August 10, 2025 is the deadline for certain workplaces located in Catalonia (Spain) to adopt a company mobility plan, which must be drawn up with the participation of the workforce and is subject to a report from the competent territorial authority in matters of mobility.
Decree 132/2024, of July 30, approving the Air Quality Plan, Horizon 2027, the Short-Term Action Plan for High Levels of Air Pollution and the regulatory determinations to achieve air quality objectives, obliges workplaces in Catalonia that have certain characteristics to have company mobility plans (CMPs) based on sustainability criteria and aimed at reducing pollution.
The CMPs are a set of transport measures that seek to rationalize journeys to and from the workplace and aim to “reduce the inefficient use of private vehicles by both employees and supplier companies, visitors and customers and plan the required mobility related to the activity of the workplace”.
The aforementioned characteristics are specified in article 12 of the decree that establishes the obligation to have CPMs for workplaces (i) with more than 500 employees, own or external, or with more than 250 employees per shift; and (ii) for workplaces with more than 200 employees, own or external, located in areas with exceedances. The latter are defined in article 9 as areas in which air quality has exceeded the limit or target values for any of the pollutants referred to in Royal Decree 102/2011, of January 28, during the previous 5 years, in the terms defined by the decree.
The plans will be understood to be in line with the criteria of sustainability and orientation towards reducing pollution if they provide for journeys to be made by sustainable transport and priority to collective transport.
The CMPs must be prepared with the participation of the workforce —but the decree does not detail how this participation must be carried out— and adopted within a period of no more than 12 months from the entry into force of the decree (i.e., before August 10, 2025). In addition, they are subject to a report by the competent territorial authority in matters of mobility, and, on a biennial basis, the workplaces with the indicated characteristics will have to submit a follow-up report of the CMP to said authority.
The decree also establishes that, in the processing of administrative permits for activities and their substantial modifications and revisions, the competent authority will check whether the workplace has a CMP and, if not, will inform the competent territorial authority in transport matters.
The countdown begins for the fulfillment of an obligation that requires the application of technical and legal knowledge and demands that different areas of the company act in a coordinated manner.
On this topic, it is important not to lose sight of the parliamentary processing of the Sustainable Mobility Law, which seeks to introduce an obligation similar to the one explained in this post, to establish sustainable mobility plans for workplaces throughout Spain with more than 500 employees or 250 per shift that must be negotiated with the legal representation of the employees (or with the unions in the absence of legal representation).
