The Sustainable Mobility Act 9/2025 requires workplaces with more than 200 employees (or more than 100 per shift) to implement a Sustainable Mobility to Work Plan (PMST), negotiated with workers’ representatives. The original deadline was 24 months from the Act’s entry into force, but Royal Decree-Law 7/2026, which has since been ratified by Congress, reduced it to 12 months: the deadline is 5 December 2026. If your business meets that threshold, the clock is already ticking.
At Waiis, we have put together this guide to the 2026 Sustainable Mobility Act to review who the rules affect, the deadlines following the amendment, what the plan must include and what may happen if the requirements are not met.
What is the Sustainable Mobility Act?
The Sustainable Mobility Act 9/2025 was published in the Official State Gazette (BOE) in early December 2025 and came into force on 5 December 2025. It is the framework law that, for the first time in Spain, requires certain workplaces to actively plan how their employees travel, with the aim of reducing individual use of private vehicles, travel-related emissions and congestion on access roads to industrial estates, hospitals, shopping centres and other major traffic generators.
The Act does not replace existing regional or local mobility rules ; it applies on a supplementary basis, meaning it governs areas that an autonomous community or local council has not already regulated more strictly. If your business is in an area with its own mobility ordinance (some local councils and metropolitan areas already required mobility plans before this Act), any local rules that are stricter take precedence on that specific point.
Which businesses are affected by the Sustainable Mobility Act (Act 9/2025)?
The Sustainable Mobility Act applies to workplaces that exceed either of these two thresholds:
- More than 200 employees at the workplace, counting the total workforce regardless of shift.
- More than 100 employees per shift, even if the workplace has fewer than 200 employees overall. This criterion is particularly relevant to factories, logistics centres, hospitals and other workplaces operating several rotating shifts.
The threshold applies to each workplace, not to the company as a whole: a company with several small sites may not be covered at any of them if each site remains below the threshold, whereas a single large logistics warehouse will be covered if it exceeds those figures. The Act also identifies industrial estates, hospitals and large shopping centres as “major activity centres”; they have additional obligations, including reviewing their mobility plan every five years and appointing their own mobility manager.
When does the Sustainable Mobility Act come into force?
The deadline has changed since the original Act was passed.
- Original deadline (Act 9/2025): 24 months from the Act’s entry into force (5 December 2025), that is, until 5 December 2027.
- Current deadline (following Royal Decree-Law 7/2026): Royal Decree-Law 7/2026, since ratified by the Congress of Deputies, shortened that period to 12 months. The new deadline for having the PMST in place is 5 December 2026.
In practice, this means affected businesses have half the time originally envisaged to assess their workforce’s mobility, design the plan, negotiate it with workers’ representatives and put it into operation.
What does the Sustainable Mobility Act require businesses to do?
The Sustainable Mobility Act does more than require businesses to have a PMST. For workplaces within its scope, it means analysing how employees travel, defining measures to encourage more sustainable mobility and monitoring how those measures are implemented.
In practice, a business must:
- Analyse employees’ regular journeys and the workplace’s mobility needs.
- Identify the main access-related challenges and opportunities.
- Design measures that encourage alternatives to individual private vehicles, such as public transport, active travel or car-sharing.
- Negotiate the plan with the workers’ legal representatives.
- Implement the planned measures and monitor their results.
Therefore, a PMST should not be treated as a document that is prepared once and filed away, but as a tool for managing and improving mobility associated with the workplace.
The Sustainable Mobility Act and businesses: a summary
In summary, the Sustainable Mobility Act 9/2025 establishes a framework to promote more efficient and sustainable mobility in Spain and requires certain workplaces to have a Sustainable Mobility to Work Plan. Workplaces with more than 200 employees or more than 100 per shift must have their PMST in place within the deadline set by the current legislation, which is 5 December 2026.
| Legislation | Act 9/2025 of 3 December on Sustainable Mobility |
| Entry into force | 5 December 2025 |
| Workplaces covered | More than 200 employees or more than 100 per shift |
| Main requirement | Have a PMST in place |
| Current deadline | 5 December 2026 |
| Purpose | Improve mobility and reduce the impact of commuting |
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