMO, ICAO) while the reporting obligation is given shape at European or national level. This makes the question "which rules apply to our company" more layered for a transport company than for a sector that operates within a single jurisdiction and a single mode of transport.
Whether a transport or logistics company itself falls under the CSRD depends on the familiar criteria around size: number of employees, revenue and balance sheet total. A listed company is subject to a different regime than a non-listed company of comparable size. For the exact threshold values and the effective dates per category, the following applies: these are laid down in the directive and the national transposition legislation, and it is best to consult that text directly, because thresholds and transitional periods are subject to revision.
What is certain, however, is that a company that is not itself subject to reporting obligations is nevertheless constantly asked for ESG data by customers that are. This is an obligation that does not arise from the law itself, but from the contractual and commercial reality of a chain in which the largest party pushes the reporting burden downward. For a medium-sized transport company, that derived demand can weigh more heavily than its own legal obligation.
The common thread in ESG legislation is that a European rule rarely lands unchanged in national legislation. For transport, this effect is pronounced, because member states impose additional requirements, for example on emission registration of a company's own vehicle fleet, on subsidy conditions for making vehicles more sustainable, or on permits linked to CO2 targets. A company that consults only the European source text often does not see the national layer, while in practice that layer determines which authority supervises and what evidence that authority requires. That is precisely the point where many boards go wrong: they think of "the CSRD" as a single rule, while its demonstrability is organised differently per country.
Regardless of whether a transport company itself falls under a reporting obligation, the question a board, CFO or General Counsel must ask is not only "which rule applies", but "who within the organisation owns which obligation, what evidence substantiates that this obligation has been met, and which control ensures that this is repeatable". A transport company that supplies scope 3 data to customers has just as much need for a documented owner and a verifiable process as a company that falls directly under the CSRD, because that data provision too can be queried, disputed or audited.
The Compliance Check is built on that structure: for each obligation relevant to the organisation, it records who the owner is, what evidence exists, and which control oversees it. This is not a second set of rules alongside existing legislation, but the layer that allows a board to demonstrate that it is in control, regardless of the precise articles and deadlines that apply.
Transport and logistics serve almost every other sector, and the ESG obligations of those other sectors carry through into the demand placed on a transport company. For example, the nature of the demand for chain transparency differs when the client must answer which ESG rules apply to retail, compared to the question that arises when the client belongs to professional services or to the agricultural sector, where, for example, refrigerated transport and shelf life add extra layers of reporting. A transport company that drives for multiple sectors therefore sees these different demand patterns arrive simultaneously, which makes it harder to follow a single uniform approach.
The Compliance Check for transport and logistics is currently being built. There is not yet a working overview that automatically indicates which obligations apply to a specific company and who should own them. Anyone who wants insight into this now can sign up for the waiting list and will be informed as soon as the check becomes available.
Once it is clear which ESG obligations rest on a transport company and who owns them, the next question follows naturally: who carries out the work associated with that ownership, and how much of that work, from data collection to drawing up scope 3 reports for customers, is a task that can be structured and accelerated. FTE TO AI offers a work scan for this purpose that calculates per task which part of the work can be taken over by AI, which for a sector that largely runs on repeatable, data-intensive reporting questions is a logical next step after answering the question of which rules apply.
Vraag maar welke verplichting op u van toepassing is, en waaraan u dat kunt aantonen.
Answers come from this site’s knowledge base. Not tailored advice, and not a scan of your company.