What the CSRD actually asks for

The Corporate Sustainability Reporting Directive has been law for a while. What changed is the deadline. From 2026, the next wave of “large” EU companies (broadly, anyone meeting two of three thresholds: more than 250 employees, over €40 million in net turnover, or over €20 million in total assets) has to report on 2025 activity, including business travel. Not travel policy in the abstract. Actual trips, actual venues, actual numbers.

That reporting obligation sits with finance and sustainability teams on paper. In practice, the person who can actually answer “how many kilometres did our Q3 leadership offsite generate” is whoever ran the event. Usually that is us, or a planner very much like the ones reading this.

We have sat in three of these conversations this year already. Each one started the same way: a client’s sustainability lead emailed asking for a breakdown of flights, ground transport, accommodation nights and catering for a programme we delivered months earlier. We had the data. Most agencies we have compared notes with did not, because nobody had asked them to keep it in a usable format.

There is a second layer stacking on top of the CSRD that fewer planners have clocked yet. The EU’s Green Claims Directive, which member states must write into national law by 27 March 2026 with the rules applying from 27 September 2026, targets loose language like “eco-friendly conference” or “carbon neutral gala” unless the company can back the claim with verifiable data. That matters directly for events, because a lot of event marketing has quietly used exactly this kind of phrase for years, usually without anything behind it.

Put the two together and the practical upshot is simple. Say less, but be able to prove everything you do say. A one line description of an event as “low impact” is now a liability if a regulator, or a journalist, asks for the working.

The scope also widens over time, which planners tend to underestimate. Listed small and medium companies join the reporting requirement on a later timeline than the large companies covered from 2026, and plenty of mid market firms that are not technically in scope this year are already being asked for the same data by larger clients or investors further up their own supply chain. We increasingly see companies well below the formal thresholds requesting event emissions data anyway, simply because a bigger customer or a bank asked them to demonstrate it first.

Why this became an events problem, not just a finance one

Business travel is one of the few CSRD line items a company can actually influence quickly. You cannot restructure a supply chain in a quarter. You can change how many people fly to a kickoff, whether the venue runs on grid electricity or diesel generators, and whether delegates take a coach or forty individual taxis from the airport.

That is why events keep surfacing in these conversations even though nobody in the original CSRD drafting sessions was thinking about incentive trips. A 300 person conference with international flights, three nights in a hotel and a gala dinner is, for a mid sized company, sometimes the single largest travel emissions event of its year. It is visible, it is discretionary, and it is the easiest thing for a board to point at.

Discretionary is the key word. Nobody can easily cancel a client site visit or an audit trip. A leadership offsite, an incentive trip, an annual conference: these are choices a company makes about how to spend money and time, which is exactly why they draw scrutiny first. If a board is looking for a visible, defensible sustainability win to report alongside the harder, slower changes to supply chains and manufacturing, the events calendar is often the easiest place to start.

Munich to Tirana is 2h 10m direct on several carriers; London to Tirana runs under 3 hours. Those numbers matter now in a way they did not two years ago, because a shorter flight is a smaller number on somebody’s spreadsheet, and that spreadsheet gets audited.

It also changes who gets invited to the planning call. Two years ago, sustainability leads were rarely in the room when an events team picked a destination or a venue shortlist. Now they often ask to see the shortlist before anything is confirmed, purely so they are not surprised by the number six months later when the report is due. If your programme touches a company anywhere near the CSRD thresholds, expect that person to show up earlier in the process than they used to.

The numbers a client will now ask you for

We rewrote our own proposal template this year to have this ready before anyone asks. The request usually breaks into five categories, and if your agency cannot hand these over within a day, that is worth knowing before you sign anything.

Category	What gets asked for	Who usually has it
Flights	Origin, destination, class, headcount per route	Travel agent or DMC booking record
Ground transport	Vehicle type, distance, occupancy	DMC logistics sheet
Accommodation	Room nights, hotel energy rating where available	Hotel contract or DMC
Catering	Covers served, menu type (meat heavy versus plant forward)	Venue or caterer
Venue energy	Grid versus generator, certification if any	Venue, rarely volunteered

Venue energy is the one that trips people up. Most venues in Europe can tell you their grid mix if asked directly. Fewer can tell you unprompted, which means it has to be a specific line in your RFP, not an assumption.

None of these five categories require specialist software. A shared spreadsheet, updated as bookings are confirmed rather than reconstructed afterwards from invoices, covers most of what a sustainability team will ask for. The mistake we see most often is treating this as a report to write after the event, rather than a log to keep during it. By the time someone asks in November for a March programme, half the underlying detail has usually been lost with the supplier who handled it.

What we have had to build into our own numbers

We routinely reclaim VAT for clients running events in Albania, and the same administrative habit now applies to emissions data. Every group we move gets a transport log: vehicle, route, distance, passenger count. We started doing this properly three years ago for cost control, long before any client asked about carbon. It turned out to be exactly the record a sustainability officer wants.

A concrete example. Earlier this year we moved 280 delegates across the Adriatic coast in a single afternoon for a pharmaceutical company’s incentive trip, splitting the group between Tirana and Sarandë on coaches rather than a longer chain of transfers and short domestic flights. That single routing decision, coaches instead of a domestic flight leg, was the biggest lever available to us, bigger than any catering choice or hotel selection further down the list.

On accommodation, a 4 star hotel in Tirana during shoulder season runs €85 to €110 a night, noticeably below equivalent programmes in Croatia or Portugal. Lower cost does not automatically mean lower emissions, but it does mean clients have more budget headroom to spend on the parts of the programme, like direct routing or better catering sourcing, that actually move the number.

Durrës and Krujë both host venues we use for smaller breakout sessions, within 40 minutes of Tirana by road, which keeps ground transport short even when a programme splits across sites. Vlorë and Sarandë sit further south, closer to three hours from Tirana by coach, and we only route programmes there when the itinerary genuinely earns the extra travel time, a coastal gala dinner, a diving excursion, something the destination itself is doing the work for.

None of this is unique to Albania. Any DMC operating in a compact country with short internal distances can make the same argument. What we would say, having run this exercise for fifteen years now, is that the discipline of tracking it matters more than the destination. A well documented programme in a higher emissions destination will beat a badly documented one in a lower emissions destination, every time an auditor looks at the paperwork rather than the map.

Cutting the number without cutting the experience

Nobody wants an event that reads like a compliance exercise. The good news is that most of the changes that help a carbon number also make the programme better to attend.

• Consolidate arrivals: booking delegates onto two or three flight windows instead of scattering arrivals across a day cuts both transfers and idle coach time.
• Choose venues that already run efficiently: a hotel with its own conference space beats shuttling delegates to a separate venue twice a day.
• Rethink the gala: a plant forward menu with one strong meat option, rather than the reverse, cuts catering emissions meaningfully and, in our experience, gets better feedback scores.
• Keep the group together: one coach convoy beats a fleet of private cars, every time, on both cost and emissions.
• Extend the stay slightly: adding a half day to justify the flight, rather than flying delegates in and out on the same long day, spreads the fixed cost of travel across more programme value.

None of this requires telling delegates they are attending a smaller or less comfortable event. It mostly means making decisions in the first planning call rather than retrofitting them after contracts are signed.

We had a client last year push back hard on the coach consolidation point, worried it would feel regimented compared with letting people arrange their own airport transfers. We ran both versions side by side across two similar groups. The coach group’s post event survey scores on “logistics and ease of travel” came back higher, not lower, largely because nobody was left waiting alone at an arrivals hall wondering where their driver was. Efficient and pleasant are not always in tension. Sometimes the efficient option is also the one people actually prefer.

Questions to ask your DMC or agency before you sign

If your company is in scope for CSRD reporting this year, or expects to be soon, it is worth putting these questions to any MICE partner before a contract is signed, not after the event.

1. Can you provide a transport log (vehicle type, distance, occupancy) within five working days of the event closing?
2. Do you already ask venues for their energy source, or would that be a new request on our behalf?
3. Can catering orders be broken down by menu type, not just headcount?
4. Have you handled a group transport plan built around minimising vehicle count, rather than maximising convenience?
5. Who on your team owns this data once the event is over, and how long do they keep it?

An agency that hesitates on any of these is not necessarily a bad agency. But it means the reporting burden falls back on your own team, at exactly the point in the year when nobody has time for it.

Worth asking, too, whether the answer changes for a smaller programme. A twenty person board retreat generates far less data than a five hundred person conference, but it still generates some, and the same five categories still apply. Agencies that only have this process built for their largest accounts are worth a second question about how it scales down.

One more practical point that gets missed. Ask when in the process the data gets compiled, not just whether it exists. A log built live, as bookings are confirmed, is far more reliable than one reconstructed from invoices after the fact, because invoices rarely capture occupancy or routing detail cleanly. If your agency’s answer is “we can pull that from the invoices afterwards”, treat that as a partial answer rather than a full one.

The wider point, and the one worth taking away from all of this, is that CSRD compliance for events is mostly a record keeping habit, not a design constraint. Nobody needs to accept a worse conference to hit these numbers. They need a supplier willing to write things down consistently, and a client willing to ask for it before the contract is signed rather than after the invoices land.

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