The equation for thermal comfort for buildings in the free-running mode (Annexe A2) in European Standard EN15251 rests on the data collected in the EU project Smart Controls and Thermal Comfort (SCATs). Many of these data were from naturally ventilated office buildings which were in free-running mode outside the heating season. Using the data from these buildings a relationship between indoor comfort and outdoor climate was developed for free-running buildings. This paper describes the data and the methods of analysis used to estimate the comfort conditions in the variable environment of free-running buildings. The paper also describes how the indoor comfort conditions were related to the running mean of the outdoor temperature, and addresses the effects of air movement and humidity. The paper considers the proportions of people likely to be comfortable if the temperature differs from the neutral temperature. The differences between the adaptive comfort charts in EN15251 and ASHRAE 55-2004 are discussed.