The WPM threshold may rise, but travel data still touches payroll, fleet costs and proof.
On a Monday morning, this starts as a small question at the payroll desk. A founder with 160 employees has already asked staff how they travel, cleaned the answers, and sent the numbers through the right route. Then official policy notes suggest that this duty may soon be lifted for many smaller employers.
The signal has to become readable
The legislative calendar for WGK028577 describes a draft change to the Besluit activiteiten leefomgeving. It would exclude undertakings and legal persons with fewer than 250 employees from the WPM rules on work-related personal mobility.
The procedure is still open. Consultation has passed, ministerial council approval has been given, and parliamentary pre-laying has started. Advice from the Council of State is still pending.
That is not a moment to throw away the work. It is a moment to decide what the work is still worth.
Relief is not deletion
Since 1 July 2024, organisations with 100 or more employees have had to collect data on business travel and commuting. Annual reporting started in 2025. The WPM data concerns kilometres travelled, travel modes and fuel type.
It sounds tidy when written like that. In a real company, those words land in HR, payroll, fleet contracts, rosters, homeworking rules and employee addresses.
The first reporting cycle was real work. The Ministry of Infrastructure and Water Management reported that 86 percent of employers with 100 or more employees complied for the 2024 reporting year. Many businesses have already spent time, money and patience on the process.
The proposed threshold change would move the practical line from 100 employees to 250. Policy material says 58 percent of the current 100-plus WPM target group has fewer than 250 employees, equal to 4,620 organisations. CBS shows 4,855 companies in the 100-to-250 working-person range in the second quarter of 2026.
What the signal changes
Together, those figures show the size of the middle band. For a founder inside it, this reads as pending relief, not as administrative amnesia.
The hard part was commuting
The clearest reason for the change is workability. Smaller and mid-sized employers often lack automated systems for the required travel data.
That is not a minor detail. A payroll system can show an allowance. A lease invoice can show a car. A fuel card can show litres. A roster can show expected working days. None of those alone shows how an employee actually travelled in a given year.
Commuting is especially awkward. People work from home, visit clients, change addresses, take leave, work part-time, share cars, cycle in summer and drive in winter. CBS reports an average commuting distance of 19.6 kilometres for employee jobs where both residence and work were in the Netherlands in December 2024. That calculated distance is useful context for scale, not a diary of daily movement.
The administrative burden became visible there. The original estimated burden for SME companies was about €1.6 million. Practical analysis found €5.2 million per year. For collecting commuting data, the earlier assumption was about three hours. Practice came closer to 20 hours.
Anyone who has sat with a small HR team will recognise the problem. The burden is not only the form. It is the chase behind the form.
The fleet question stays on the table
Return to the 160-employee company. If the exemption becomes final, the annual WPM report may fall away. The founder may reasonably want to stop asking employees for data that no longer serves a statutory report.
Yet the company still pays travel allowances, lease costs, fuel, parking and insurance. It may still need to explain payroll choices. It may still price travel time into client work.
A separate tax pressure is building beside the mobility report. Rijksoverheid states that from 2027 employers will pay a pseudo-final levy for new diesel and petrol cars offered to employees when those cars are also used for commuting and private use. The levy is 12 percent of the catalogue price per year. Petrol and diesel cars already provided before 2027 fall under a transition regime until 16 September 2030.
What founders should check
That is a different rule from WPM. It deserves a different calculation. A smaller employer can leave the WPM reporting duty and still face a harder fleet cost if it keeps ordering fossil company cars for mixed use.
For larger employers, the direction is different again. Employers with 250 or more employees remain close to the WPM line. Some larger businesses also face sustainability and energy reporting layers, including CSRD and EED contexts. Official material treats a single reporting route as a longer-term option, not as a working portal today.
Keep the decision close to the business
The practical governance point is simple. Travel data should not float between HR, finance, payroll and the fleet manager. One person needs to know whether the company is inside the WPM scope, what has already been collected, what has been reported, and what can be simplified when the legal change is finished.
This is not a plea to keep every spreadsheet forever. It is a plea to avoid two bad reflexes. The first is overbuilding a costly reporting machine for a duty that may soon disappear for the company. The second is deleting a useful trail before it has been judged for payroll, fleet, allowance and tax purposes.
Employers near 250 employees need extra discipline. Growth, acquisitions, group structure and the definition used for the threshold can change the position. A company that feels small in culture may no longer be small in compliance terms.
The WPM debate is often presented as a climate reporting story. It is that, but inside the business it is also a record of movement, cost and responsibility. The official WPM reduction aim was linked to 1.5 megaton less CO2 from work-related travel in 2030. The proposed threshold change lowers the WPM target to 1.2 megaton, with the remaining 0.3 megaton to be found through other measures.
That policy balance sits above the entrepreneur. The company decision sits much closer to the desk.
If the exemption lands, many employers will welcome the relief. They should. A rule that assumes a back office is stronger than it is will produce more friction than insight. But the best smaller firms will not read relief as permission to stop knowing how people move, what that movement costs, and where the evidence sits.
A kilometre can leave the WPM report and still remain in the business.
Sources
- CBS labour market data
- Rapportageplicht zakelijk en woon-werkverkeer straks niet meer voor mkb – antwoord op vragen · Salaris Vanmorgen
- Overheid.nl – Legislative status of the proposed WPM threshold change
- Overheid.nl – Policy case for excluding 100 to 249 employee organisations
- Overheid.nl – Regulatory burden assessment and timing risk
- Rijksoverheid – WPM reporting design, overlap and one-loket options
- Rijksoverheid – WPM compliance in the first reporting cycle
- Rijksoverheid – Employer mobility behaviour research
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