CSRD for Travel Agencies: What to Do About Indirect (Scope 3) Emissions

Travel agencies and tour operators often face one of the most common sustainability questions under the Corporate Sustainability Reporting Directive (CSRD):

“If we don’t own the planes, coaches, or hotels, how do we report the emissions linked to travel?”

The answer lies in understanding Scope 3 emissions — indirect greenhouse gas (GHG) emissions that occur in your value chain rather than from your own operations.

This guide explains how SME travel agencies can address Scope 3 emissions under the Voluntary Sustainability Reporting Standard for SMEs (VSME), what level of detail is expected, and how to report responsibly without overcomplicating your sustainability disclosure. If you’re new to emissions reporting, review what counts as Scope 1 vs Scope 2 first, or see the step-by-step guide to reporting Scope 1 and 2 emissions.

What Are Scope 3 Emissions?

The GHG Protocol, followed by CSRD and VSME, divides emissions into three categories:

For travel agencies, Scope 3 typically represents over 95% of total emissions — but that doesn’t mean you must measure every kilometre or passenger exactly.

What CSRD and VSME Expect from Travel Agencies

Under VSME Basic Module B3 – Energy and Greenhouse Gas Emissions, SMEs must disclose:

• Total energy use and direct (Scope 1 & 2) emissions;
• And, optionally, Scope 3 emissions if material or readily available.

Because travel agencies’ business models depend on outsourced services (flights, hotels, transfers), Scope 3 is material — but data quality may be low.

The CSRD allows proportionality: SMEs should report qualitative and estimated information when precise data isn’t available.

Step-by-Step: How to Approach Scope 3 Emissions as a Travel SME

Step 1 – Map Your Value Chain

Identify where emissions occur in the services you sell. Typical categories include:

• Flights and rail travel booked for clients
• Coach and car transfers
• Hotel stays and meals (especially if you bundle accommodation)
• Business travel by staff
• Purchased goods and services (IT systems, marketing materials)

Make a short list of the main emission hotspots — for most agencies, these are flights and accommodation.

Step 2 – Focus on Influence, Not Ownership

Under CSRD’s double materiality principle, you report impacts that are significant — even if they happen outside your direct control.

You’re not responsible for airlines’ or hotels’ emissions, but you enable or influence them through your choices.

Example:

A travel agency specialising in eco-tours can reduce Scope 3 emissions by promoting train travel over short-haul flights.

Include this influence in your VSME B2 (Practices and Policies) disclosure.

Step 3 – Estimate Emissions Using Reliable Sources

If you can’t obtain exact supplier data, use reputable databases or calculators:

Example estimate:

1,000 client flights (average 1,500 km × 0.15 kg CO₂e/km) = 225 tCO₂e 4,000 hotel nights × 15 kg CO₂e/night = 60 tCO₂e Total estimated Scope 3: 285 tCO₂e

That’s enough to identify your major sources and track year-on-year progress.

Step 4 – Report Qualitatively if Quantification Is Impossible

If you don’t have access to reliable data, describe your approach instead. Example wording for your VSME report:

“As a travel agency, we do not own or operate transport or accommodation facilities. We monitor Scope 3 emissions using public emission factors for flights and hotels and work with low-carbon suppliers where possible.”

This satisfies VSME’s proportional disclosure requirement.

Step 5 – Engage Suppliers and Partners

Many airlines, hotel chains, and transport companies now offer emissions data per booking or night. Ask them for:

• CO₂ per passenger-km (flights, trains, buses)
• CO₂ per room night (hotels)
• Renewable energy share (tour operators, resorts)

You can include a short policy statement:

“We prioritise suppliers that report carbon emissions and commit to Science Based Targets or equivalent frameworks.”

Step 6 – Include Scope 3 in Your VSME B3 Table

Narrative:

“Scope 3 emissions mainly arise from client travel. We estimate total indirect emissions at 285 tCO₂e in 2024 and aim to reduce them through supplier engagement and customer education.”

What Not to Do

• ❌ Don’t claim “zero emissions” unless offsets or verified reductions exist.
• ❌ Don’t ignore Scope 3 if it’s clearly material to your business model.
• ❌ Don’t overstate accuracy — use clear disclaimers if estimates are used.

Transparency matters more than perfection.

Step 7 – Communicate with Clients

CSRD encourages value chain transparency. Travel agencies can help clients choose greener options:

• Label itineraries with estimated emissions.
• Offer train alternatives for regional travel.
• Promote certified sustainable accommodations.
• Share reduction goals publicly on your website or in your sustainability statement.

This approach both reduces emissions and enhances your brand credibility.

Example Disclosure Summary (VSME + CSRD Alignment)

Practical Tips for SMEs

• Start small — estimate Scope 3 for your top three suppliers or destinations.
• Keep a simple Excel model for calculations and update yearly.
• Use consistent assumptions (same distance factors, same room-night estimates).
• Document all sources for verifiability.
• Collaborate with tourism boards or trade associations for shared data.

Example: Boutique Travel Agency

Company: GreenPath Journeys Focus: Eco-tours and small-group travel Highlights:

• Scope 3 emissions: 190 tCO₂e (client travel and stays)
• 60% of hotels used renewable electricity
• Introduced “train-first” booking policy for European destinations
• Reduction target: –15% emissions intensity by 2026

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Scope 3 emissions: Indirect emissions from supply and value chains
• Double materiality: Reporting on how sustainability affects your business and how your business affects the environment
• Emission factors: Standardised values (e.g. kg CO₂e/km) used to estimate emissions
• ESRS E1: European Sustainability Reporting Standard on Climate Change

Use our interactive calculator to estimate emissions from the travel services you provide:

The calculator uses standard DEFRA 2024 emission factors for flights, trains, cars, and hotels, providing a detailed breakdown with personalized recommendations.