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Will your travel policy survive the 2026 ESG audit?


JOHANNESBURG – For decades, South African corporate travel was ruled by a single metric: cost. If a route via the Middle East saved R5,000 on a trip to London, it was booked. But as we approach the 2026-2030 commitment period of the Climate Change Act, that logic is breaking down.

Today, that same indirect flight presents a boardroom-level dilemma. It might be cheaper, but does the extended flight path blow the carbon budget? And given current geopolitical volatility, does the layover expose the employee to unacceptable security risks?

Travel has shifted from a procurement line item to a complex governance challenge. While South African businesses remain budget-conscious, the convergence of stricter ESG reporting and heightened Duty of Care means the “cheapest fare” is often no longer the viable option.

The regulatory wake-up call

The catalyst for this shift is regulatory. In March last year, the Climate Change Act came partially into effect, fundamentally changing how large companies view their operations. The Department of Forestry, Fisheries and the Environment’s technical guidelines for carbon budgets set up the first commitment period (2026 to 2030). This pushes companies from merely “preparing” to proving exactly what they emit and how they will cut it.

Crucially, business travel is explicitly listed in the JSE’s climate disclosure guidance as a Scope 3 emissions source.

For those outside the sustainability office, the distinction between the different scopes is an important one. Scope 1 covers direct emissions (like fuel for company cars), and Scope 2 covers indirect energy (like electricity for the head office). Scope 3 is the catch-all for the wider value chain, including every flight, hotel night, and Uber ride taken by staff. Because these emissions happen outside the company’s direct control, they are the hardest to measure, yet for many service-based companies, they make up the bulk of their carbon footprint.

“Before, boards considered travel expenditure purely as a finance issue. Now, it’s about how business travel fits into the carbon budget,” says Mummy Mafojane, GM FCM South Africa. “Boards want to know: what did we emit, where did it come from, and what are we doing differently next quarter? If companies are expected to report emissions properly, travel has to be counted and managed like any other source of carbon.”

Leading by example

We are already seeing this shift among South Africa’s major players. Leading financial group Discovery has committed to eliminating its Scope 1 and 2 emissions by 2028. In practice, this means decarbonising their physical operations, shifting their buildings to renewable energy and eliminating emissions from company-owned fleets.

But the bigger challenge lies in Scope 3, where they have committed to cutting business-travel emissions by a further 30% by 2030. This requires a fundamental change in behaviour: replacing non-essential flights with digital alternatives, enforcing stricter approval flows, and selecting travel partners based on carbon efficiency rather than just price.

Similarly, energy and chemicals giant Sasol already measures and reports its global business-travel footprint under Scope 3. Unlike companies that simply estimate this, Sasol uses granular data to calculate the exact impact, using that information to purchase verified carbon credits to offset the emissions they cannot yet eliminate.

However, many companies struggle to match this precision because complete, auditable travel data is notoriously difficult to collate. When employees book directly with airlines, use consumer sites, or pay with personal cards, the data fragments. Without details on cabin class, routing, or ground transport, calculations rely on averages and assumptions, and those are methods that auditors are increasingly rejecting.

When disruption becomes a data problem

Here’s where South Africa’s recent travel chaos becomes more than just an operational headache and becomes an ESG compliance issue.

When jet-fuel shortages at OR Tambo and Cape Town forced flight cancellations and diversions recently, employees scrambled to rebook. Some used personal credit cards. Others booked last-minute alternatives through consumer sites. Fuel had to be sourced from Durban and Mozambique, creating extended ground transport and unplanned routing changes.

Similarly, when severe weather repeatedly flooded roads and disrupted flights across coastal and inland regions, itineraries were rewritten on the fly, often outside the official travel management channel.

The result? Every disruption creates a data gap. Those emergency re-bookings, alternative routes, and last-minute hotel stays rarely get captured in the company’s emissions tracking system. When audit season arrives, the carbon calculation is incomplete, and the auditor flags it.

“Emissions reporting is only as good as the supplier inputs behind it,” notes Mafojane. “But when a crisis forces employees off-programme, even the best suppliers can’t help you. You end up with gaps in your Scope 3 data, and that becomes a regulatory risk, not just a travel risk.”

This is why resilience planning is now an ESG imperative. Companies that build contingency into their travel programmes, including preferred backup routes, pre-vetted alternative carriers, clear escalation protocols, don’t just protect their people. They protect their data integrity. And in a world where incomplete emissions reporting can trigger audit findings or regulatory scrutiny, that matters.

Even when travel goes according to plan, supplier quality determines whether your emissions data holds up under scrutiny. If an airline, hotel group, or car-rental partner can’t provide usable emissions data, the company ends up relying on proxies, and those numbers get interrogated later by auditors, assurance teams and, in some cases, regulators.

That’s why preferred supplier lists will increasingly favour providers that can deliver consistent emissions information and show credible progress on their own footprint. It lowers reporting risk as much as it lowers emissions.

Duty of care meets carbon accountability

This is where ESG and Duty of Care fully converge. More companies are aligning travel risk management to ISO 31030, moving beyond ad-hoc approvals to structured frameworks with clear escalation paths and contingency plans that don’t hinge on a single airport, corridor, or carrier.

This complexity changes the mandate for the Travel Management Company (TMC). It’s no longer enough to simply issue a ticket. The TMC must ensure that every booking – and every rebooking – flows through channels that capture the data needed for compliance.

“Boards don’t like surprises – on carbon, on cost, or on disruption – and they expect their TMC to flag those issues before they happen,” Mafojane adds.

The Climate Change Act puts business travel inside the same reporting rules as the rest of a company’s emissions. If the information is incomplete, an auditor will pull it apart. If there’s no backup plan, a fuel shortage or storm doesn’t just strand people, but can creates holes in your carbon reporting that you’ll have to defend later.

As we head into 2026, the companies that will succeed are those that can provide evidence of controls, supplier vetting, and data integrity. Those that can’t will find themselves defending carbon budget overruns to the regulator, and explaining to the board why their teams were stranded halfway across the world instead of in front of clients.

**ends**

For more information about FCM Travel call Sonnette Fourie on 081 072 2869 or email sonnette@bigambitions.co.za.

About FCM Travel:

FCM Travel, the flagship corporate travel brand at Flight Centre Travel Group (FCTG), is the business travel partner of choice for large national, multinational and global corporations. We are an award-winning global corporate travel management company ranking as one of the top five by size around the world. We operate a global network which spans more than 100 countries, employing over 6000 people.

FCM are transforming the business of travel through our empowered and accountable people who deliver 24/7 service and are available either online or offline. Leveraging FCM’s negotiating strength and supplier relationships in conjunction with our tailored business travel programs, our expertise delivers more for our clients where it matters most to them.

Visit us at www.fcmtravel.co.za

Issued by: Big Ambitions

Contact: Lori Cohen

Tel: +27 79 641 4965

Email: Lori@bigambitions.co.za

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