Basis of reporting

This chapter contains an elaboration of the assessment on the classification of eligible and aligned activities in accordance with the EU Taxonomy, following the summary provided in the chapter Environmental value, section EU Taxonomy on sustainable activities. As the legislation is continuously in development, the assessment on eligibility and alignment is an iterative process. The setup of our assessments so far is to provide a foundation for the EU Taxonomy implementation and reporting for the coming years.

The EU Taxonomy prescribes quantitative and qualitative reporting on predefined key performance indicators (KPIs). In this section we present the share of PostNL’s consolidated total operating revenue , capital expenditure (capex) and operating expenses (opex) for the reporting period 2023. The disclosures are associated with Taxonomy-eligible economic activities related to the environmental objectives in accordance with the Regulation (EU) 2020/852 as supplemented with Commission Delegated Regulation (EU) 2021/2139, Commission Delegated Regulation (EU) 2021/2178 (EU Taxonomy), Delegated Regulation (EU) 2023/2486 of 27 June 2023 (Environmental Delegated Act) and the Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending the Climate Delegated Act.

Basis of preparation

Our approach to report in accordance with the relevant EU Taxonomy regulation includes the following key steps:

  • Evaluation of PostNL's activities in relation to the EU Taxonomy classification of economic activities;
  • Evaluation of technical specifications of activities and related assets in relation to substantial contribution and Do Not Significantly Harm (DNSM) criteria;
  • Evaluation of Minimum Safeguards (MS) criteria based on existing policies and business practices;
  • Calculation and reporting of the KPI.

The alignment with relevant financial statement line items is the starting point of our Taxonomy allocation methodology. The reported figures have been determined based on the allocation of activities to the Taxonomy, derived bottom-up for all PostNL reporting units. The figures are based on the actual amounts represented in the general ledger accounts as included in PostNL's consolidated financial statements. In addition, the split between transport by road and air in our international business is based on expected transport used between countries for our trade lanes.

To avoid double-counting, we eliminated inter-company transactions, which are separately specified in our general ledger accounts and consolidated financial statements. We did not identify any other risk of overlapping activities that could lead to double-counting for our 2023 reporting.

Significant estimates and judgements

PostNL has implemented the Taxonomy-related requirements based on the detailed regulatory documents, frequently asked questions (FAQs) from the European Commission and, where needed, our own interpretation of the criteria. Although the requirements are detailed, on specific areas they leave room for interpretation. On relevant elements where interpretation is needed, PostNL applied due care in its approach by focusing on maximum transparency and through engagement with dedicated professional consultants and peers, for example a PostEurop working group. We are aware that views on the interpretation by the European Commission may change over time and that this may lead to different conclusions on the reported eligibility and alignment in the future.

For CCM 6.4 (Operation of personal mobility devices, cycle logistics), the calculation of the share of aligned activities, PostNL allocated the proportion of turnover based on the kilometres driven by the Taxonomy-aligned activities relative to the total kilometres driven by vehicles attributed to this economic activity.

For CCM 6.5 (Transport by motorbikes, passenger cars and light commercial vehicles), for the calculation of the share of aligned activities, PostNL allocated the proportion of turnover based on the kilometres driven by the Taxonomy-aligned activities relative to the total kilometres driven by vehicles attributed to this economic activity.

The share of Taxonomy-aligned activities for CCM 6.5 is currently built up from electric scooters. For the electric small trucks in our fleet we concluded that these cannot yet be reported as Taxonomy aligned, because PostNL has not yet been able to substantiate the DNSH criteria for the environmental objective Pollution. All other technical screening criteria are being met for the activities with these vehicles.

EU Taxonomy activities and key interpretation elements

PostNL has identified the following EU Taxonomy economic activities applicable for its 2023 reporting.

CCM 6.4 Operation of personal mobility devices, cycle logistics

All transport devices where the propulsion comes from the physical activity of the user, from a zero-emissions motor and combined with physical activity such as such as an (e-)bike and/or (electric) cargo bike (i.e. bicycles, electric bicycles, or cargo bikes) are categorised under activity 6.4. This means that the kilometres of the delivery process, using a personal mobility device such as an (e-)bike and/or (electric) cargo bike, in combination with physical activities are categorised under activity 6.4.

CCM 6.5 Transport by motorbikes, passenger cars and light commercial vehicles

The purchase, financing, renting, leasing and operation of vehicles designated as category M1, N1, or L (2- and 3- wheel vehicles and quadricycles). In PostNL terminology, all activities with small trucks are attributed to this category, as well as with motorised scooters and light electric freight vehicles.

CCM 6.6 Freight transport services by road

This activity concerns power-driven vehicles having at least four wheels and which are used for the carriage of goods. In PostNL terminology, the activities with large trucks are attributed to this economic activity.

CCM 6.15 Infrastructure enabling low-carbon road transport and public transport

PostNL links its sorting activities to a specific sub-activity described in the EU Taxonomy, infrastructure dedicated to transshipment. Our interpretation of this activity is that infrastructure and related activities in the sorting centres of PostNL are related to transshipment of freight between the modes (Delegated act Annex 1 art. 6.15: 1.b of the technical screening criteria). Capex related to buildings are considered eligible under CCM 6.15. This infrastructure is fundamental to enable the efficient transport of letters and parcels and is therefore indispensable to minimise the required transport activities in our business. Other alternatives would imply a significant expansion of transport movements and related environmental impact, resulting in increased GHG emissions.

CCM 7.7 Acquisition and ownership of buildings

Buying and owning real estate. PostNL considers rent and leasing buildings as ‘exercising ownership of that real estate’, which is a specific part of this economic activity. PostNL has renting and leasing activities of its own buildings on a small scale.