Carbon Reporting for Staffing and Recruitment Agencies
Carbon Reporting for Staffing and Recruitment Agencies
Staffing and recruitment agencies are now receiving carbon data requests from enterprise clients — and many are surprised. "We just provide people, not products" is a common reaction. But staffing firms do have a carbon footprint, and it is dominated by Scope 3, specifically employee commuting and business travel.
Why Staffing Agencies Are Being Asked for Carbon Data
Your clients are reporting under CSRD and need Scope 3 Category 2 (capital goods) and Category 1 (purchased services) data from significant suppliers. A large staffing contract can represent millions in annual spend — significant enough to appear in a client's material supply chain emissions. The emissions they are asking for are your agency's operational emissions, not the commuting of workers you have placed (that is the client's Scope 3 Category 7).
The Emission Profile of a Staffing Agency
| Source | Scope | Notes |
|---|---|---|
| -------- | ------- | ------- |
| Office electricity | 2 | Head office, branch offices, remote worker home offices |
| Office gas | 1 | If offices have gas heating |
| Company car fleet | 1 | Sales consultants and account managers |
| Business travel | 3 (Cat 6) | Client site visits, candidate interviews, conferences |
| Employee commuting | 3 (Cat 7) | Your agency staff (not placed workers) |
| Waste (offices) | 3 (Cat 5) | Shredded documents, general office waste |
Placed Worker Commuting: Not Your Scope 3
A common misconception: staffing agencies sometimes include the commuting of placed temporary workers in their Scope 3 Category 7. Under the GHG Protocol, Category 7 covers the commuting of your own employees — the people on your payroll. Temporary workers under assignment are on the host employer's payroll (or on an intermediary payroll for tax purposes) and their commuting to the host site falls within the host employer's Scope 3. You do not need to include it.
If placed workers remain on your payroll (common in agency staffing), some frameworks include their commuting within your Category 7. In practice, most SME procurement questionnaires accept commuting estimates for your office/desk headcount only.
Calculating Commuting Emissions for Office-Based Staff
For a typical recruitment agency: - 30 consultants, average commute 18 km each way, 230 working days/year - Mixed transport: 60% car (petrol), 30% rail, 10% other - Car commuting: 30 x 0.6 x 36 km x 230 days = 149,040 km x petrol factor = approximately 4.2 tCO2e - Rail commuting: 30 x 0.3 x 36 km x 230 days = 74,520 km x 0.035 kgCO2e/km = approximately 2.6 tCO2e - Total commuting: approximately 7–8 tCO2e/year
Business Development Travel
Sales-intensive agencies with high client visit frequency can accumulate significant Category 6 emissions. A senior consultant flying to 8 European client meetings per year generates roughly 2.5–3.5 tCO2e in short-haul air travel. Ten consultants with similar travel patterns = 25–35 tCO2e/year — often larger than all office energy combined.
Generating Your Carbon Passport
DeCarbonOPS covers all the operational Scope categories relevant to staffing agencies: Scope 1 office gas and company vehicles, Scope 2 electricity, and Scope 3 Categories 3, 5, 6, and 7. Enter your office energy, vehicle fuel, travel records, and headcount — the 20-minute calculation produces a Carbon Passport with a public verification URL. Share it with enterprise clients requesting carbon data and include it in supplier qualification submissions.
Frequently Asked Questions
Are the commuting emissions of temporary workers we place included in our GHG inventory?
No — unless they remain permanently on your payroll throughout the assignment. Under the GHG Protocol Category 7 (employee commuting), you report the commuting of people employed by your organisation. Temporary workers placed with host employers are typically in your Scope 3 only if they are on your agency payroll; their commuting to the host employer site is generally the host's Category 7. Confirm with your accountant which payroll arrangement you use.
Our agency is small — 15 consultants. Does carbon reporting apply to us?
CSRD directly applies only to companies above 250 employees (from 2025) or with EU public interest entity status. However, if you supply large enterprise clients who are CSRD reporters, they may ask you for carbon data regardless of your size to satisfy their own Scope 3 disclosure requirements. A 15-person agency supplying an NHS Trust, a FTSE 100, or an EU corporate has effectively inherited the reporting requirement through the supply chain.
How large are Scope 2 emissions for a typical recruitment agency?
Scope 2 for a 20-person office-based agency typically ranges from 5–15 tCO2e/year depending on office size, equipment, and country. A 500m² open-plan office in the UK consuming 60,000 kWh/year: 60,000 x 0.193 = 11.6 tCO2e. Energy-efficient LED lighting, hot-desking policies, and occupancy controls can reduce this by 20–30%. Consider renewable certification to reduce your market-based Scope 2 figure.
What documentation do I need to support a carbon questionnaire response?
Minimum documentation: annual electricity bill (kWh), gas bill if applicable (m³), fuel card statements for company vehicles (litres), headcount and commuting survey results, and any business travel records (flight booking system or expense report extracts). Attach these as supporting evidence in the questionnaire portal, or reference a Carbon Passport URL that links to a verified summary of your calculation.
How do I handle Scope 3 for a remote-first staffing agency with no physical office?
Remote-first agencies still have Scope 3 Category 7 emissions — employee home working generates home energy consumption attributable to work hours (DEFRA guidance: approximately 0.06 kgCO2e per home-working hour). For a 20-person fully remote agency, 8 hours/day x 230 days x 20 employees x 0.06 = 22,080 kgCO2e = 22.1 tCO2e/year in Category 7. Business travel (Category 6) from client and candidate visits remains relevant even without a central office.
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