New Mobility Plans and Compliance: Adapting to Legal Requirements

New Mobility Plans and Compliance: Adapting to Legal Requirements

A significative new legislative development has recently been introduced for the business community: the obligation to implement Workplace Sustainable Mobility Plans. This new requirement, introduced by Law 9/2025 of 3 December on Sustainable Mobility, represents an organisational challenge with a direct impact on companies’ internal management, labour relations, and regulatory compliance.

What are Sustainable Mobility Plans?

A Sustainable Mobility Plan is a set of measures designed to optimise employees’ commute to and from work by encouraging the use of more efficient and environmentally friendly means of transport. Its purpose is to reduce reliance on private vehicles, lower the carbon footprint and improve employee’s quality of life.

Which companies are subject to this obligation?

The regulations establish that this obligation applies to companies and public sector entities with workplaces meeting any of the following criteria, pursuant to Article 26 of Law 9/2025, governing Workplace Sustainable Mobility Plans:

– Workplaces with more than 200 employees.

– Workplaces with 100 or more employees per shift.

In this regard, it is essential for each company to assess its particular situation, taking into account the total number of employees at each workplace, in order to determine whether it is subject to this obligation.

What is the implementation deadline?

Initially, Law 9/2025 established a 24-month period for the implementation of these plans. However, the subsequent Article 63 of Royal Decree-Law 7/2026, concerning the implementation of the Workplace Sustainable Mobility Plans regulated under Article 26 of that Law, reduced its period to twelve (12) months from the entry into force of the original law. Consequently, the new implementation deadline is 5 December 2026. This amendment significantly accelerates the need for affected companies to adapt.

Key implications for your company:

– Collective bargaining obligation: The Third Final Provision, amending the revised text of the Workers’ Statute Law, approved by Royal Legislative Decree 2/2015 of 23 October, introduces the obligation to negotiate these plans with the employees’ legal representatives (RLT, by its Spanish acronym). The absence of employee representatives does not simplify the process; rather, negotiations must instead be conducted with the sector’s authorised trade unions, in a manner similar to that established for Equality Plans.

– Minimum content of the plan: The plan must include a mobility assessment, measurable objectives, specific measures (such as remote working, collective transport, etc.) and the appointment of a Mobility Manager.

– Non-compliance Consequences: Failure to implement a mobility plan may give rise to several consequences, including the repayment of public grants received, as well as possible administrative sanctions.

How can Bové Montero assist you?

The proper implementation of a Sustainable Mobility Plan requires a detailed legal and technical analysis. Our Labour Team can assist you in the following areas:

1. Mandatory requirements analysis and initial assessment: We carry out an assessment of your company’s structure and workforce to determine whether it is subject to this obligation, and we evaluate its starting point in terms of mobility.

2. Drafting and design of the plan: We advise you on the preparation of a tailored plan, ensuring that it meets the minimum legal requirements and is realistic and effective for your organisation.

3. Avice during collective bargaining: We assist you throughout the negotiation process with the employee representatives in order to reach an agreement that balances sustainability objectives with operational and labour needs.

4. Support with implementation and monitoring: We assist you with the implementation of the agreed measures, as well as with the appointment and training of the Mobility Manager. In addition, we help you prepare the biennial monitoring reports required by the applicable regulations.

5. Defence and advice in the event of non-compliance: In the event of requests from the authorities or sanctioning proceedings, we provide specialised legal advice and defence in order to protect your company’s interests.

We recommend that you anticipate this new requirement and turn it into an opportunity to improve your organisation’s management, sustainability and image.

Furthermore, alongside this new mobility regulation, we would like to also highlight the crucial importance of Equality Plans, which are already a fully enforceable obligation for companies with more than 50 employees, non-compliance with which may result in very serious consequences. The proper implementation of these plans, together with overall compliance with labour regulations, including the pay register, working time recording obligations, the digital disconnection protocol and other labour compliance obligations applicable to all companies regardless of their size, requires a detailed legal and technical analysis.

Bové Montero’s Labour Team offers a comprehensive service designed to ensure your company’s legal certainty in matters of labour compliance.