Law 9/2025 requires mobility plans to be negotiated with workers’ representatives. With the deadline ending in December 2026, many companies are already receiving applications to start negotiations. In this post we offer keys to the new legal obligations.
Law 9/2025, of 3 December, on Sustainable Mobility, has placed mobility at the center of labor relations during this year 2026. Although the legal deadline for compliance with the obligations regulated in it may still seem distant, the calendar is very demanding since it was shortened by Royal Decree-Law 7/2026, of 20 March. For this reason, in many workplaces, this matter has already been incorporated into the collective bargaining agenda.
Sustainable mobility has gone from being a voluntary initiative to becoming a legal obligation with a direct impact on business organization and collective bargaining in a short time. Many obligated companies already have measures in place to facilitate the travel of their staff (shuttles, electric charging points or car-sharing incentives), but do they comply with the new legal requirements? We offer below certain keys to the legal obligations.
- It is not enough to have measures: a negotiated plan is necessary
The rule is not satisfied with isolated actions. It requires mobility measures to be integrated into a sustainable mobility to work plan, a structured document to be drawn up in the framework of collective bargaining. The company cannot approve it unilaterally: it must negotiate it with the legal representation of the employees.
This approach reinforces the transversal nature of sustainable mobility and fully incorporates it into the field of labor relations, as one more subject that requires planning, dialogue and a clear strategy on the part of the company.
- Which companies are affected and what time frame do they have?
The obligation applies to workplaces with more than 200 employees, or with more than 100 employees per shift (a point that could be interpreted as meaning that it is sufficient for there to be a work shift with more than 100 employees for the obligation to be activated, even if the company does not reach 200 employees). In these cases, the plan must be approved within 12 months of the entry into force of the law, which places the deadline on December 5, 2026.
While the timeline may seem reasonable on paper, it is worth bearing in mind that negotiating a plan of this nature is not a quick process. It requires prior analysis (diagnosis), collection of information, definition of concrete measures and a structured dialogue with the workers’ representatives. Approaching the process well in advance will avoid hasty negotiations and will facilitate a result that is more aligned with the reality of each workplace.
- A document with measures adapted to each company
The plan must be adapted to the specific characteristics of the workplace and contemplate appropriate mobility solutions for those who access it, prioritizing those with the greatest impact on sustainability.
Among other measures, it must address active mobility, collective transport, low-emission alternatives, shared mobility, electric vehicle charging, remote work when possible, road safety and carbon footprint offsetting when it is not feasible to act on all emissions. The law also includes tools that can facilitate the implementation of the plan, such as the possibility of offering transport cards under a favorable tax regime.
- Collective bargaining
The regulation attributes an important role to collective bargaining. On the one hand, it establishes that the sustainable mobility plan must be negotiated with the legal representation of the employees. On the other hand, it includes in the content of the negotiation of collective agreements the duty to negotiate measures to promote the development of sustainable mobility to work plans, with the scope and content provided for in Law 9/2025, to achieve the objectives of air quality and emission reduction, as well as to avoid congestion and prevent accidents on the way to work.
- Follow-up
The obligations do not end with the approval of the plan. The company must carry out periodic monitoring reports and communicate the plan to the competent authority, which makes it advisable to design it from the beginning with a vision of continuity.
In short, the implementation of the sustainable mobility plan to work requires time, internal coordination and a clear negotiation strategy. With a time horizon limited to December 2026, anticipating is not only good practice, but a key condition to arrive on time and avoid possible sanctions.
