In Spain, Ley 9/2025 (article 26) requires in-scope workplaces to prepare a Plan de Transporte Sostenible al Trabajo (PTST) to reduce the environmental impact of employee commuting.
The PTST must be negotiated with the legal representation of workers and it should include sustainable mobility measures following a hierarchy.
The practical deadline to have the PTST ready is 5 December 2026 (the law was published on 5 December 2025; the original deadline of 24 months was reduced to 12 months by Real Decreto-ley 7/2026). First follow-up reporting is due 2 years after approval, and follow-up continues every 2 years.
In this article we focus on the operational reality: what commuting data you need (transport mode, commuting distance, frequency, and telework days), how it connects with Scope 3 Category 7, and how to build traceable, comparable evidence for PTST preparation and follow-up.
Who is in scope for Article 26 (PTST), in practice?
This obligation applies to private companies and public sector entities with:
- workplaces with more than 200 employees, or
- workplaces with 100 employees per shift in the usual workplace (the usual workplace is that centre).
What the PTST must include (and why negotiation matters)
At a minimum, your PTST needs a defensible measure hierarchy and a data basis that can be discussed with employee representatives.
That is where governed commuting evidence becomes important for your broader ESG work, including your Carbon Footprint for commuting.
Why PTST preparation matters in practice
Employee commuting is a compliance risk with real business impact
Workplace mobility is not a side topic. It affects how you demonstrate compliance, how you reduce emissions and how prepared you are for scrutiny.
When your data is structured, your plan stops depending on last-minute efforts. It becomes a repeatable process.
The market cares about evidence, not assumptions
Each measure needs justification. You need traceable inputs such as distances, transport modes and frequency.
Without consistency in methodology, you end up with narratives that “fit” but do not stand when challenged.
Commuting also connects to broader ESG work. If you manage reporting aligned with CSRD principles and your disclosure approach benefits from double materiality CSRD, commuting evidence fits more smoothly into your system.
What PTST commuting data means and why it often fails
Many data sources and too much manual work
Mobility data often lives in different places. Some teams use commuting surveys. Others rely on spreadsheets. The challenge appears when you cannot clearly define boundaries, update cadence or data ownership.
If your model is not governed, emissions calculation and follow-up lose momentum. When the plan cycle starts, you switch into “urgent mode”.
Traceability is the proof layer for plan credibility
A sustainable mobility plan requires a hierarchy of measures. It typically includes mobility active options, public transport, zero-emission vehicles, shared mobility, charging infrastructure and telework where possible.
It also includes safety and training, and compensation only when emissions are not reducible in practice.
This order matters because it explains the logic behind your choices. Traceability turns that logic into evidence.
Negotiation with employee representatives requires usable information
The PTST framework includes negotiation with employee representatives. That means your data needs to be understandable and consistent, not just stored somewhere.
If evidence is scattered, negotiation becomes complex. If evidence is structured, governance decisions are faster and more defensible.
From commuting evidence to PTST design and follow-up
Baseline and emissions to design the plan
Plans start with diagnosis. You need a baseline that reflects real commuting patterns and supports the measures you choose.
Practically, this means calculating commuting emissions as part of your Carbon Footprint, typically framed as Scope 3, Category 7, and aligning them with your reporting approach.
Structure the plan measures using a clear hierarchy
The PTST model shows a key pattern: build the plan from what can be reduced first, then move to residual measures and compensation when needed.
If you convert data into measures with that logic, your plan remains coherent and easier to defend.
Review cycles: the plan must evolve, not be delivered once
The law sets follow-up reporting cycles. The lesson is universal: you need inter-period comparison to assess what changed and why.
When data is integrated, follow-up becomes a controlled update instead of a full rewrite.
What PTST preparation needs in practice
A document structure that keeps evidence traceable
Your PTST is more than calculations: it needs a clear measure hierarchy and a data basis you can point to during review and follow-up.
The goal is to keep inputs, assumptions and outcomes consistent enough that the story does not change when you update it two years later.
A measure hierarchy you can justify with commuting data
Because the PTST must follow a hierarchy, you need a defensible link between commuting inputs (transport mode, commuting distance, frequency, and telework days where relevant) and the measures you prioritise.
That also helps the negotiation process with employee representatives, because the data is understandable and consistent.
Follow-up ready inputs for inter-period comparison
Follow-up reporting every 2 years works only if you can compare like-for-like over time.
That usually means reusing the same definitions, maintaining a governed evidence base and updating the same inputs on a predictable cadence.
Potential sanctions and how to reduce exposure
Possible minor infringement and sanctions range
Depending on the circumstances and the administration’s assessment, the regime can include infracción leve with sanctions of 101 to 2,000 EUR when the key expectations linked to the PTST deadline and follow-up reporting are not met.
In practice, the risk is most commonly associated with:
- missing the PTST deadline
- failing to prepare the required follow-up reports
If your organisation has received public support, a consequence in relevant cases can include the repayment of the received aid.
You reduce exposure by treating the PTST as an evidence process: a clear measure hierarchy, governed commuting inputs and a follow-up cycle that stays consistent over time.
Common challenges and how to address them with method
1) Survey design that does not produce calculation-ready inputs
Surveys work when they capture what the calculation needs: distances, transport mode, commuting frequency and telework days where relevant.
If the input data is not enough, you cannot justify measures properly.
2) Evidence stored without a conversion path into documentation
Some teams measure but do not prepare the documentation needed for PTST preparation and follow-up. Others recreate content manually for each cycle.
The most effective approach is a governed process: collect, structure and calculate with consistent methodology so the evidence base stays reusable.
3) Updating evidence over time without breaking traceability
Plans change. People change. Your evidence layer must keep up.
Without governance of data, follow-up becomes costly and slow.
How to start: first steps to avoid wasting time
Step 1: confirm whether your organisation needs a structured plan cycle
Start by confirming whether you are in scope for Article 26 PTST in Spain (workplaces with more than 200 employees, or 100 employees per shift in the usual workplace) and whether the PTST must be negotiated with worker representatives.
That prevents unnecessary work.
Step 2: run mobility surveys to capture commuting and telework patterns
Capture must be designed for usability. It should be calculation-ready and usable for governance.
Step 3: translate baseline into measures and negotiation-ready actions
Once the baseline is set, you convert mobility patterns into actions.
Here, process automation helps you reduce duplication between data capture and plan creation.
Step 4: generate the plan and plan the follow-up cadence
Finally, you produce the plan document and define how you will compare outcomes over time.
Then your plan becomes a system of continuous improvement.
Dcycle: structuring PTST-ready commuting evidence
What we do and what we do not do
We are not an audit firm or a consultancy that appears only at deadlines. We are a solution that helps your organisation:
- measure commuting-related Carbon Footprint evidence
- capture and centralise commuting inputs through employee mobility surveys (transport mode, commuting distance, frequency and telework days where relevant)
- structure the evidence base needed for PTST preparation and follow-up
- support inter-period comparison for the required 2-year follow-up cadence
- connect commuting emissions with broader ESG work, including use cases like EINF, SBTi, CSRD, Taxonomy and ISOs (or whatever you use internally)
- keep definitions, assumptions and calculations consistent over time so your evidence remains explainable to employee representatives
You still own the PTST negotiation process and the final documentation, but Dcycle helps you keep the underlying evidence coherent from one cycle to the next.
How it works at a high level
- We collect commuting inputs through mobility surveys.
- We calculate commuting emissions as part of your Carbon Footprint (typically framed as Scope 3, Category 7).
- We help you structure the evidence behind the measure hierarchy and the choices you prioritise.
- We support inter-period comparisons so follow-up reporting is based on consistent baselines and definitions.
Key capabilities
- mobility surveys for commuting and employee mobility
- emissions calculation for commuting (Scope 3, employee commuting category)
- evidence base structuring for PTST preparation and follow-up
- inter-period comparison for follow-up
- support for mobility measures and expected reductions
- centralised commuting inputs with traceability
If you also want to connect this with broader governance, you can align your workflow with compliance and sustainable decision-making through sustainable governance.
Frequently Asked Questions (FAQs)
What does PTST mean in practice for employers?
It is a workplace mobility plan designed to reduce the environmental impact of commuting, based on a diagnosis, a hierarchy of measures and evidence-backed tracking.
What data do you need to build a defensible plan?
You need commuting inputs (distance, transport mode and frequency), telework patterns where relevant, and an evidence structure you can reuse in follow-up cycles.
When do you have to have the PTST ready, and what comes next?
In Spain, the practical deadline to have the PTST ready is 5 December 2026. After approval, the first follow-up report is due 2 years later, and follow-up continues every 2 years.
Do you have to compensate residual emissions?
Compensation typically appears when emissions cannot be reduced further in practice. The key is the hierarchy and the evidence behind your decision.
How often should you run follow-up?
PTST follow-up starts 2 years after approval and continues every 2 years. The operational lesson is the same: you need inter-period comparison based on consistent definitions and inputs.
What happens if you miss the PTST deadline or the follow-up cycle?
Depending on the circumstances, the regime can include infracción leve with sanctions of 101 to 2,000 EUR when the PTST deadline or follow-up expectations are not met. If your organisation has received public support, repayment of the received aid can apply in relevant cases.
To reduce exposure, confirm whether you are in scope, build the PTST with traceable commuting inputs, and maintain a follow-up cadence that preserves comparability over time.