Market Trends
How to report transport emissions under CSRD
Why outsourced city delivery lives in Scope 3 — and how to make that data audit-ready.
CSRD makes transport a reporting obligation, and for most shippers outsourced city delivery sits in Scope 3. Here’s what’s required — and how to get carrier data accurate enough to pass assurance.
Samuel Jones
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What CSRD requires for transport emissions
Under the EU’s Corporate Sustainability Reporting Directive (CSRD), companies in scope must report greenhouse gas emissions across Scope 1, Scope 2 and Scope 3, following the European Sustainability Reporting Standards (ESRS E1). For most businesses that move goods, the emissions from transport — particularly delivery handled by an outside carrier — fall into Scope 3, and they are consistently one of the largest and hardest-to-measure parts of the entire report.
In Finland, the CSRD is implemented through national accounting law. The Finnish Ministry of the Environment has found that poor data availability is one of the biggest practical challenges companies face when producing these reports (Ministry of the Environment).
The factor that decides how difficult this becomes is data quality. There are two ways to arrive at a transport emissions figure: primary data, measured from the actual movement (distance, vehicle, fuel or energy used), and estimated data, calculated after the fact from industry-average emission factors. The ESRS expect companies to use primary data where it’s available and to fall back on averages only where it isn’t. The recognised methodologies here are the GHG Protocol, and for transport specifically ISO 14083 (which replaced EN 16258) and the GLEC Framework from the Smart Freight Centre.
A note on scope, because it changed recently: the Omnibus simplification package agreed in late 2025 narrowed mandatory CSRD reporting to larger companies and pushed back several deadlines. But even companies that fall out of direct scope keep receiving CSRD-style data requests from their larger customers, their lenders, and procurement teams — because those larger players still need value-chain (Scope 3) data to complete their own reports. In practice, if you move goods in Europe, accurate transport emissions data is something you’ll be asked for either way.
Sources used in this section
Why estimated carrier data becomes a problem
Most companies don’t run their own city fleet — they outsource last-mile and in-city delivery. That places the actual emissions with a subcontractor, and leaves the shipper dependent on that carrier to supply the numbers. In practice, many carriers provide either nothing, or a figure calculated after the fact from generic averages.
That’s where it gets risky. CSRD reporting is subject to independent assurance, and auditors don’t just want a number — they want traceable data lineage: the source, the method, the emission factor, and the date behind every figure. A number built on industry averages is weaker evidence, harder to defend, and carries greenwashing risk if it can’t stand up to scrutiny. Estimates can fill a gap, but they’re not the same as knowing.
There’s a commercial edge to this too. Increasingly, your own customers ask for per-shipment or per-tonne-kilometre emissions in their tenders, so they can complete their Scope 3 reporting. If you can’t hand that over, it can cost you the contract — and if your carrier can’t hand it to you, you’re stuck.
So the real question isn’t which spreadsheet to use. It’s whether the party actually doing the driving produces verifiable, primary data in the first place.
Getting data that’s accurate by default
This is where the structure of your carrier matters more than the tools bolted on afterward. A traditional carrier moves goods and, at best, estimates the emissions later. A Neocarrier — where the fleet and the software are built as one system — measures as it moves.
At Dubs, every kilometre driven generates verified emissions data in real time, produced from the actual operation rather than estimated afterward. For a shipper, that means the transport line in your Scope 3 reporting comes from primary source data with a clear trail behind it, aligned with recognised methodologies — the kind of evidence assurance is looking for. There’s no chasing a carrier for a spreadsheet at year-end; the data exists because the work created it.
That gap between measured and estimated is widest exactly where Dubs operates — in the city. Urban delivery means mixed vehicles, dense stops, and short legs, the conditions where industry-average factors are bluntest and real measurement matters most.
If city delivery is part of your footprint, and CSRD or your customers are already asking for the numbers, it’s worth working with a carrier whose data is audit-ready from day one rather than reconstructed after the fact.