Workers’ mobility is no longer merely a matter of sustainability or corporate responsibility. With the enactment of Law 9/2025, dated December 3, on Sustainable Mobility—published in the Official State Gazette (BOE) on December 4, 2025, and effective as of December 5, 2025—commuting to the workplace is now incorporated into the regulatory compliance framework of certain companies and public entities.
The regulation introduces a specific requirement: to have a Sustainable Commuting Plan (PMST) in place at workplaces that exceed certain workforce thresholds. Specifically, this requirement applies to companies and public-sector entities with workplaces employing more than 200 workers, or 100 workers per shift, provided that such a workplace is the employee’s regular place of work.
In addition, the timeline has been accelerated. The amendment introduced by Royal Decree-Law 7/2026, dated March 20, reduces the deadline for implementing the plan from 24 to 12 months, setting December 5, 2026, as the key date for affected institutions.
Who does this affect?
This requirement must be analyzed on a site-by-site basis, not solely based on the total number of people employed by the company. Therefore, an organization with multiple locations must determine whether each site exceeds any of the legal thresholds: more than 200 workers at the site or more than 100 workers per shift.
What should a PMST include?
The Sustainable Commuting Plan should not be viewed as a purely formal document. Law 9/2025 requires that it incorporate sustainable mobility solutions tailored to the needs of the facility and the people who use it, including not only employees but also visitors, suppliers, and other users of the facility.
Measures to be considered include, among others, promoting active mobility, public transportation, low-emission mobility, shared or collaborative solutions, facilitating the use and charging of zero-emission vehicles, teleworking whenever possible, and road safety and accident prevention measures for commutes to the workplace.
From a technical standpoint, a robust PMST should be based on a realistic assessment of the facility’s mobility: travel patterns, shifts, public transportation use, accessibility, parking, charging infrastructure, road safety, associated emissions, and monitoring indicators.
Negotiation, Follow-up, and Record-Keeping
One particularly important point is that the plan must be developed within the framework of collective bargaining. Law 9/2025 links the PMSTs to workers’ legal representation and to the obligation to negotiate measures that promote sustainable commuting to work.
Therefore, beyond simply “having a document,” companies should be able to demonstrate that they have conducted a thorough assessment, negotiated the plan, defined actionable measures, established indicators, and put in place a system for regular monitoring.
Key Dates
This requirement must be analyzed on a site-by-site basis, not solely based on the total number of people employed by the company. Therefore, an organization with multiple locations must determine whether each site exceeds any of the legal thresholds: more than 200 workers at the site or more than 100 workers per shift.
- December 4, 2025: Publication in the Official State Gazette (BOE) of Law 9/2025 on Sustainable Mobility.
- December 5, 2025: Law 9/2025 takes effect.
- March 21, 2026: Publication in the Official State Gazette (BOE) of Royal Decree-Law 7/2026, which amends the implementation schedule.
- December 5, 2026: Deadline for schools subject to the requirement to have the PMST in place, following the reduction of the deadline from 24 to 12 months
An opportunity to stay ahead of the curve
The affected organizations should begin an applicability analysis by workplace as soon as possible, review their workforce and shift data, determine whether there are any additional regional or local regulations, initiate the participation process, and design a plan that is technically sound, negotiated, measurable, and ready for monitoring.
At PKF Attest organizations throughout the entire compliance cycle: applicability analysis, compliance assessment, PMST design, negotiation support, definition of indicators, action plan, monitoring, and preparation of supporting documentation for the competent authority.
If your company has work sites with more than 200 employees, more than 100 people per shift, or sites located in areas with specific regulations, now is the time to review your situation and implement a compliance roadmap.
