LABOR AND SOCIAL SECURITY DIVISION
Growing social concern about environmental, social, and economic sustainability is progressively transforming many areas of everyday life. The world of work is no exception. In fact, daily commuting to the workplace is one of the factors with the greatest impact on urban mobility and on organizations’ environmental footprint.
In this context, Law 9/2025, of December 3, on Sustainable Mobility introduces a set of measures aimed at reducing the environmental impact arising from work-related travel. The regulation seeks to promote a more efficient, equitable, and environmentally friendly transport model, while also introducing new obligations for companies regarding the mobility of their workforce.
One of the main instruments introduced by the law is the Sustainable Workplace Mobility Plans (SWMPs).
Although Law 9/2025, of December 3, initially established that these plans would be required from December 5, 2027 (24 months after its entry into force), Royal Decree-Law 7/2026, of March 20—approving the Comprehensive Response Plan to the Crisis in the Middle East and published in the Official State Gazette on March 21—brings this requirement forward by one year. That is, from December 5, 2026, companies must have a Sustainable Workplace Mobility Plan in place for workplaces with more than 200 employees, or more than 100 employees per shift.
The aim of these plans is to analyze commuting patterns to workplaces and design measures to reduce their environmental impact, improve travel efficiency, and enhance road safety.
The law does not establish a closed list of actions but provides guidance on the types of measures to be included. These include: (i) promoting active mobility, such as walking or cycling; (ii) encouraging collective transport; (iii) promoting low-or zero-emission vehicles; (iv) shared or collaborative mobility systems; (v) measures to facilitate the charging of electric vehicles; and (vi) the implementation or expansion of remote work, where the activity allows.
In addition, the plans must include measures to improve road safety and prevent accidents during commuting, including specific training initiatives.
A relevant aspect is that these measures must not only consider employees but also visitors, suppliers, and anyone who regularly accesses the facilities.
With regard to high-occupancy workplaces (those with more than 1,000 employees located in municipalities or metropolitan areas with more than 500,000 inhabitants), measures must be included to reduce employee mobility during peak hours or within the working day.
SWMPs must be negotiated with the legal representatives of employees. In companies where no such representation exists, a negotiating committee must be established, composed of the most representative trade unions and unions representative of the company’s sector.
Approval of the plan does not mark the end of the process. The regulations require periodic monitoring to assess the level of implementation of the adopted measures.
Specifically, companies must prepare a monitoring report within two years of the plan’s approval and subsequently repeat this analysis every two years throughout its duration.
Likewise, both the plan and its updates and reports must be communicated to the competent regional authority, which will incorporate them into the Integrated Mobility Data Space within three months of their adoption.
Failure to comply with these obligations may result in administrative penalties of up to €6,000, reinforcing the importance of companies beginning to plan their adaptation to this new regulatory framework in advance.
Sustainable mobility thus becomes a new dimension of business management and labor relations. Beyond mere regulatory compliance, SWMPs can become a strategic tool to improve work organization, reduce costs associated with commuting, and strengthen companies’ environmental commitment.
In short, the new regulatory framework encourages organizations to take an active role in transforming mobility models, integrating sustainability into business planning and human resources management.
Preparing a SWMP requires analyzing employees’ commuting habits, designing measures tailored to the reality of the workplace, and negotiating its content with employee representatives.
Given that the requirement for these plans has been brought forward by one year compared to the original schedule, it is necessary to begin working on them now in order to implement these measures in an orderly manner, avoid improvisation, and turn this legal obligation into an opportunity to improve work organization and advance sustainability policies.
