European Network of Business Travel Associations
BT4Europe
In Europe the leading National Business Travel Associations are united through BT4Europe to empower the local, regional and pan-European representation of the business travel industry with a clear focus on the customer journey of the business traveler.
ID: 201577050121-73
Lobbying Activity
Response to Targeted revision of Regulation (EU) 2021/782 on rail passengers’ rights and obligations
22 Sept 2025
BT4Europe response to the Targeted revision of Regulation (EU) 201/782 on rail passengers rights and obligations. BT4Europe appreciates the Commissions initiative to update and strengthen Rail passenger rights when travelling cross-border, long-distance within the EU. We find that the Problems identified and Practical need for EU action described in the Call for Evidence-document (Ref.Ares 2025 6077874-28/07/2025) cover the needs of travellers but would like to emphasise a few points particularly important for those traveling for business. 1. The paying party needs to be reimbursed (for instance a business travel agency or corporate travel account), rather than the individual traveller. 2. It needs to be clear who is responsible for reimbursements, compensations etc. 3. We ask for simplified claims processes, via APIs or automated forms for corporate travellers/corporations. BT4Europe has responded to the Impact Assessment on MDMS and SDBTR earlier this year but would like to reemphasise the need for a simplified booking process. One where cross-border, long-distance and regional rail travel can be purchased as one transaction from a ticket platform that, in the best of worlds supports the corporations chosen booking platform and thereby also supports their need for tracking spend, managing risk and duty of care. Business travel could be a strong driver for more sustainable travel in Europe by shifting from car or air to train, but for this to happen the booking processes as well as passenger rights need to be made easier.
Read full responseResponse to Sustainable transport investment plan
3 Sept 2025
BT4Europe Feedback on the Sustainable Transport Investment Plan (STIP) BT4Europe, the European Network of Business Travel Associations, welcomes the European Commissions ambition behind the Sustainable Transport Investment Plan (STIP). The plan represents a vital and timely step toward achieving climate neutrality in the European transport sector. To ensure its full success, STIP must be underpinned by a strong cooperation model across the entire value chainincluding infrastructure providers, technology developers, regulators, corporate stakeholders, and customer-facing services. The integration of customer-related regulations is essential to drive adoption and embed sustainability throughout the mobility ecosystem. Business travel, as a strategic and high-volume segment of the mobility market, holds significant potential to act as a demand driver for sustainable transport solutions. To unlock this potential, BT4Europe recommends the following key priorities: 1. Reliable and Globally Aligned CO Data Standards CO data standards must serve the full stakeholder chainfrom investors and regulators to corporate customers and end-users. This requires globally aligned, accurate, auditable, and comparable data that can be integrated into both financial and non-financial reporting frameworks. Current reporting requirements, including those under the Corporate Sustainability Reporting Directive (CSRD), do not sufficiently account for the type of fuel used in transport. This gap risks reducing sustainability decisions to cost-based choices alone. To address this, CO data must be embedded into regulated reporting criteria, including sector-specific standards under IFRS, ensuring that sustainability is reflected in both shareholder and customer markets. A circular approach to reportingwhere emissions data flows consistently from investment decisions to point-of-sale transparency and corporate disclosuresis essential to enable informed decision-making and measurable progress. 2. Infrastructure Development The availability of enabling infrastructuresuch as charging points for electric vehicles and access to Sustainable Aviation Fuel (SAF)is critical to making sustainable mobility options viable for corporate travellers. Investment must target both transitional and breakthrough technologies across all transport modes, particularly aviation and rail. 3. Closing the Price Gap The cost disparity between fossil fuels and SAF/E-fuels remains a major barrier to adoption. Bridging this gap is essential to create fair market conditions and accelerate the transition to low-emission alternatives. 4. Global Alignment of Emissions Reporting Emissions reporting and data exchange must be aligned internationally to ensure scalability, transparency, and comparability across borders. Fragmented approaches risk undermining progress and creating competitive distortions. 5. Business Travel as a Catalyst for Scaling Sustainable Mobility Business travel should be explicitly considered in STIP as a key lever for scaling sustainable mobility. Corporate travel decisions influence large volumes of transport activity and can drive early adoption of cleaner technologies and services when supported by reliable data and infrastructure. ________________________________________ Conclusion BT4Europe believes that only through coordinated actionlinking investment, infrastructure, regulation, and customer engagementcan STIP deliver on its promise of a sustainable, competitive, and climate-neutral transport system. We remain committed to supporting the Commission in shaping a future-ready mobility framework and welcome continued dialogue to ensure business travel is effectively integrated into Europes sustainability journey. Attachment: BT4Europe Sustainability Position Paper 2025
Read full responseResponse to Digitalisation of identity cards issued to EU citizens
13 Jan 2025
BT4Europe welcomes the Commissions proposed regulation on the issuance of digital travel credentials (DTC). This has the potential to facilitate an enhanced travel experience for the many business travelers who cross our European borders each year. Travel is by nature a global activity, so the Commissions approach of building on international standards to ensure a consistent approach at international level makes sense. Global interoperability of digital travel credentials is key. The possibility for travelers to decide whether or not to obtain and use DTCs is fair. Not all travelers feel confident navigating the digital world and some might not have the devices necessary. With that statement follows that the system needs to be intuitive and easy to use. Digital Travel Credentials will only be a success if users trust that their data and privacy is safe. Making sure that robust safety measures are in place is of the highest importance.
Read full responseResponse to ReFuelEU Aviation environmental labelling scheme
22 Oct 2024
The Flight Emissions Label aims to provide a clear view of CO emissions per flight, allowing for informed decision-making when choosing travel options. For a company or organisation concerned with reducing the environmental impact of travel, this would be a significant advantage, as it could use this data to optimize corporate travel, selecting flights with lower emissions or opting for alternative, more sustainable means of transport. Summary of the Business Travel Manager requests: 1. Methodology used for the calculation should be aligned with Count Emissions EU 2. Voluntary disclosure for the introduction phase shall be followed by mandatory disclosure in the long term 3. Airlines should be required to share this information with 3rd party resellers (OBT, OTA) to make sure that consumers can easily compare emissions between airlines Detailed observations: 1. In the current proposal, the regulation mentions the obligation for airlines to display the labels at points of sale and in advertising, including websites and digital platforms. However, there does not seem to be an explicit reference to the need for deep integration with external platforms such as Travel Management Companies (TMCs) or corporate booking systems. It would be useful for this integration to be clearly defined, so it does not become a critical issue for the corporate world, which requires transparency towards travelers and methodologies used for sustainability reporting and evaluation. 2. The regulation provides for the creation of a centralized website to consult flight emissions, offering a unique platform that could facilitate access to environmental data. It is essential that the centralized website allows data to be exported in flexible formats (such as APIs or customizable formats) to enable integration with TMC systems for integrated corporate reporting and to create personalized reports based on the unique needs of each organization. (Although the regulation mentions data transparency and accessibility, the export of data in flexible formats such as APIs does not seem to be explicitly provided for). 3. The regulation is at the EU level, but many companies and organisations operate on a global scale. It would be preferable for the labeling system to be harmonized internationally. Non-European airlines may not adopt the same standard, which could create potential difficulties in comparing emissions on flights operated by carriers from other jurisdictions, such as those in the United States or Asia, which may not have similar obligations. Moreover, this would make it difficult for companies to ensure accurate and consistent reporting. 4. The regulation mainly focuses on CO emissions and does not include other environmental metrics, such as NOx emissions, noise pollution, or the impact of local pollution near airports. For a company with a broader view of sustainability, limiting the analysis to CO alone might not be sufficient to consider the overall impact of a trip. 5. Although the methodology foresees the use of primary data for calculating emissions, there is always the possibility that, in some cases, secondary estimates or models will be used. In such cases, there is a risk of not having full confidence in the reported figures, especially when comparing flights from airlines with different technologies or alternative fuels (such as SAF, Sustainable Aviation Fuel). It would be useful to know how accurate the information is for each flight. 6. While the scheme may seem beneficial, there could be hidden costs for companies and organisations due to the potential increase in airfare prices if airlines pass on the costs of voluntary participation in the labeling scheme to customers. A company or organisation should carefully consider the trade-offs between sustainability and costs.
Read full responseResponse to Efficient cross-border car rentals
22 Sept 2024
Taking car rentals into other EU countries rules Response to European Commissions Public Consultation by BT4Europe We advocate for the creation of a unified EU regulatory framework in car rental sector. This initiative has the potential to greatly improve the mobility and convenience of EU citizens and visitors, fostering stronger integration and cohesion within the single market. The Single Market The Single Market is one of the cornerstones of the European Union, designed to facilitate the free movement of goods, services, people, and capital across borders. This fundamental principle should extend to the mobility sector, including cross-border car rentals, which play a vital role in both business and leisure travel across Europe. Multimodality and Sustainability Excessively high one-way fees in case of car rentals across borders create a significant barrier to free movement, often forcing unnecessary returns to the country of origin, which increases carbon emissions and undermines EU green policies aimed at reducing environmental impact. The integration of electric vehicles into rental fleets, supported by an adequate charging infrastructure across countries, should also be part of this regulation. Every country should have a comparable level of charging stations, which is not yet the case. Multimodality is crucial for European business travel and the achievement of sustainability goals. It can only succeed if car rentals are properly regulated and harmonized among the different countries to enable their integration with other means of transportation. Harmonized Cross-Border Regulations Harmonized cross-border regulations are essential to provide standard insurance coverage and insurance requirements for vehicles rented in different countries, allowing cars to be rented out across borders without complications. Currently, each country has different laws, regulations, and insurance requirements, which creates inconsistencies and barriers. In light of the significant bilateral agreements concerning land transport with non-EU countries, such as Switzerland (e.g. the borders between Germany and Switzerland), we believe it is necessary to harmonize cross-border regulations in car rental sector with these countries as well. Harmonized regulations on fleet management, car maintenance, insurance, and liability across the EU will contribute to consumer protection and also enhance the efficiency and sustainability of the entire mobility sector. Aligning standards across borders will ensure that all vehicles meet the same safety and environmental criteria, regardless of where they are rented or returned.
Read full responseResponse to Detailed rules for calculating CORSIA offsetting requirements
13 Jun 2024
The use of air travel by corporate companies for business activities presents a confusing situation as it remains ambiguous whether the offsets for scope 3 emissions have already been carried out or if companies still have to offset their flights, which could potentially result in double counting. Evidently, the directive places responsibility on Member States rather than airlines themselves, leading to questions surrounding the exact requirements for offsetting. Furthermore, the lack of a standardized calculation method for emissions and the directive's focus on a catch-up effect rather than proactive sustainability measures creates further uncertainties about its effectiveness. From the perspective of business travel in general, the connection to the CountEmissions EU Regulation is essential for transparency. The consequences of non-compliance with the directive also remain unclear. An additional concern is, that airlines may not be able to use offsetting/reductions paid by their customers to claim compliance with this directive
Read full responseResponse to Better protection for passengers and their rights
8 Mar 2024
The European Network of Business Travel associations (BT4Europe) appreciates the opportunity to give feedback on the revision of existing regulation on Passenger Rights in Europe. The proposal is definitely a step in the good direction, but there are a few details we believe must be amended; 1. Reimbursement, if required by disruptions or cancellations, should be made via the payment method which was originally used to purchase the ticket. Effectively, if the ticket was paid for by a corporation for a business traveller, that corporation should be reimbursed. 2. Rules for passenger reimbursement are not harmonized across all modes of transportation, e.g. different rules apply for airlines and for rail companies. BT4Europe asks for coherent rules in particular for multimodal travel. 3. Providers of travel and intermediaries (e.g. booking engines) should not be allowed to exclude multimodal ticket complaint handling and reimbursements in their terms and conditions. 4. BT4Europe expresses particular appreciation for the 14-day-reimbursement deadline outlined in the European Commission's proposal. This requirement is crucial and fulfills a significant need in the process.
Read full responseMeeting with Gabriele Bischoff (Member of the European Parliament, Rapporteur)
7 Sept 2023 · Letzte Entwicklungen 883