Scope 3 Category 7: measuring commuting emissions for BRSR

Employee commuting is one of the more awkward lines in a corporate carbon inventory. It is large enough to matter, it sits outside the company's direct control, and it is usually estimated from a survey that a fraction of staff bother to fill in. For an Indian company reporting under BRSR, there is a better way to produce that number, and it starts with understanding exactly where the line sits.

Why commuting is Scope 3, and specifically Category 7

The GHG Protocol splits a company's emissions into three scopes. Scope 1 is what the company burns directly, such as fuel in its own vehicles. Scope 2 is the electricity it buys. Scope 3 is everything else in its value chain, the emissions it is responsible for but does not own, and the Protocol divides Scope 3 into fifteen categories. Employee commuting is Category 7.

That placement is worth being precise about. Moving your staff to work is not a tailpipe emission from a company car, which would be Scope 1. It is the footprint of getting people to their desks, and it belongs in Scope 3 Category 7 whether the ride is a company-arranged bus, a private car or a shared cab.

Where BRSR actually requires it

India's Business Responsibility and Sustainability Reporting framework, mandated by SEBI, is where most large Indian companies now disclose this. It is worth stating the position carefully, because overclaiming the rules is the fastest way to lose the one reader who knows them better than you do.

The full BRSR report is required from the top 1,000 listed companies by market capitalisation. Within it, SEBI has defined a tighter set of assured indicators called BRSR Core, and the requirement to have them independently checked has been phased in by market-cap band:

Financial year	BRSR Core assurance or assessment applies to
FY 2023-24	Top 150 listed entities
FY 2024-25	Top 250 listed entities
FY 2025-26	Top 500 listed entities
FY 2026-27	Top 1,000 listed entities

From 2025, SEBI also softened the requirement from mandatory "reasonable assurance" to a choice between assurance and a lighter "assessment" route. Employee commuting itself sits under the BRSR Leadership Indicators, the voluntary tier, rather than the mandatory core. So for most companies today, reporting a commuting number is a choice, not a legal obligation.

The real pressure is rarely the letter of the regulation. It is investors, CDP questionnaires, and multinational parents pulled into CSRD-style expectations, all of whom increasingly want a defensible number rather than a blank or a guess.

Why the survey approach struggles

The standard method is a commuting survey: ask employees how they travel, how far and how often, then gross the sample up to the whole workforce. The trouble is the response rate. A survey that reaches a fraction of staff and is then extrapolated carries all of that uncertainty into the disclosure, and an assurance provider knows it. Survey-based commuting figures are among the most likely to attract a qualification.

The method, when the trips are measured

If a company runs managed employee transport, the inputs stop being estimates. Distance is the metered trip kilometres actually driven. Energy is the kilowatt-hours recorded charging the vehicles. Both are primary data. The reported figure is then straightforward:

Reported emissions = grid emission factor × energy used.

For the electricity that charges an electric fleet, the grid emission factor comes from the Central Electricity Authority's CO2 Baseline Database. Its latest version puts the all-India grid factor at about 0.71 tonnes of CO2 per megawatt-hour, a figure that has been falling year on year as renewables enter the grid. Using the published national factor, and stating so, is more defensible than an unsupported number.

The avoided figure, the "that did not happen" number, needs a counterfactual: what the same journeys would have emitted in a comparable diesel vehicle. That baseline should be stated, not flattered, because an inflated baseline inflates the avoided number, which is exactly the overstatement assurance is designed to catch.

Draw the boundary, and show it

A commuting number is only trustworthy when its edges are visible. A managed-transport figure covers the trips the operator runs. It should not silently absorb the commuting your people do outside that service, personal vehicles, other modes, trips nobody measured, and present a partial figure as a total. The honest statement names the boundary on the face of the report, so the scope of the number is never in doubt.

What good looks like on the page

A commuting-emissions statement your sustainability team can hand to an assurer, or drop into a BRSR Leadership Indicator, has a few plain features:

• Distance and energy shown as measured primary data, not a sampled estimate.
• The grid factor named, with its source and version.
• The baseline for any avoided-emissions claim stated openly.
• The boundary written on the statement itself.
• A published, versioned method behind the arithmetic, so any line can be checked.

None of this is complicated. It is simply the difference between a number you can defend and a number you hope nobody examines.