The regulatory framework for sustainable mobility in Spain has taken a key turn in 2026. With the approval of the Royal Decree-Law 7/2026, the Government has significantly shortened the deadlines for companies to implement their Sustainable Commuting Plan (PMST), reducing the adaptation period from 24 to 12 months. This means the deadline is brought forward to 5 December 2026, a year earlier than originally planned. This change accelerates the need for action and places many organisations in a more demanding scenario, where planning and implementation will need to be addressed more quickly.
The new Sustainable Mobility Act (Law 9/2025 of 3 December on Sustainable Mobility) approved on 13 November 2025 and published on 3 December 202, introduces direct obligations for companies regarding labour mobility. The rule prioritises The most sustainable modes of transport, such as walking or cycling and public transport, and advocates for digital and connected mobility to reduce emissions and improve the efficiency of corporate travel.
In this new framework, organisations exceeding a certain number of employees will be required to develop Sustainable Mobility to Work Plans (SMWP) and implement measures that promote safer, more efficient travel aligned with national and European climate objectives.
Although the regulation adds new responsibilities, it also opens the door to optimising resources, improving internal mobility and relying on legally recognised technological solutions to facilitate compliance, such as transport tickets. Edenred Mobility.
Companies in Spain are obliged to implement a Sustainable Commuting Plan (SCP) with over 200 employees, as well as those that have with over 100 employees per shift. Autonomous Communities will be able to adjust these thresholds according to their local characteristics, and public entities are also included within this requirement. In practice, many organisations that had never formally addressed their internal mobility will now have to do so.
The Sustainable Mobility Act was approved by Congress on 13 October 2025. However, Article 63 of Royal Decree-Law 7/2026, of 20 March 2026, has introduced a key change in the deadlines: reduced from 24 to 12 months the period for obligated companies to prepare and implement their Sustainable Mobility Plan for Work. Consequently, the deadline is brought forward to 5 December 2026, one year ahead of the initially planned date (5 December 2027).
During this period, companies will need to analyse the travel habits of their workforce, define concrete measures and implement them. Furthermore, the process will need to be carried out in coordination with the legal representation of the workers, or with a trade union committee if this is not the case, ensuring that the actions respond to the real needs of the team.
failure to implement the Sustainable Mobility to Work Plan within the deadline is considered minor infringement, punishable by fines of between 101 and 2,000 euros. The same penalty applies if the company fails to prepare the monitoring report within the timeframes established by law.
Beyond the size of the fine, the real risk is usually greater: the companies that have received public aid linked to Royal Decree-Law 7/2026 They will have to return that funding in full if they do not comply with their PMSER obligation. Added to this is the reputational impact and the possible exclusion from public tenders, which is especially relevant for organisations that work with the Administration or depend on aid and grants.
Therefore, more than a bureaucratic formality, the PMST should be understood as an obligation with direct economic consequences – and as one more reason to get ahead of the deadline of 5 December 2026 instead of waiting until the last minute.
The Sustainable Commuting Plan (SCP) must start from a detailed diagnosis from workplace mobility: modes of transport used, journey distances and times, origin zones, factors influencing access, and emissions generated. Based on this analysis, the company must Set emission reduction targets aligned with the hierarchy of mobility, which prioritises walking, cycling and public transport, leaving private vehicles as a last resort.
This is added to the measures to promote sustainable mobility, which can include incentives for cycling and public transport, secure parking, collective routes or shuttles, or the implementation of digital solutions to manage journeys.
The law also introduces a particularly relevant innovation: the explicit recognition of transport cards managed by authorised issuing companies, such as Edenred, as a valid and effective tool for achieving sustainability objectives. These cards help promote public transport, reduce emissions, and also provide tax advantages for both the company and the employee.
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Once approved, the Sustainable Mobility to Work Plan must Register with the EDIM, the official platform where labour mobility information is centralised at state level. This process has a specific timeframe from the approval of the plan, so it is advisable to incorporate it from the outset into the implementation schedule and not treat it as a subsequent or accessory step.
The regulation does not limit itself to requiring the initial plan: it obliges companies to draw up a Bi-annual follow-up report to assess the actual level of implementation of the measures and the results obtained. Failure to submit this report on time carries the same legal consideration – and the same penalty – as not having the plan.
The New Sustainable Mobility Law directly impacts a wide range of organisations and entities in Spain. Firstly, it targets companies —both public and private— that exceed certain staffing thresholds, that is, those with more than 200 employees or more than 100 workers per shift. It is important to note that this threshold applies per place of work, not to the total company staff. This means that a company with several smaller centres may not be obliged to comply, while another with a single large centre will be, regardless of the overall size of the organisation.
In addition, the public administrations are also subject to this regulation, not only as those obliged to comply with it, but as key players in promoting good practices. In this regard, local authorities with intermediate populations (between 20,000 and 50,000 inhabitants) will have to develop adapted or simplified versions of these plans, adjusted to their size and needs.
Lastly, the law places special focus on Environments where mobility is a critical factor, such as logistics sectors or activities with a high volume of travel. In these cases, route optimisation, energy efficiency, and emission reduction take on a particularly relevant role.
The plans will not be static documents. The regulations require them to be periodic review and update of measures according to the results obtained or changes in the workplace operations. Beyond legal compliance, the benefits are extensive: reduced costs and emissions, improved team well-being and punctuality, strengthened ESG commitment, greater capacity to attract talent, and a more responsible corporate image.
At Edenred, we understand the challenges this transition poses for organisations. That's why the transport card Edenred Mobility It presents itself as an innovative solution designed to facilitate regulatory compliance and move towards more sustainable corporate mobility.
Prioritising sustainable mobility not only improves environmental performance, but also reinforces ESG commitment, corporate image and competitiveness in an increasingly demanding regulatory environment.
Discover more advantages of the Edenred Mobility transport card!
The new Sustainable Mobility Act marks a before and after in the management of business travel. Companies obliged by this regulation will have to implement Sustainable Mobility Plans, prioritising public transport, sustainable mobility alternatives such as public transport. Far from being a simple obligation, the regulation opens up opportunities to optimise resources, reduce emissions and incentivise teams.
On this path, Edenred Mobility becomes the ideal strategic allya practical, simple, and flexible tool, recognised by the law itself and designed to help businesses comply with regulations while moving towards a greener and more responsible future.
Professional with extensive experience in Human Resources and client management, specialising in optimising the employee value proposition and developing strategic business relationships.
Throughout her career, she has built a profile that combines a solid foundation in talent management, compensation, and employee relations, with a clear customer and business orientation. Her experience allows her to deeply understand the needs of organisations and align them with solutions that directly impact employee well-being, retention, and engagement.
