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The PMST and Scope 3 Category 7: one dataset, two obligations
The commuting data you collect for the mobility plan is the same data that feeds Scope 3 Category 7, ESRS E1 and CDP. How to collect it once.
Dcycle Team 3 min The commuting plan is a mobility obligation, not a climate one — art. 26 does not require a carbon footprint. But the data the plan needs is exactly the data Scope 3 Category 7 needs. Collect it once and it serves both; collect it twice and you will end up with two figures that disagree.
What each one needs
| Data point | PMST | Scope 3 Cat. 7 |
|---|---|---|
| Main mode per person | Modal split, the plan’s core indicator | The emission factor to apply |
| Distance per journey | Accessibility analysis, route design | Vehicle-km input |
| Car occupancy | High-occupancy measures, art. 28 hierarchy | Emissions allocated per person |
| Journey frequency | Shuttle and shift sizing | Annual scaling |
| Site of assignment | The per-workplace threshold and per-site chapters | Allocation by facility |
| Season | Mandatory: the plan must address peak periods | Splitting the inventory by period |
| Postcode of origin | Origin–destination analysis | Distance estimation |
The overlap is almost total. The plan also needs road safety and willingness-to-change data; the inventory also needs emission factors and a declared methodology.
Design the survey for both from the start
Adding the questions Category 7 needs — occupancy, frequency, distance — costs nothing at design time and everything if you have to re-run the survey. See The mobility survey and the indicator dashboard for the minimum question set and how to run it in Dcycle.
Why put the footprint in the plan anyway
It is not required, but it is the indicator that makes sense of the rest. “Modal split moved 4 points” is a mobility statement; “we avoided 180 tCO₂e” is a business one. It also gives every measure card a comparable impact field, so a shuttle, a carpooling platform and a charging point can be ranked against each other — and it is what the biennial follow-up can show, since modal split moves slowly while tonnes and cost saved do not.
The same data serves three more frameworks
- GHG Protocol Scope 3, Category 7 — employee commuting
- CSRD / ESRS E1 — gross Scope 3 by category, and the E1-3 mitigation actions, which is essentially what a measure card is
- CDP — Category 7 reporting and the emissions reduction initiatives section
- ISO 14064-1 — indirect emissions from transport
The reverse holds too: if you have been calculating Category 7 for years, most of your plan’s diagnosis already exists.
Declare your boundary in both places, identically
Field crew transport, machinery, inbound raw material logistics and product distribution are not commuting — they belong in Categories 4, 9 or Scope 1. State the boundary the same way in the plan and in the inventory methodology, so the two figures reconcile when someone compares them.
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Up next
The mobility survey and the indicator dashboardThe minimum a commuting survey has to ask, why seasonal sites need two waves, the participation rate that makes a diagnosis defensible, and the indicators to track.
Read more → A structure for the plan: ten sections and a measure cardA working index for a Sustainable Commuting Plan, aligned with the OTLE monograph — what goes in each section, and the fields every measure card should carry.
Read more → Upload employee commuting from your own surveyIf you run your own commuting survey — in your HR system, an internal form or an intranet — you can export the results and upload them straight to Dcycle instead of using the built-in mobility survey. Anonymous surveys work too: the employee email is optional.
Read more →