YourcompanyhasuntilDecember2026tohaveaSustainableMobilityPlan

Ley 9/2025 de Movilidad Sostenible is Spain's Sustainable Mobility Law, published in the BOE on 4 December 2025 and in force since 5 December 2025. It requires companies above certain workforce thresholds to approve a Plan de Movilidad Sostenible al Trabajo (PMST) and sets obligations for mandatory diagnostic, negotiation with employee representatives, biennial reporting, and registration in the national EDIM data space.

The law applies to: (1) workplaces with more than 200 employees, (2) workplaces with more than 100 employees per shift, and (3) large activity centers such as business parks, logistics hubs, hospitals, and shopping centers with high footfall (Art. 25). It covers both private companies and Spanish public-sector entities. Where several centers share a location, the law encourages coordinated joint plans.

The original deadline under Ley 9/2025 was 24 months from entry into force, placing it at 5 December 2027. RDL 7/2026, in force since 22 March 2026, reduced that period to 12 months and brought the deadline forward to 5 December 2026. Important: RDL 7/2026 must be ratified by the Spanish Parliament within 30 days of publication. If not ratified, the original December 2027 deadline applies. We recommend monitoring this ratification before committing to December 2026 as the binding date.

The plan must begin with a mandatory diagnostic: transport modes used by employees, distances and shifts, and a 5-year history of commuting accidents (in itinere and in mission). The plan itself must then address active mobility (walking and cycling with supporting infrastructure), collective transport (company buses, shuttles, public transport coordination), low-emission vehicles (EVs, hybrids, and charging points), carpooling, telework, flexible working hours, and road safety protocols. For workplaces with 1,000+ employees in cities of 500,000+ inhabitants, additional peak-hour reduction measures are required.

Not having a PMST in place (if it causes harm to the mobility system) is a minor infraction: fines of 101 to 2,000 euros with a 6-month statute of limitations. Not submitting the biennial follow-up report carries the same range. Providing false data to the EDIM or repeatedly failing to submit data is a serious infraction: fines of 2,001 to 6,000 euros with a 3-year statute of limitations. Companies that received direct subsidies under RDL 7/2026 and fail to comply with the PMST obligation must repay those subsidies in full.

The PMST must be negotiated with the legal representation of workers (RLT). If no such representation exists, a negotiating committee must be formed with sectoral trade unions. This obligation has been in force since 5 December 2025, as the law amends Art. 85.1 of the Workers' Statute. Large activity centers must also designate a Mobility Manager responsible for the plan. All plans must be communicated to the EDIM registry once approved, and progress must be evaluated in a report every two years.

Dcycle's commuting survey already collects the transport mode data required for the PMST diagnostic as part of Scope 3 Category 7 GHG emissions reporting. With an extended module adding shift data, reasons for transport choice, and perceived route risks, Dcycle turns existing ESG data collection into a complete legal diagnostic without duplicating effort across sustainability and HR teams. The result: a single survey that satisfies both GHG Protocol Scope 3 requirements and the Ley 9/2025 diagnostic obligation.

The current Dcycle commuting survey covers transport mode and distance, the core inputs for both Scope 3 emissions and the PMST diagnostic. The extended PMST module adds three fields not currently captured: employee shift, reason for current transport choice, and perceived commute risks. The 5-year in itinere accident history required by the law must be sourced from the company's occupational health records; Dcycle can help structure and store this data but does not capture it directly from source systems.