What changed
Spain’s Sustainable Mobility Law (Ley 9/2025) was published on December 4, 2025. It introduced a binding obligation for companies to develop a Plan de Movilidad Sostenible al Trabajo (PMST), a Sustainable Commute Plan, for every qualifying workplace.
The original timeline gave companies 24 months, until December 2027. That’s no longer the case.
Royal Decree-Law 7/2026 has accelerated the schedule to just 12 months from the law’s entry into force. The new deadline is December 5, 2026. Roughly 8 months from now.
Non-compliance is classified as a minor infraction, with fines ranging from €101 to €2,000 per violation. The fine applies per workplace, not per company, which adds up quickly for multi-site organizations.
Who needs to comply
The law applies per workplace, not per legal entity. This catches many companies off guard.
Every site with more than 200 employees needs its own PMST. So does any site with more than 100 workers per shift whose habitual workplace is that location.
A company with four large offices across Spain needs four separate plans, each tailored to local conditions. Sites with over 1,000 workers in municipalities exceeding 500,000 inhabitants (Madrid, Barcelona, Valencia, Seville, Zaragoza, or Malaga) face additional requirements to reduce peak-hour traffic.
What the PMST must include
Article 26 of the law requires a structured document with two mandatory phases.
Phase 1: Diagnostic. You need to map how your employees currently commute. This means collecting data on transport modes, distances, shift patterns, perceived barriers to sustainable alternatives, and safety risks during commuting.
Phase 2: Concrete measures. The plan must include real sustainable mobility solutions, prioritized by impact following a hierarchy principle: active mobility (cycling, walking), organized collective transport, low-emission mobility, carpooling, EV charging infrastructure, remote work where feasible, and road safety measures.
The PMST must be negotiated with employee representatives, registered in the EDIM (Spain’s integrated mobility data platform), and reviewed through a mandatory follow-up report every two years. The law also creates the role of mobility manager for high-occupancy sites.
The data connection most companies are missing
Here’s what makes this regulation different from a standalone mobility exercise.
If your company already measures Scope 3, Category 7 emissions under the GHG Protocol, covering employee commuting, your mobility survey already captures a significant portion of the data the PMST diagnostic requires: transport modes, distances, and frequencies.
One data collection process can serve two compliance outcomes: your carbon footprint reporting and the mandatory PMST diagnostic. Companies that treat these as separate workstreams will spend double the time surveying employees, processing data, and building reports to reach the same destination.
Those that integrate them get more accurate data, faster compliance, and a clearer picture of where mobility improvements drive the biggest emission reductions.
What to do this week
Start by auditing what data you already have.
Review what your current Scope 3, Category 7 calculations collect. If you already run a mobility survey for your carbon footprint, compare it against the PMST diagnostic requirements. The typical gaps are shift-pattern data, reasons behind transport choices, and perceived commuting risks. Add the PMST-specific questions to your next employee survey cycle.
If your company operates sites with 200+ employees in Spain, the time to act is now. Eight months go fast when you factor in union negotiation, administrative registration, and a mandatory follow-up report.
Book a demo to see how Dcycle’s mobility survey serves as the foundation for both your Scope 3 reporting and PMST diagnostic.