A sustainability officer at a logistics company outside Rotterdam told me last month that she had spent the better part of two weeks trying to reconcile fuel purchase records with telematics data for a fleet of about 140 trucks. The numbers did not match. They never do, she said, but until this year, nobody with actual authority over the company’s financial disclosures had cared enough to ask why. What changed is that her company fell into the second wave of CSRD reporting, and the audit committee wanted to see Scope 1 transport figures that could survive third party assurance. She had been sending emissions estimates to the sustainability report for three years. Nobody on the board had ever questioned the methodology. Now somebody was questioning it, and she did not have answers that would hold up.
This is happening across European logistics and distribution right now, and most of the people I talk to in fleet operations are somewhere between annoyed and alarmed about it. The Corporate Sustainability Reporting Directive started biting for the largest companies in the 2024 reporting year, and the second wave, which, after the Omnibus I narrowing pulls in companies above 1000 employees and 450 million euros in turnover, files in 2028 on fiscal year 2027 data. That means the data collection should already be running. For a lot of companies, it is not. Scope 1 covers every liter of diesel your trucks burn, and EFRAG wrote the ESRS E1 standards with teeth. A single fuel bill and a conversion factor do not cut it anymore. They expect vehicle level breakdowns by fuel type and route, and they expect someone other than the fleet manager to be able to find the source file. I talked to an auditor in Amsterdam last month who told me the first thing he does now is ask a company to pull up their Scope 1 source data while he watches. Half the time, nobody in the room knows where it is stored.
I spent an afternoon with a fleet controller in Hamburg, who showed me what his emissions reporting process actually looks like, and it was not encouraging. He has telematics on every truck. Knows where they are, knows how fast they are going, and gets CAN bus readouts on about 60 percent of the fleet. None of that got him anywhere near what sustainability needed. What they actually asked for was fuel consumption per vehicle per route per day with methodology notes, and he told me his telematics system has never once produced anything close to that without someone manually stitching it together. He spent weeks on it. GPS logs against fuel card receipts, then cross referencing tank sensor readings on the trucks that had them, then trying to account for the days when a driver paid cash at a station in Poland or when a unit went offline for three days and left a gap in the data. Duplicate entries kept inflating the numbers on certain routes, so he had to go through those line by line, too. The whole mess then had to go into something a big four auditor would not immediately reject. His word for it was that it felt like assembling furniture from two different boxes that got mixed together at the warehouse. His company has 140 trucks. I asked what happens to the companies with 500. He just shook his head.
There is a separate problem building underneath all of this that almost nobody in fleet ops has noticed yet, and it involves the AI Act. Most telematics platforms now run some kind of machine learning. Driver scoring, predictive maintenance scheduling, and route suggestions. A few of the fleet managers I know use those driver scores to set quarterly bonuses. At least two companies I am aware of feed safety alerts from the telematics system directly into their disciplinary process. Once you are doing that, you are probably in Annex III high risk territory, whether you realize it or not. The conformity assessment obligations are not theoretical. Companies are supposed to be documenting their AI governance right now, before full enforcement hits. I asked about fifteen fleet managers at a conference in Düsseldorf last month whether anyone had spoken to their legal team about AI Act classification for their telematics. Not one hand. I remember looking around the room, thinking somebody would at least say they had it on a list somewhere. Nothing. And here is the part that gets me. That same driver behaviour data, the stuff that is about to cause all this compliance work, is also quietly responsible for the best emissions numbers these companies have ever reported. Smoother driving means the trucks burn less. Simple as that. Scope 1 goes down. And the accident rate drops too because fewer hard stops and less speeding means fewer crashes, and that feeds into workforce safety under ESRS S1 and S2. Two separate reporting obligations served by the same data. That actually matters, but only if you can show an auditor and an AI compliance reviewer that the data behind both numbers is governed properly. Most companies are nowhere close to being able to do that.
Every CFO I have talked to about this eventually asks the same thing. Do we build the data pipeline ourselves, or do we pay someone else to do it? Neither answer is comfortable. Building it in house means you need people who understand telematics data and sustainability reporting at the same time, and good luck hiring them because there are maybe a few hundred people in Europe with that combination, and most of them are not looking. An operations director at a GPS server provider mentioned that roughly a third of their enterprise clients started requesting CSRD formatted exports last summer. A year earlier, the number had been close to zero. What surprised him was who was making the requests. Almost none came from the fleet. It was finance people and sustainability officers who had never logged into the telematics dashboard before in their lives. Outsourcing the pipeline to a platform gets you past the technical bottleneck, but it raises questions that auditors are trained to ask. Like, who actually holds three years of historical data if you walk away from the contract? Or whether anyone outside the vendor’s own team can look at the calculation methodology and tell you if it holds up. I sat in on an audit prep meeting in March where the external reviewer spent twenty minutes asking about data portability before he even opened the emissions file.
A guy running the numbers at a mid sized distributor outside Lyon told me his team burned four months and about 180000 euros reconciling their 2025 Scope 1 transport data by hand. Spreadsheets, manual matching, the whole painful process. Then somebody from the sustainability department wandered over one day and said hey, you know the telematics system has an API that does most of this automatically, right. Fleet ops had known about it for years. Nobody on the finance side had ever thought to ask. I wish that story were unusual, but I have heard it in some form at five or six different companies this year alone. The fleet people are sitting on exactly the data that the governance people have been scrambling to produce, and the two groups just do not talk. The fix, when it happens, is always the same. Someone senior enough to matter, a CFO or a head of audit, takes an hour out of their week and goes to the fleet office and asks to walk them through what you have. It sounds like such a small thing. Almost nobody has done it.
