The questionnaire still arrives. Fourteen pages, a tab for fleet composition, a request for emissions in kilograms per transfer, a box for the supplier's own decarbonisation trajectory. It was calibrated in 2024 against a directive that has since shed something close to nine tenths of the companies it originally captured. Plenty of the firms still sending it have no reporting obligation left to justify it. Plenty of the firms answering it are under no obligation to answer.
What that leaves is more interesting than what it removed. Ground transport and ESG reporting still meet, but they now meet on the buyer's terms instead of a regulator's, and the arguments that were being made on the regulator's behalf do not all survive the move. Three of them do. One does not. Before any of that, though, there is a rule arriving in January 2027 that almost nobody in a Paris procurement team has read.
The rule arriving in January, and what it actually does
Buried in the Omnibus text is a provision the trade press filed under "supplier relief". For financial years beginning on or after 1 January 2027, a company inside the reporting scope may not require a supplier of no more than 1,000 employees to hand over more sustainability information than the voluntary standard for smaller firms contains. That standard, drafted by EFRAG and long known as VSME, was adopted by the Commission as a delegated act on 3 July 2026 under the plainer name of Voluntary Standard, and is now serving its scrutiny period before Parliament and Council.
The cap does not forbid the question. It rearranges who has to answer it. A large client may still ask for more, on condition that it flags which parts exceed the ceiling and tells the supplier, in writing, that it is entitled to decline. That is a smaller change than a prohibition and a larger one than it sounds, because a request a supplier may lawfully refuse is no longer a control. It is a favour. Auditors do not build assurance on favours.
Read from the buyer's side the consequence is blunt. If your business-travel line was going to rest on data extracted from suppliers by questionnaire, that extraction stops being enforceable for every supplier under the threshold, which in Paris ground transport means all of them; the largest chauffeur operators in the city employ in the low hundreds. The luxury houses met this first, because their tenders carried the heaviest environmental sections and their suppliers were the smallest firms around the table. We traced what the February text did to the sustainability clause in maison transport tenders, where it survives as a preference and no longer as a requirement. January puts a ceiling on the preference too.
The order of magnitude that never makes it into the deck
Before deciding what to measure, it helps to know what the measurement is worth. ADEME puts an average petrol car at roughly 214 grams of CO2 equivalent per vehicle-kilometre once fuel production is counted alongside combustion, and a battery-electric car on the French grid at roughly 82 across its whole life, battery manufacture included. Note the asymmetry, because it runs against the electric car: the 214 excludes the factory that built the petrol vehicle, the 82 does not. Even so the French ratio lands around two and a half to one, not the four or five to one that circulates in supplier decks, and the reason is a grid that runs on nuclear power rather than coal.
| Leg, one passenger | Basis | kg CO2e |
|---|---|---|
| CDG to the 8th, 35 km, average petrol car | ADEME, 214 g/km, combustion and fuel production | 7.5 |
| Same leg, battery electric | ADEME, 82 g/km, full lifecycle, French grid | 2.9 |
| Gap between the two fleet choices | Difference between the rows above | 4.6 |
| London to Paris, economy seat, 350 km | ADEME short-haul factor, combustion only | 88 |
| Same flight, radiative forcing counted | ADEME short-haul factor with RFI | 176 |
The gap between the two fleet choices is around five percent of the flight that created the trip, and under three percent once the contrails are counted. Put two executives in the same car and both figures halve. That is the number, and it does not improve by being kept out of the room. Anyone selling a chauffeur service as the environmental lever in a business trip is offering the smallest line in the file and hoping nobody opens the file. The absolute cost of the transfer, incidentally, is easier to defend than its carbon: our breakdown of what a Paris airport transfer should cost puts the CDG run at €105 fixed.
So the tonnage argument fails. What replaces it is an argument about method, and it happens to be the stronger of the two, because it applies to the whole travel line and not to its last thirty-five kilometres.
What an assurance provider tests is the method, not the mass
The GHG Protocol accepts three ways of computing business travel: fuel-based, distance-based, spend-based, in descending order of precision. Audit practice puts the error on spend-based estimation somewhere between forty and sixty percent against actual fuel burn. That is the sort of range a first filing survives if the method is disclosed, and the second filing does not.
Most companies compute business travel from expense lines, because expense lines are what a finance system already holds. That is spend-based by construction. A euro amount and a date do not become distance data by being sorted more carefully.
A supplier that invoices per journey, with route, distance and vehicle class attached to each line, moves that part of the calculation off the weakest method and onto the middle one. More usefully, a supplier organised to do it for the car is usually organised to do it for everything else the account touches, since the same booking record carries the flight reference and the hotel booking. The gain in method does not stop at thirty-five kilometres.
An app receipt carries a price and a timestamp. Whatever car turned up, the figure that reached the ledger was money, and money feeds the method nobody defends twice. This is the part of the audit that moves companies off platform accounts that owes nothing to service quality and survives every argument about price.
What the S in ESG actually covers here
Of the three letters, the second is the one that holds up best under questioning, and it is the one nobody puts in the pitch. French employment law places an obligation de sécurité on the employer, a duty of care set out at article L. 4121-1 of the code du travail, and it does not lapse at the office door when the employer is the one arranging the journey. What that duty needs, the day something goes wrong, is a file: vehicle inspection records, the driver's carte VTC (the professional licence every French chauffeur must hold), the professional liability cover, a named contact, a written escalation path and the hour it was followed. A contracted supplier produces that on request. A platform account produces a receipt and a support ticket.
A symmetrical error runs the other way, and procurement teams make it constantly. The guaranteed minima cited as evidence of decent conditions in French ride-hailing, thirty euros per hour of activity, nine euros net per trip, one euro net per kilometre, come from sector agreements signed in December 2023 and homologated in March 2024, and they bind connection platforms. "Hour of activity" is itself narrower than it sounds: ride time plus approach time, not time logged in and waiting. These floors describe the platform market. They say nothing about what a chauffeur company pays its own drivers, which is either a salary under a collective agreement or a directly negotiated commercial rate. Ask a non-platform supplier whether it respects the ARPE floors and you will collect a yes to a question that does not apply to it.
The questions that do apply are duller. How many drivers on this account are employed and how many subcontracted. What last year's driver turnover was. Whether the same driver covers a recurring route. What a Paris chauffeur actually earns, and under which structure, is a supply-chain question with an answer, which is more than can be said for most of the fourteen pages.
Where your executives' movement data is processed
A ground transport booking file is not a neutral record. It lists who was collected from where, at what hour, and taken to meet whom. Across a year it holds home addresses, patterns of absence, and the shape of every negotiation the company conducted in person.
For a listed company in a live transaction, that file is price-sensitive information sitting in a third-party database. Where it is processed, under which jurisdiction, and who can compel its production is a governance question well before it becomes a privacy one. A supplier holding the booking in France, able to state the retention period in a sentence, is answering something a platform headquartered outside the Union answers with a policy document and a set of standard contractual clauses. Both answers can be compliant. Only one of them is short, and shortness is what a board committee is buying. The practice is furthest developed in the profession with the most to lose, which is why the way Paris law firms handle client movement reads like a data protection protocol with cars attached.
Two dated deadlines, and one that refuses to be dated
The value chain cap bites on financial years opening from 1 January 2027, and it arrives by delegated act, directly applicable, without waiting for anybody's parliament. France separately has until 19 March 2027 to transpose the Omnibus itself, which is when the domestic thresholds move. The two are easy to confuse and they are not the same mechanism.
The third has no date. Inside the low-emission zone, the 77 communes enclosed by the A86, Crit'Air 3 vehicles are barred on weekdays between 8am and 8pm, and the Métropole du Grand Paris runs 2026 as another year of checks without fines. Sanctions are not expected before 2027, largely because the plate-reading enforcement is not ready. The ZFE calendar as it now stands is the one item on this list that touches the vehicle instead of the paperwork.
Which makes the next four months unusually cheap. Nobody is auditing the travel line, nobody is issuing fines over a windscreen sticker, and moving an account from expense reconstruction to invoiced distance data is a procurement conversation, not a capital decision. Do it this autumn and the 2027 financial year, the first that will be filed under the new regime, is covered by activity data from its opening day. Wait, and year one gets filed on spend-based estimates and year two gets spent explaining them.
Falling out of scope, incidentally, does not stop the questions. Banks ask. Insurers ask. Customers ask hardest of all, because a large customer still inside the scope needs something from its suppliers and the cap now tells it exactly how much it may require. The voluntary standard is becoming the common denominator by default, not by decree.
The case has quietly inverted. For three years the argument for a documented ground transport supplier was borrowed: the buyer relayed a demand that had arrived from above, and the supplier answered a question the buyer had not written. February removed the demand for most of the companies it applied to, and January hands the supplier a right to decline what is left. What survives is the part that was always true and almost never the reason anybody signed. An invoice with kilometres on it beats an invoice with a price. A driver with a file beats a screenshot. A booking held in France is a shorter conversation than a booking held elsewhere. None of that is an emissions argument, and the emissions argument, told honestly, is a five percent line in a document where the flight is the document. Firms that bought a chauffeur service to look serious about carbon bought the wrong thing for a defensible reason. What they should have been buying is duller, cheaper to verify, and still standing now that the directive has lost nine tenths of its reach.
PrivateDrive runs corporate accounts in Paris on fixed rates confirmed at booking, with consolidated monthly invoicing and per-journey distance and vehicle data in a format a sustainability team can use without rework. CDG transfers from €105, hourly hire from €85/h. Open a corporate account →