- Workplaces with more than 200 people, or 100 per shift, must adopt a sustainable commuting plan.
- Plans are negotiated with employee representatives and reviewed every two years.
- The law also covers freight transport, carbon footprint and innovation sandboxes.
The Official State Gazette of 4 December 2025 published Law 9/2025, of 3 December, on Sustainable Mobility, which entered into force on the 5th. It is a broad law, of over a hundred articles, that regulates everything from public transport and urban mobility to logistics and innovation. For companies, the most immediate novelty is the obligation to adopt sustainable commuting plans in the larger workplaces.
Article 26 requires the plan from companies and public-sector bodies with workplaces of more than 200 employees, or 100 per shift, where they carry out their regular work. The deadline to adopt it is twenty-four months from the law’s entry into force, that is, until December 2027, and it must be accompanied by a follow-up report after two years, repeated every two years of validity.
What a mobility plan is
A sustainable commuting plan is a set of measures to reduce staff travel by private vehicle and make alternatives easier. They usually include, for example, public transport, cycling, walking, shared vehicles or flexible hours. The law requires that it be negotiated with the legal representatives of employees and, if there are none, with a negotiating committee made up of the company and union representatives.
Very large workplaces have an additional requirement: those with more than 1,000 people in municipalities or metropolitan areas of more than 500,000 inhabitants must include measures to reduce peak-hour mobility. The law also provides for subsidies to encourage the drawing up of plans and amends the Workers’ Statute so that these measures form part of collective bargaining.
Other novelties for companies
The law is not limited to staff commuting. It regulates freight transport, including safe and protected parking areas for heavy vehicles, and provides for coordination of logistics hubs and the logistics chain between authorities. It also deals with calculating and reporting the carbon footprint and with environmental and energy management systems in transport services.
It also includes a controlled testing space for mobility pilot projects, in which innovative companies could take part, and its own penalty regime, identifying the responsible parties. Transport, logistics and mobility companies should look closely at how it affects them, because the text is long and several of its obligations may depend on later regulations. Anyone operating in those sectors should also review the penalty provisions, to understand which conduct counts as an infringement and who is liable.
What to review
The first step is to count workplaces and headcount: the threshold refers to the employees of the workplace where they usually work, and per shift where there are shifts. Next, it is worth diagnosing how staff get to work, what alternatives exist in the area and which measures would be viable, before opening negotiations with employee representatives.
Two years seem a lot, but negotiating a plan, gathering data and approving measures takes time. It is also worth watching for subsidies and implementing regulations. This note is general information: consult your employment adviser on how the law applies to your organisation and workplaces. A practical option is to start with a mobility diagnosis —how each person gets to the workplace— and present a starting proposal to staff representatives.
Staff mobility is now a matter for negotiation, not merely for convenience.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
