Spain introduces mandatory Commute Plans: everything you need to know about Ley 9/2025

With the entry into force of Ley 9/2025 on Sustainable Mobility, Spain has introduced the most comprehensive regulatory framework in Europe for commute mobility plans. For those working in mobility management (gestores de movilidad, Mobility Managers, HR Directors, sustainability officers), this is a major legislative development with immediate operational implications.

In this article we analyse the Spanish regulation in detail and compare it with the Italian PSCL (Piani degli Spostamenti Casa-Lavoro) system, the first in Europe to introduce a similar obligation and today a useful benchmark for identifying strengths and areas for improvement.

A new law, a very tight deadline

Ley 9/2025, de 3 de diciembre, de Movilidad Sostenible was published in the BOE on 4 December 2025, entering into force the following day. It originally set a 24-month deadline for plan adoption, but Real Decreto-ley 7/2026 of 20 March halved it to 12 months, bringing the deadline to 5 December 2026.

In practice, Spanish companies have roughly eight months to design, negotiate with employee representatives, and implement a complete commute mobility plan. For those familiar with the process (data collection, territorial transport supply analysis, measure definition, negotiation), this is an extremely compressed timeline.

Who is required to comply and what they must do

The obligation applies to all companies and public bodies with workplaces exceeding 200 workers, or 100 workers per shift. The obligation is nationwide: no geographic filter applies, unlike other European models that limit the requirement to certain urban areas.

The mandatory plan contents are broad. The law requires the inclusion of solutions covering the full spectrum of sustainable mobility: active mobility (walking, cycling), collective transport, low or zero-emission mobility, shared and collaborative mobility solutions, electric vehicle charging infrastructure, remote working, as well as road safety measures and commuting accident prevention.

A key point: plans must account not only for employees, but also for visitors, suppliers, and anyone accessing the workplace. They must also be coordinated with the sustainable mobility plans of the local authorities where the workplace is located.

The law introduces the figure of the gestor de movilidad, mandatory for large activity centres and with the possibility of regulatory extension to workplaces subject to the PMST.

For centres with more than 1,000 workers in metropolitan areas above 500,000 inhabitants, enhanced requirements apply, with specific measures for reducing peak-hour mobility, promoting zero-emission transport, and installing charging infrastructure.

The national PMST regime operates as a residual norm: it applies only where no specific regulation from the autonomous communities already exists. Catalonia, for example, already has its own regulation (Decreto 132/2024) with partly different thresholds and requirements.

District plans: the most significant innovation

Perhaps the most innovative aspect of Ley 9/2025 is the provision for sustainable mobility plans for large activity centres (art. 25): not company plans, but district plans.

A large activity centre (an industrial area, a business district, a hospital or university campus) aggregating multiple organisations is required to approve its own sustainable mobility plan, review it at least every five years, and designate a gestor de movilidad del centro de actividad responsible for its preparation, coordination, and updating.

This represents an intermediate planning level between the company plan and the urban plan: the plan is not limited to a single company’s employees but encompasses the entire mobility demand generated by the territorial hub, and must be coordinated with the local authority’s mobility plans.

In other words, Spain has institutionalised the idea that commuting is not just an individual employer’s problem, but a territorial system problem that must be addressed at the scale where it actually occurs. This is a principle we know well: it underpins the Manifesto of Territorial Coalitions of Mobility Managers that Wiseair presented in May 2025 with the patronage of the City of Milan, proposing exactly this shift from isolated company planning to coordination among organisations sharing the same territory and transport infrastructure. Seeing this principle translated into a regulatory obligation confirms the direction is right.

Collective bargaining as a structural lever

Ley 9/2025 amends article 85.1 of the Spanish Workers’ Statute, making sustainable mobility a mandatory subject of collective bargaining. All collective agreements whose negotiation process began after 5 December 2025 must include measures to promote plan adoption.

Plan preparation must take place in negotiation with the workers’ legal representatives. In the absence of company representation, the law provides for the establishment of a union negotiating committee composed of the most representative unions in the sector.

This is an architecture where commute mobility is not an isolated technical compliance exercise, but becomes an integral part of the social dialogue between company and workers. A choice no other European country has made with this degree of formalisation.

The sanctions regime

Failure to adopt the PMST, when it causes harm to the mobility system, constitutes a minor infringement, punishable with fines from 101 to 2,000 euros. Repeated violations or the provision of false data are classified as serious infringements (from 2,001 to 6,000 euros).

But the most effective mechanism is another: obligated companies that benefit from direct public aid under RDL 7/2026 and fail to adopt a PMST must return the aid received. For many companies, this financial incentive carries more weight than the fine itself.

The pecuniary sanctions are moderate in themselves. But the principle they establish is clear: plan adoption is an obligation with consequences, not a recommendation.

Registration and monitoring: the EDIM platform

Plans and their related indicators must be registered in EDIM (Espacio de Datos Integrado de Movilidad), a national digital registry created by the Ministry of Transport. The objective is to centralise commute mobility data in a single system, enabling aggregate monitoring and evidence-based transport policy formulation.

Plans must undergo biennial follow-up, with a first mandatory monitoring report due within two years of approval, aimed at assessing the level of implementation of the planned measures.

The law also provides for the possibility of public funding lines to support companies in plan preparation and implementation.

Comparison with the Italian model

Italy was the first European country to introduce a structured obligation for commute mobility planning: the 1998 Ronchi Decree established the Mobility Manager role for companies with more than 300 employees. The 2020 Rilancio Decree lowered the threshold to 100 employees, and the Ministerial Decree of 12 May 2021 defined roles, procedures, and operational guidelines in detail.

The comparison between the two systems is instructive in both directions.

Where the Italian model is stronger. Italy has a lower threshold (100 employees vs 200), reaching a broader base of companies. It requires annual plan updates (vs biennial Spanish follow-up), generating a more frequent review cycle. It introduced the Area Mobility Manager, a municipal coordinator who oversees the plans of different companies in a territory, an institutional coordination function Spain lacks. And it has detailed, operational PSCL guidelines with a structured methodology that Spain has yet to publish.

Where the Spanish model is stronger. Spain provides for sanctions (Italy does not, which has significantly weakened the effectiveness of the Italian obligation). It integrates mobility into collective bargaining (Italy does not). It creates a national data registry (Italy delegates collection to individual municipalities, which rarely manage to aggregate the data). And, most importantly, it institutionalises district plans, a level of coordination that in Italy remains dependent on the voluntary Territorial Coalitions.

Three insights for Italian regulatory evolution

The comparison with Spain is not about importing a model, but about identifying concrete directions for evolution. Three seem particularly relevant.

1. Introduce district mobility plans. The Spanish provision for large activity centre plans fills a gap that is particularly felt in Italy. The Italian PSCL is a company plan: each company analyses its own employees, its own sites, its own alternatives. But mobility does not respect organisational boundaries. In an industrial district, a business park, a hospital area, dozens of companies generate commuting flows that rely on the same infrastructure, at the same times, with the same bottlenecks. Addressing them in isolation means forgoing solutions (a shared shuttle, a cycling corridor, a joint negotiation with public transport) that only make sense at the territorial scale.

This is exactly the principle behind the Territorial Coalitions of Mobility Managers, the operational model that Wiseair presented in May 2025 with the patronage of the City of Milan and captured in a Manifesto signed by companies, institutions, and associations. As Carla Messina of the Ministry of Infrastructure and Transport observed on that occasion, plans too often remain on paper when the Mobility Manager operates in isolation. Spain has chosen to make this level of coordination a regulatory obligation. Italy could do the same, formalising the possibility (or obligation, for hubs above certain occupational thresholds) of adopting district PSCLs that integrate and coordinate the plans of individual companies located in the same territory. The benefits would be clear: sufficient critical mass to justify infrastructure investment, greater bargaining power with transport operators, cost reduction through economies of scale, and above all a structural link between aggregate mobility demand and territorial transport policies.

2. Create a national data infrastructure. Spain’s EDIM represents a correct ambition: centralising mobility plan data in a single digital system. In Italy, PSCLs are transmitted to individual municipalities, which rarely have the resources to aggregate, analyse, and translate them into transport policies. A national (or at least regional) registry would enable a shift from document collection to data-driven planning: identifying demand patterns, dimensioning public transport services, assessing the aggregate impact of adopted measures. For those, like Wiseair, working on the convergence between employee mobility demand and territorial transport supply, this would be a transformative step.

3. Link the PSCL to collective bargaining. Spain’s choice to integrate mobility into labour law through the negotiation obligation is ambitious and may not be immediately replicable in Italy. But a more structured link between the PSCL and company negotiation processes (even if only in the form of an obligation to inform and consult employee representatives) would make the plan a shared instrument rather than a unilateral employer exercise. This would also have the effect of strengthening the Mobility Manager role, giving them an institutional counterpart within the company.

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Ley 9/2025 is not an isolated experiment. It is part of a European trend towards the progressive formalisation of commute mobility as an employer responsibility, which France initiated with the Plan de Mobilité Employeur and which Spain now takes to a higher level of detail and enforceability. For those working in mobility management — in Spain, in Italy, in Europe — the time to get structured is now.