On March 20, Royal Decree-Law 7/2026 was approved under the title “Comprehensive Plan to Address the Crisis in the Middle East.” This is an emergency energy measure designed to reduce dependence on fossil fuels and accelerate the electrification of the economy in response to the global surge in prices.
However, among the measures designed to support transportation, industry, and consumers, the decree includes a key change for businesses that has gone largely unnoticed: the halving of the deadline for implementing the Sustainable Commuting Plan (PMST).
From 24 to 12 months: the new deadline has been set
Article 63 of Royal Decree-Law 7/2026 amends Law 9/2025 on Sustainable Mobility, bringing forward by 12 months the effective date of the requirement for affected companies to negotiate and develop Sustainable Mobility Plans (PMSTs).
In practice, this means that:
- The duration of your Sustainable Mobility Plan has been cut in half. It has been reduced from 24 to 12 months.
- The deadline is December 5, 2026
- As of today, there are just 7 months left
A regulatory change that does not stem from a reform of the mobility law itself, but rather from an emergency energy decree, which explains why many organizations have not yet fully grasped its real impact.
The PMST is not a technical document “to be complied with and filed away”
One of the most common mistakes is to treat the Sustainable Mobility Plan as a technical document that is simply drafted, submitted, and filed away. Law 9/2025 is clear: the SMP is a negotiated process with labor, safety, and collective implications.
Specifically, the regulation states that:
- The plan must be formally negotiated with the workers' legal representatives (RLT)
- If there is no works council, it is mandatory to establish a negotiating committee with the most representative unions in the sector
- Mobility will become a mandatory subject of collective bargaining for any bargaining committee formed on or after December 2025
- The PMST should be incorporated into the occupational risk assessment and addressed by the Occupational Safety and Health Committee
- A biennial follow-up report is required, with the active participation of the employee representative
Therefore, we are not just talking about measures such as carpooling, cycling, or telecommuting. We are talking about governance, collective bargaining, and the traceability of the process.
What the Labor Inspectorate Will Look For (and What It Won't)
It is worth dispelling another myth. The Labor Inspectorate will not assess whether a company has opted for one specific mobility measure or another.
What they will be reviewing is how the plan was negotiated:
- If there is a charter establishing the commission
- If there is evidence of genuine negotiations
- If the PMST is integrated into preventive systems
- If the monitoring required by the standard is carried out
The difference between simply having a document and having properly followed the process can be decisive in the event of a request or an inspection.
Has your company already started the process?
Bringing the deadline forward is neither a mere formality nor a minor matter. It poses a tangible regulatory risk for many organizations that have not yet begun the process or have reduced it to an overly technical perspective.
At PKF Attest companies in designing, negotiating, and implementing Sustainable Commuting Plans, ensuring they comply with labor, safety, and governance regulations.
The question is no longer whether we should do it.
The question is how to do it right and on time.
