Why EV Fleets Still Have a Carbon Footprint to Report

Why ESG Reporting is on Your Radar

The EU has a law requiring larger companies to publicly report their climate impact, including emissions from their vehicle fleet. The list of companies legally required to do this just got a lot shorter: a 2026 update raised the bar to roughly 1,000 employees and €450 million in revenue, so many mid-sized fleets that expected to be on the hook are no longer required to report.

That said, being under the threshold doesn't make the question go away. Larger customers and lenders who are still required to report often ask their smaller suppliers for the same emissions data anyway, since they need it to fill in their own numbers.

_{Source: EUR-Lex, EU sustainability reporting rules (CSRD and its 2026 update)}

What You May Not Know About ESG Reporting

Carbon accounting splits a company's emissions into three scopes. Scope 1 covers direct emissions the company creates itself, like diesel burned in a van that hasn't gone electric yet. Scope 2 and Scope 3 are where things get less obvious, because that's where electricity comes in, and here's the part that isn't obvious: the same kilowatt-hour of electricity gets counted differently depending on where the vehicle was plugged in.

Charge a van at your own depot, using electricity your company pays for directly, and that counts as your company's own energy use. In carbon accounting language this is called Scope 2. 

Have an employee charge a company car at home overnight, or a driver top up at a random public charger, and that electricity was never something your company directly bought or controlled. It still counts toward your total footprint, but it lands in a much broader, messier bucket called Scope 3, the catch-all for everything in your value chain that isn't your own direct energy use.

What does that mean?

Two vans doing the same job, using the same amount of electricity, can end up filed completely differently, purely based on where they charged. This is also a genuinely unsettled area: even the industry groups that write guidance on this admit some of the edge cases (like charging on a roaming network, or at a partner's site) still don't have a clean, agreed-upon answer.

This is exactly where visibility into your own energy use starts to matter. If your charging setup already tells you, for every session, where it happened and who controls that site, making the Scope 2 versus Scope 3 call becomes a lookup instead of a guess made months later from patchy records. 

Smappee's chargers, feeding data into its energy management system, already capture that context for every session, since cost splitting and load management depend on knowing it too, and that's what makes correct classification possible in the first place.

_{Source: Smart Freight Centre, guidance on reporting EV charging emissions}

How the Actual Number Gets Calculated

Once you know which bucket a charging session belongs in, the number itself comes from a simple formula: kilowatt-hours used, multiplied by how dirty the electricity was. But "how dirty" can be measured two different ways, and they can give very different answers for the exact same charging session.

The first way looks at the actual grid the vehicle was plugged into and uses its average mix of coal, gas, wind, solar, and so on. The second way looks at what your company specifically paid for, so if your depot has a contract for renewable power, you can count that electricity as much cleaner, even though the physical grid outside didn't change at all.

There's a lever hiding in that formula that's easy to miss: smart charging doesn't just make the number easier to report, it can genuinely lower it. 

Grid carbon intensity moves throughout the day as the mix of wind, solar, gas, and nuclear generation shifts, so charging the same van at 3pm and at 3am on the same grid can produce meaningfully different figures under the location-based method above. 

Research confirms this mechanism works, but with a catch

Charging shifted purely for cost or grid-capacity reasons doesn't automatically lower emissions. It only helps when that shifted window is also a genuinely cleaner one on the grid, not just a cheaper or quieter one. The two often line up, but not always.

There's a more direct version of this that doesn't depend on guessing the grid's mood: charging straight from on-site solar. 

For a depot or site with its own solar panels, every kilowatt-hour drawn from that solar output instead of the grid carries no grid emissions factor at all, under either calculation method above. 

Smappee's energy management system can prioritise EV charging around on-site solar generation, so fleets with solar on site can shift more of their charging to when the sun is actually producing, not just to whenever the tariff happens to be cheapest.

_{Source: GHG Protocol, official guidance on the two accounting methods, EurekAlert, research on carbon-aware EV charging}

Frequently Asked Questions: ESG Reporting for EV Fleets

Does my company have to report emissions from EV charging?

Only if it meets the EU's CSRD thresholds, roughly 1,000 employees and €450 million in revenue. Below that, you may still be asked for the same data by larger customers or lenders who do have to report.

_{Source: EUR-Lex, EU sustainability reporting rules (CSRD and its 2026 update)}

Is charging at home Scope 2 or Scope 3?

Usually Scope 3, since the company doesn't directly control or pay for that electricity. Charging at a company-owned depot is usually Scope 2, though some edge cases like roaming networks still don't have a clean, agreed-upon answer.

_{Source: Smart Freight Centre, guidance on reporting EV charging emissions}

What's the difference between location-based and market-based reporting?

Location-based uses the average emissions of the local electricity grid. Market-based reflects what your company specifically paid for, such as a renewable power contract. Companies are generally expected to report both figures.

_{Source: GHG Protocol, official guidance on the two accounting methods}

Can smart charging actually lower my company's emissions, not just make reporting easier?

General cost-based smart charging alone doesn't reliably reduce emissions, it needs to specifically target cleaner electricity. The clearest way to do that is charging directly from on-site solar, which avoids grid electricity, and its emissions, entirely for that portion of energy.

_{Source: EurekAlert, research on carbon-aware EV charging}

What This Means For You

None of the above can be figured out from a single electricity bill at the end of the year. It depends on knowing, for every charging session: how much energy was used, when, and whether it happened at a site your company controls or somewhere else. That happens to be the same data most fleet charging platforms already collect for entirely different reasons, like managing load or splitting costs between drivers, so the gap for carbon reporting is rarely the underlying data. It's usually just tagging where each session happened clearly enough to sort it into the right accounting bucket.

One more piece is worth factoring in, further up the chain: buying charging hardware is itself a purchase, and purchases show up somewhere in a buyer's own footprint, under the Scope 3 category that covers purchased goods and services. 

A supplier that documents and works to reduce its own footprint makes that slice of a customer's reporting both easier to source and, generally, smaller to begin with. 

Smappee's Sustainability Efforts

Smappee publishes its own Carbon Footprint Report and a separate EV Product Footprint Report for its chargers, works from a public Environmental Policy, and is a signatory to the UN Global Compact, so that upstream part of the picture is already documented rather than something a customer has to chase down themselves.

_{Source: Smappee, ESG and sustainability commitments}