Sustainable Mobility to Work Plan (PMST): what it is, who needs one and how to implement it

Employee mobility is no longer just a matter of commuting. For many businesses, how their workforce gets to the workplace affects costs, road safety, parking access and sustainability goals.

Since the Sustainable Mobility Act 9/2025 came into force, certain workplaces have been required to have a Sustainable Mobility to Work Plan (PMST). The Act came into force on 5 December 2025 and, although the original text set a 24-month deadline, Royal Decree-Law 7/2026 of 20 March amended Article 26 and shortened the deadline to 12 months. This means the deadline for having a PMST in place is 5 December 2026. 

To explain what a Sustainable Mobility to Work Plan is, who is required to prepare one and what steps a business should take to implement it, Waiis tells you everything you need to know. 

What is a Sustainable Mobility to Work Plan (PMST)?

A Sustainable Mobility to Work Plan (PMST) is a set of measures designed to rationalise journeys associated with a workplace and encourage more sustainable, safer and more efficient forms of mobility. 

The Sustainable Mobility Act states that these plans must be led by workplace management and drawn up as part of collective bargaining. They are also not limited to employees’ journeys: among others, they must take customers, suppliers and visitors into account.  

A PMST is therefore not simply a recommendation that employees use their cars less. It must be based on an analysis of actual mobility at the workplace and set out measures tailored to its needs. 

Its objectives may include: 

• Reducing individual use of private vehicles.  
• Encouraging public transport and active travel.  
• Promoting car-sharing and other collaborative mobility solutions.  
• Improving road safety during journeys.  
• Reducing energy consumption and mobility-related emissions.  
• Improving access to the workplace. 

Which businesses must have a Sustainable Mobility to Work Plan in 2026?

In 2026, businesses and public-sector bodies must have a PMST if they have workplaces with more than 200 employees or more than 100 employees per shift, as set out in Article 26 of Act 9/2025. The requirement applies to each workplace, not simply to the total number of employees across a business. Therefore, a business with several workplaces must assess each one individually to determine whether it is required to prepare a plan. 

In general:

Workplace	PMST required
More than 200 employees	Yes
100 employees per shift	Yes
Fewer than 200 employees	Not under this national threshold, although other requirements may apply
Several workplaces	Each workplace is assessed according to its own circumstances

In addition, the regulations cover other cases and allow the competent authorities to set further requirements in certain areas. Therefore, falling below the thresholds above does not necessarily mean that a business is exempt from every requirement relating to sustainable mobility. 

What should a Sustainable Mobility to Work Plan include? 

The regulations set out the main areas a PMST must address, but its specific content must reflect the circumstances of each workplace.

Mobility assessment

Before deciding which measures to introduce, it is necessary to understand how people currently travel to the workplace. The assessment may examine matters such as: 

• Where employees live.  
• Modes of transport used.  
• Journey distance and duration.  
• Arrival and departure times.  
• Availability of public transport.  
• Parking availability and occupancy.  
• Whether people can walk or cycle to work.  
• Accidents or risks associated with journeys.  

This stage is particularly important because there is no one-size-fits-all PMST. A measure that works for a workplace in a city centre may be unrealistic for a business located on an industrial estate with no nearby public transport.

Objectives and measures

Using the assessment findings, a business can set specific objectives and define the measures needed to achieve them. Act 9/2025 covers options including active travel, public transport, low-emission vehicles, shared and collaborative mobility, the use and charging of zero-emission vehicles, and remote working where possible. It also includes road-safety and accident-prevention measures.  

Implementation and monitoring

A PMST should not remain just a document. The business needs to establish how the measures will be put into practice and how it will check whether they are working. The regulations require implementation to be monitored and stipulate that a monitoring report must in all cases be prepared two years after the plan is approved and every two years thereafter while it remains in force. 

How to implement a Sustainable Mobility to Work Plan step by step

Implementing a Sustainable Mobility to Work Plan starts with understanding how employees travel and what their main mobility needs are. Based on that assessment, a business can set objectives, select measures, put them in place and measure the results. 

1. Check whether your workplace is covered: First, determine whether the workplace exceeds the thresholds set by the regulations, and check whether any additional local requirements apply. 

2. Assess how employees travel: Gather information about origins, schedules, modes of transport, access difficulties and employees’ needs. 

3. Involve employees: The PMST must be negotiated with the legal representatives of the workforce. If there are no legal representatives, the Act sets out a specific process for forming a negotiating committee.  

4. Set realistic objectives. For example, reduce individual use of private vehicles, increase the number of employees using public transport or encourage them to share a car. 

5. Select the measures: The aim is not to introduce every possible option, but to choose those that make sense in light of the assessment. 

6. Measure the results: Set indicators to show whether the measures are working, and use the findings to make improvements.

How can Waiis help implement a Sustainable Mobility to Work Plan?

Using tools to manage a PMST is the easiest and most effective way to understand how employees travel, put measures into practice and collect metrics to assess their results. Waiis brings these functions together on one platform, helping businesses move from assessment to action.

Assessment based on real data

The first step is to understand how employees travel. WAIIS can collect information through real mobility data and integrated surveys, helping identify workforce origins, destinations, schedules and needs. This allows a business to spot mobility patterns and see where measures such as car-sharing make sense. 

Creating and updating the PMST 

Using the information collected, WAIIS can generate a draft Sustainable Mobility to Work Plan based on the company’s mobility data. The platform can also keep the analysis connected to changing travel patterns, preventing the PMST from becoming a static document. 

Smart Match to encourage car-sharing

Once the potential for shared mobility has been identified, Smart Match technology connects employees with compatible routes and schedules, also taking their workplace into account. The system makes it easier to organise journeys and calculates the meeting point, making car-sharing straightforward for the workforce.

Alternatives when there is no match

A suitable match is not always available. To prevent this from becoming an obstacle, WAIIS also offers the option to book a taxi or private-hire vehicle at a fixed price when there is no match, giving employees an alternative way to make their journey. 

Incentives and monitoring results

WAIIS also makes it possible to manage the Energy Saving Certificates (CAE) generated by shared journeys and turn energy savings into an economic opportunity for the business. Employees can also receive incentives for the kilometres they share.

Everything is centralised in a dashboard, where the business can review journeys and measure indicators such as CO₂ avoided. WAIIS can therefore support different stages of a PMST: assessing mobility, implementing shared-mobility measures, encouraging their use and measuring the impact achieved. The goal is for the plan to become more than a document and serve as a useful tool for managing the company’s day-to-day mobility.

What are the consequences of failing to comply with the Sustainable Mobility to Work Plan?

If a business is required to have a Sustainable Mobility to Work Plan, failing to have one by the deadline may have consequences beyond a simple administrative matter. The regulations provide for offences and penalties for workplaces exceeding the thresholds of 200 employees or 100 per shift. 

These are the main consequences to bear in mind before 5 December 2026: 

• Financial penalties: 
• Failure to have a PMST by the deadline: a minor offence, €101–€2,000 where this harms the mobility system.  
• Failure to prepare the monitoring report: a minor offence, €101–€2,000 where harm is caused.  
• Certain offences relating to EDIM data: serious offences, €2,001–€6,000. 
• Loss or repayment of grants. Non-compliance may also affect access to or retention of certain grants where their rules set requirements relating to the PMST. 
• Lost economic opportunities. Not implementing tools to measure and manage journeys may also mean missing out on Energy Saving Certificates (CAE) generated by car-sharing. With WAIIS, these savings can be converted into revenue for the business.  
• Impact on tenders and ESG criteria. Not having a PMST may affect participation in public tenders and negatively affect the organisation’s ESG indicators, with possible consequences for its reputation among investors and customers.  

Ultimately, complying with the Sustainable Mobility to Work Plan should not be viewed solely as an obligation to deal with before a certain date. It can also be an opportunity to better understand workforce mobility, reduce costs and move towards sustainable mobility.