In short
- The test is headcount per KvK number on 1 January of the reporting year, and only staff contracted for at least 20 paid hours a month count.
- The binding threshold is still 100 employees. The approved move to 250 was not in the Staatsblad on 28 August 2026, so it does not get you out yet.
- Being in scope means filing kilometres by mode and fuel to RVO by 30 June. It does not mean holding a carbon footprint.
WPM applies to you if one thing was true on one day. If your onderneming or rechtspersoon is registered in the KvK handelsregister and had 100 or more employees on 1 January of the reporting year, you are in scope and you file. That is the entire test. It is assessed per KvK number, fresh each year, and only staff contracted for at least 20 paid hours a month are counted. The threshold is still 100, not 250, whatever you have been told. If you are in, you submit kilometres to RVO by 30 June.
WPM is the rapportageverplichting werkgebonden personenmobiliteit, the Dutch reporting obligation for work-related personal mobility. It has been in force since 1 July 2024 and it sits in afdeling 18.1 of the Besluit activiteiten leefomgeving, the decree on activities in the physical environment.
What is the exact test?
Two conditions, and nothing else.
Condition one: registration. You are an onderneming or a rechtspersoon registered in the KvK handelsregister, the Dutch chamber of commerce register. A company established outside the Netherlands is in scope only where its Dutch branches together reach the threshold.
Condition two: headcount on 1 January. You had 100 or more employees on 1 January of the reporting year. Not an average across the year, not headcount at year end, not full-time equivalents. A single date.
Two details do most of the damage when people get this wrong. The count is per KvK number, not per group, so sister companies with separate registrations each run their own test and each file their own report, while several sites under one KvK number are one filing. And the test is rerun every year, so an organisation that grows past 100 during a year is in scope for the following reporting year rather than immediately.
There is no sector test, no turnover test and no vehicle test. A hospital, a wholesaler and an engineering consultancy with the same headcount are treated identically.
Which people count toward the 100?
Only those on your own payroll with a real contract of a real size.
An employee counts if they are contracted for at least 20 paid hours a month under an arbeidsovereenkomst, a contract of employment, or a publiekrechtelijke aanstelling, a public law appointment. Below 20 paid hours a month, they do not count.
| Counts toward the threshold | Does not count |
|---|---|
| Employees on an arbeidsovereenkomst with 20 or more paid hours a month | Uitzendkrachten, agency workers |
| Civil servants on a publiekrechtelijke aanstelling with 20 or more paid hours a month | Gedetacheerden, secondees from another employer |
| Part-time staff who clear the 20 hour floor | ZZP'ers, self-employed contractors |
| Staff at any Dutch site under the same KvK number | Volunteers and interns |
| Dutch branches of a foreign company, added together | Oproepkrachten, on-call staff |
| Anyone contracted for fewer than 20 paid hours a month |
This is why organisations with a large flexible workforce can sit just under the line while feeling much bigger, and why a payroll export is a better starting point than an HR headcount slide.
Does the pending 250-employee threshold get you out?
Not yet, and this is where most current advice is out of date.
The Dutch cabinet approved a wijzigingsbesluit replacing "minder dan 100 werknemers" with "minder dan 250 werknemers" in the Besluit activiteiten leefomgeving. Its own text gives it retroactive effect to 1 January 2026, which would make 2025 the last reporting year for anyone below 250.
It is not in force. The internetconsultatie ran from 2 February to 9 March 2026, the Ministerraad approved it on 24 April 2026, it was laid before both chambers from 24 April to 1 July 2026, and it went to the Raad van State for advice on 19 May 2026, and the Raad van State gave its advice on 10 September 2026. As of 17 September 2026 it had still not appeared in the Staatsblad, the official Dutch legal gazette. In an answer to parliamentary questions, the state secretary has put the intended entry into force at the end of 2026, retroactive to 1 January 2026, but intended is not the same as published, and a decree enters into force the day after Staatsblad publication and not before.
The practical consequence is blunt. Every employer with 100 or more employees on 1 January 2025 had to file for 2025 by 30 June 2026, including those with 150 or 200 staff who had already read that they were exempt. Before you treat yourself as out of scope for a later year, check the Staatsblad and the RVO page rather than a summary.
What do you do if you are in scope?
You collect kilometres, not carbon.
The report covers total kilometres travelled in the calendar year for commuting and for business travel, subdivided by combination of travel mode and fuel type, for example car-petrol and car-diesel. Freight, flights, ship travel and journeys entirely outside the Netherlands are excluded. It is submitted through RVO's online form on Mijn RVO and eLoket, using eHerkenning at level eH2 or above, by 30 June for the preceding calendar year.
Note who checks. You file with RVO, but the enforcing authority is the bevoegd gezag, the competent authority, which in practice is the omgevingsdienst, the regional environmental agency for the area where your head office sits. It retrieves your report from eLoket and checks compliance. Extensions are requested from the omgevingsdienst, not from RVO.
The useful part is that this dataset is not single-use. Commuting and business travel kilometres map almost exactly onto GHG Protocol scope 3 category 7 and category 6, so the survey that answers WPM is the survey that answers a large part of a scope 3 inventory. If you are heading toward a voluntary standard anyway, our explainer on the VSME standard shows where that data lands next.
What do you do if you are out of scope?
Nothing, legally. Something, commercially, if your customers ask.
If you were under 100 employees on 1 January, WPM does not touch you and no filing is due. That does not mean the data question goes away. Dutch buyers increasingly ask suppliers for travel and commuting figures inside procurement processes, and a smaller organisation with a clean commuting picture answers those faster than a larger one without. Where the questions start to exceed what a customer can reasonably require, our note on the value chain cap on ESG questions is the boundary to know.
If you are also bidding for Dutch public work, the instrument that actually moves money is not WPM but the CO2-Prestatieladder, which is voluntary certification with a procurement advantage attached.
Where does Hedgehog fit, and where does it not?
Only on the data side, and only partly.
The Hedgehog platform handles entity management across locations and sites with roles for data owners, auditors and managers, which matters when the WPM test is run per KvK number and one group holds several. It carries over 20,000 spend-based and activity-based factors that you can supplement with your own data, and the platform page reports 5,000+ users. A free account needs no sales call.
The limitation to say out loud: a small business reviewer on G2 in August 2026 rated the platform 5 out of 5 and still said that loading data is manual and takes effort, and that once loaded it works well. Commuting data is the clearest example of that, because it starts as a survey of your own staff and no system can invent it for you. Budget the collection time rather than the software time.
If the harder work is deciding boundaries and turning the same travel data into a defensible inventory, that is carbon footprint consulting rather than a filing question.
Sources: RVO rapportage WPM and its veelgestelde vragen, Stb. 2023, 472, afdeling 18.1 Besluit activiteiten leefomgeving, the ontwerp-wijzigingsbesluit and nota van toelichting of April 2026, Wetgevingskalender WGK028577, Hedgehog platform, Hedgehog on G2. Verified 28 August 2026.
Facts on this page were last verified on 2026-09-17.
