Spain’s sustainable mobility law is here, and the clock is ticking
Spain’s Ley 9/2025 de Movilidad Sostenible, published in the BOE on 4 December 2025, introduces a binding obligation for thousands of companies: approve a Plan de Movilidad Sostenible al Trabajo (PMST), or sustainable commute plan, covering every workplace that meets certain employee thresholds.
The original deadline gave companies 24 months (until 5 December 2027). But Real Decreto-Ley 7/2026, issued this year, accelerated the timeline to just 12 months, moving the compliance date to 5 December 2026. That leaves companies roughly eight months to diagnose commuting patterns, negotiate with worker representatives, draft the plan, and register it with Spain’s EDIM mobility data platform.
For sustainability teams already measuring Scope 3 emissions, this regulation creates a direct overlap: the employee mobility survey that feeds your GHG Protocol Category 7 calculations captures much of the data the PMST requires. Companies that recognize this connection early can avoid duplicating effort and turn ESG compliance into regulatory compliance with minimal extra work.
Who must comply with the PMST requirement
Article 25 of Ley 9/2025 defines clear thresholds. Your organization needs a sustainable commute plan if any of its workplaces meet these criteria:
- 200 or more employees at a single workplace
- 100 or more employees per shift at a single workplace
- Large activity centers: business parks, logistics hubs, hospitals, and shopping centers with high commuter volumes
Both private companies and Spanish public-sector entities are covered. The law applies per workplace, not per legal entity, so a company with multiple sites must evaluate each one independently.
For workplaces exceeding 1,000 employees in municipalities with more than 500,000 inhabitants (Madrid, Barcelona, Valencia, Seville, Zaragoza, Malaga), additional peak-hour traffic reduction measures are mandatory.
What the PMST must contain
The sustainable commute plan is not a generic mobility statement. Article 26 specifies a structured document with a mandatory diagnostic phase followed by concrete action measures.
Diagnostic phase
The diagnostic must map how employees currently commute. Specifically, it requires:
| Data point | Source |
|---|---|
| Transport mode used by each employee | Mobility survey |
| Commuting distances | Mobility survey |
| Work schedules and shift patterns | HR / payroll systems |
| Reason for transport choice | Mobility survey |
| Perceived commuting risks | Mobility survey |
| Accident history (in itinere and in mission, last 5 years) | Occupational health records |
Mandatory action areas
Once the diagnostic is complete, the PMST must include measures across these categories:
- Active mobility: walking and cycling infrastructure (bike parking, changing rooms, showers)
- Collective transport: company shuttle buses, coordination with public transit networks
- Low-emission vehicles: EV incentives, charging point installation, hybrid fleet policies
- Carpooling programs: shared commuting schemes between employees
- Telework and flexible scheduling: remote work policies that reduce commuting demand
- Road safety protocols: measures to reduce commuting accidents
Governance requirements
- The plan must be negotiated with worker representatives (RLT). If no RLT exists, a negotiating committee with sectoral trade unions must be formed. This obligation has been active since 5 December 2025.
- Large activity centers must designate a Mobility Manager responsible for plan execution.
- The approved plan must be registered with EDIM (Espacio de Datos Integrado de Movilidad), Spain’s integrated mobility data registry.
- Biennial progress reports are mandatory after initial approval.
Penalties for non-compliance
The sanctions regime under Ley 9/2025 operates on two tiers:
| Infraction level | Description | Fine range | Statute of limitations |
|---|---|---|---|
| Minor | No PMST approved by deadline, or failure to submit biennial reports | €101 to €2,000 | 6 months |
| Serious | False data submitted to EDIM, or repeated non-compliance | €2,001 to €6,000 | 3 years |
Companies that received subsidies under RDL 7/2026 face an additional consequence: full repayment of the subsidy if they fail to comply with the PMST obligation.
While the fines may seem modest compared to CSRD penalties, the reputational risk and subsidy clawback provisions create meaningful financial exposure, particularly for companies in regulated industries or those receiving public funding.
The deadline question: 2026 or 2027?
RDL 7/2026 cut the compliance period from 24 to 12 months, setting a 5 December 2026 deadline. However, a critical condition applies: the RDL requires parliamentary ratification (convalidation by the Congreso de los Diputados) within 30 days of publication.
If the Congreso does not ratify RDL 7/2026, the accelerated deadline lapses and the original 5 December 2027 deadline from Ley 9/2025 applies.
The prudent approach is to plan for the December 2026 deadline. Companies that wait for political clarity risk having insufficient time if the accelerated timeline holds. Starting the diagnostic phase now gives organizations flexibility regardless of which deadline ultimately applies.
How Scope 3 data powers your PMST diagnostic
Here is where ESG reporting and regulatory compliance converge. Companies measuring greenhouse gas emissions under the GHG Protocol already collect employee commuting data for Scope 3, Category 7 (Employee Commuting).
The standard mobility survey used for carbon footprint calculations captures:
- Transport mode (car, public transit, bike, walking, etc.)
- Commuting distance (home-to-workplace, one-way or round-trip)
- Frequency (days per week commuting vs. remote)
These three data points form the core of the PMST diagnostic required under Article 26. The law adds a few extra fields: shift patterns, the reason behind transport choices, and perceived commuting risks. But the foundation is already in place for any company running a Scope 3 Category 7 survey.
This means that companies using Dcycle’s automated data collection for their carbon footprint calculations are already halfway to PMST compliance. The mobility survey that calculates emissions can be extended with the additional fields the law requires, turning one data collection process into a dual-purpose compliance tool.
Practical steps to prepare before December 2026
Rather than treating the PMST as a standalone project, integrate it into your existing sustainability workflow:
Step 1: Audit your current mobility data (now)
Review what your Scope 3 Category 7 calculations already capture. If you are using Dcycle, your mobility survey data covers transport modes and distances. Identify the gaps: shift data, transport choice reasoning, and perceived commuting risks.
Step 2: Extend your mobility survey (April-May 2026)
Add the PMST-specific questions to your next employee survey cycle. This avoids survey fatigue by combining ESG and regulatory data collection into a single exercise.
Step 3: Gather accident history (April-May 2026)
Request in itinere and in mission accident records from the last five years from your occupational health and safety department. This data cannot come from surveys; it must come from official incident records.
Step 4: Begin RLT negotiation (May-June 2026)
Open formal dialogue with worker representatives. The negotiation obligation has been active since December 2025, so there is no reason to delay. Document all negotiations carefully, as this is a legal requirement, not a formality.
Step 5: Draft and approve the PMST (July-September 2026)
Use the diagnostic data to build a plan covering all six mandatory action areas. Prioritize measures that address the highest-impact commuting patterns identified in your survey.
Step 6: Register with EDIM (October-November 2026)
Submit the approved plan to the EDIM registry. Build in buffer time for any technical issues with the registration platform.
Why this matters beyond compliance
The PMST obligation is not just a regulatory checkbox. Employee commuting typically represents 5 to 15% of a company’s total carbon footprint depending on the industry and workforce size. For service-sector companies with large office-based teams, it can be even higher.
By aligning your PMST diagnostic with your ESG reporting data, you create a single source of truth for both regulatory compliance and sustainability strategy. Every improvement in employee commuting patterns (more public transit, more cycling, more telework) simultaneously reduces your Scope 3 emissions and satisfies the PMST’s action requirements.
Companies that treat these as separate projects will spend twice the time collecting data, running surveys, and producing reports. Those that integrate them will get more accurate data, faster compliance, and a clearer picture of where mobility improvements deliver the biggest carbon reductions.
Next steps
If your company has workplaces with 200+ employees in Spain, the time to act is now. Request a demo to see how Dcycle’s mobility survey can serve as the foundation for both your Scope 3 calculations and your PMST diagnostic, eliminating duplicated effort and accelerating compliance with Ley 9/2025.