Guide

CO2 reporting for transport companies: what is required in Norway

August 11, 2026
3 min read
CO2 reporting for transport companies: what is required in Norway

Short answer: There is currently no separate legal requirement for small and medium-sized transport companies in Norway to report CO2 emissions. The requirement is coming anyway - through the back door: large customers who are themselves subject to reporting under the Corporate Sustainability Reporting Directive (CSRD) must quantify emissions from purchased transport, and therefore ask their hauliers for figures. And in public tenders, climate and environment must as a rule be weighted at least 30 percent. Hauliers who can document their emissions win contracts. Those who cannot are passed over.

Why are you suddenly being asked about emissions?

Have you received a form from a major customer asking about fuel consumption and emissions per job? You are not alone. The explanation lies not with the customer, but in the rules that apply to the customer.

The EU's sustainability directive CSRD has been incorporated into the Norwegian Accounting Act and requires large enterprises to report on sustainability - including emissions in the value chain, known as scope 3 emissions. Purchased transport is one of the most common and largest scope 3 items. In other words, your customer cannot deliver their own report without figures from you.

The rules are still moving: the EU has postponed the reporting obligation for mid-sized company groups by two years, and simplification work ("omnibus") is under way that raises the thresholds. But the direction is fixed - and the very largest customers are already reporting. For you as a haulier, it is the customer's requirement, not the paragraph in the law, that applies in practice.

Three drivers that hit transport companies

1. Customers' reporting obligation (CSRD). As described above: large transport buyers need emissions figures per supplier - and eventually per transport job. Expect this to go from "nice to have" to a standard attachment in transport agreements.

2. Public tenders. Since 2024, public procurement in Norway must as a rule weight climate and environmental considerations at a minimum of 30 percent. If you drive - or want to drive - for municipalities, counties or state bodies, you are competing on emissions as much as on price.

3. Banks and insurers. The financial sector is increasingly asking climate questions when lending for vehicle purchases and when writing insurance. Documented emissions figures and a plan for fleet renewal make you a better borrower.

ISO 14083: the standard behind the numbers

When customers ask for emissions figures, they want figures that can be compared. The ISO 14083 standard describes how greenhouse gas emissions from transport chains are to be calculated and allocated - per consignment, per tonne-kilometre. This is the methodology that the large transport buyers and their reporting tools are built on.

You do not need to read the standard. But you should know what it means for you: figures worked out "on a napkin" - a flat percentage or an average from the internet - will increasingly be rejected. The figures must be based on actual operations: fuel consumption, kilometres driven and load utilisation.

What you actually need to be able to document

In practice it boils down to three data points per period or per job:

  • Energy consumption: litres of diesel/HVO or kWh, per vehicle.
  • Transport work: kilometres driven and how much load was on board - empty running counts too.
  • Allocation: how the emissions are divided between the individual customers and consignments that shared the vehicle.

The last point is where the spreadsheet gives up. Allocating one vehicle's emissions across fifteen consignments with different weights and distances, every week, all year - that is a job for a system, not a job for the office.

How to solve it without hiring a sustainability consultant

The point of a TMS in this context is simple: the data needed for emissions reporting is largely the same data the system already collects to run operations and invoice - trips, kilometres, load, fuel. That turns the CO2 report into an export, not a project.

Concretely, you should do the following, in this order:

  1. Get the driving data into one system. Without a consolidated basis, everything else is guesswork.
  2. Record fuel/energy per vehicle. Either via fleet management/integration or as a fixed routine.
  3. Ask your system provider to show you the CO2 report. Can it deliver figures per customer and per job, using recognised methodology? If not: ask why.
  4. Send figures before the customer asks. A haulier who attaches emissions figures to the invoice is positioned completely differently in the next price negotiation.

Emissions figures are becoming a competitive advantage

It is easy to see this as yet another imposition. But look at it from the buyer's side: she has to choose between two hauliers with the same price and quality. One delivers documented emissions figures per job; the other replies "we will have to get back to you on that". Which one makes her job easiest?

The next few years will separate hauliers who can document from those who have to improvise. It is cheaper to get started now than to rig everything in a panic when the tender deadline is at the door.

Frequently asked questions

Is CO2 reporting a legal requirement for transport companies in Norway?

Not directly for small and medium-sized hauliers as of today. The obligation rests on large enterprises through the CSRD and the Norwegian Accounting Act - but they pass the requirement down the value chain to their hauliers. In public tenders, however, environmental weighting is already the main rule.

What are scope 3 emissions?

Emissions that occur in an organisation's value chain, but outside its own vehicles and buildings. When a shipper buys transport from you, your emissions are the customer's scope 3. That is why they ask.

What is ISO 14083?

An international standard for calculating and reporting greenhouse gas emissions from transport chains. It ensures that figures from different hauliers can be compared, and has in practice become the common language for emissions in logistics.

Is an average figure for the whole fleet enough?

Less and less often. Customers want figures per job or per consignment, allocated by actual weight and distance. That requires emissions to be calculated from real driving data.

We run HVO on some vehicles - does that count?

Yes, and that is exactly the kind of thing that should come through in the reporting. Renewable fuel gives significantly lower reported emissions, but only if the documentation shows which vehicles and trips actually ran on it.

FleetX calculates CO2 emissions directly from the driving data already in the system - per vehicle, per customer and per job. See how it works.

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