Worker mobility has gone from being an operational issue to a regulated area with specific obligations and deadlines. Law 9/2025, of 3 December, on Sustainable Mobility —in force from 5 December 2025— redefines mobility as an essential collective right and requires certain companies to draw up a Sustainable Commuting Plan (PMST): a management tool that analyses how employees travel to the workplace and Establish concrete measures to reduce environmental impact of those journeys and improve their safety.
What initially appeared to be an obligation with ample room has changed its schedule. Royal Decree-Law 7/2026, approved in March 2026, reduced the compliance period from 24 to 12 months. The deadline is now 5th December 2026.
Which companies are obliged?
The obligation falls upon companies and public sector entities that have Work centres with more than 200 workers or centres with more than 100 people per shift, when that centre is your usual place of work.
One aspect that it's worth clarifying from the outset: The obligation is measured by work centre, not by company. An organisation with multiple sites may have some centres that are obliged and others that are not. This requires an individualised analysis before determining the real scope of the obligation.
What is the PMST
The PMST is a structured document, based on a real diagnosis, with concrete measures, measurable objectives, and monitoring indicators. The standard conceives these plans as integral instruments that should simultaneously impact sustainability, occupational health, energy efficiency, and road safety.
Its dual objective is to reduce emissions from business travel. —with a direct impact on the organisation's carbon footprint— and improve the quality of life and safety for workers on their daily commutes.
How to develop a sustainable mobility plan
Phase 1. Mobility diagnosis.
All PMST begins with a mandatory diagnosis. Before defining any measures, the company must know how its workforce truly operates. This is achieved by Mobility survey addressed to all centre workers, which must include, as a minimum:
- Usual municipality and area of origin.
- Mode of transport used.
- Travel time and distance.
- Shift or time slot for entry and exit.
- Reason why that means of transport is chosen.
- Perceived risks on the journey.
In addition to the survey, the diagnosis it must include an analysis of the public transport offering in the centre's vicinity and the Accident log in itinere and on mission in the last five years, which must be obtained from the official accident records of the occupational risk prevention department.
Phase 2. Definition of measures.
From the diagnosis, the plan must propose concrete measures in at least these seven areas:
- Active mobilitywalking, cycling or personal mobility device journeys, with supporting infrastructure such as secure cycle parking, changing rooms and showers.
- Public transportcompany buses, shuttle services, coordination with public transport operators, and travel pass subsidies. The transport card, expressly mentioned in the law, is one of the most popular measures among workers and offers a direct tax advantage for the company.
- Low or zero emission mobilityincentives for electric or hybrid vehicles and installation of charging points at the workplace.
- Shared mobilitycarpooling and vanpooling systems among colleagues, with internal organisation platforms by geographical area.
- Organisational strategiesRemote working, flexible hours and compressed working weeks to reduce demand for commuting during peak hours.
- Road safetyRoute analysis and risk points, safe itineraries, specific training for staff, and coordination with the Occupational Risk Prevention Plan.
- Internal communicationAwareness campaigns, modal shift incentive programmes and mobility events.
Measures must follow a principle of hierarchy, always prioritising the most sustainable options.
Each measure must be accompanied by objectives quantifiable, indicators of evaluation and a Implementation schedule concrete.
Stage 3. Negotiation with the workers' legal representatives.
Law 9/2025 amended Article 85.1 of the Workers' Statute to include the PMST among Matters of mandatory negotiation in collective bargaining.
Negotiation is a guarantee that the plan responds to the actual needs of the workforce and that it will have greater buy-in during its implementation. Furthermore, a consensual plan scores better in public grant applications provided for in Additional Provision 27 of the law.
Phase 4. Formal Approval and Registration in EDIM.
Once the negotiation is concluded, the plan must be formally approved through an internal minute which records the date, the participants and the outcome of the process.
Phase 5. Registration in the Integrated Mobility Data Space (IMDS).
The final step is registration in the Integrated Mobility Data Space (EDIM), the centralised system created by the law itself to consolidate mobility information in Spain. Registration is carried out through the regional authority. the competent transport authority, which transmits the information to the state system.
Phase 6. Continuous monitoring.
The approval of the plan does not close the process, but rather initiates it. The law establishes a system of permanent monitoring which includes:
Biennial follow-up report: mandatory every two years, to assess compliance with measures and adjust them if the results are not as expected.
Plan reviewin major centres of activity, at least every five years.
Mobility Manager: An essential figure in major centres of activity, responsible for coordinating, overseeing and implementing the PMST on a day-to-day basis and ensuring its update.
Periodic submission of data to EDIM, with each follow-up report.
At Zirkel, we support companies in the diagnosis, design, and implementation of their Sustainable Mobility to Work Plans, integrating the process with the organisation's decarbonisation strategy and ESG reporting.
If you want to know if your company is obligated and what steps you need to take, Contact us.
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