June 2026
By 5 December 2026, many Spanish companies will be required to have sustainable workplace mobility plans in place. This date should not be viewed merely as another compliance milestone, but as an opportunity to rethink a fundamental aspect of business organisation: how employees commute to work and the impact those journeys have on companies, their workforce and the wider environment.
Law 9/2025 of 3 December on Sustainable Mobility places this issue firmly on the corporate agenda. Article 26 requires companies and public sector entities with workplaces employing more than 200 employees — or 100 employees per shift — to implement sustainable workplace mobility plans. These plans must be negotiated with employee representatives, subject to periodic monitoring and communicated to the relevant authorities.
The significance of this development extends beyond regulatory compliance; it also carries important strategic implications. European labour law scholars have increasingly argued that businesses cannot be viewed in isolation from broader societal challenges. Wolfgang Däubler, the German labour law professor and legal scholar, has highlighted the connection between climate protection and working conditions, placing sustainability firmly within the sphere of industrial relations. Sustainability is reflected not only in environmental commitments, but also in work organisation, employee participation and everyday business decisions. In the era of ESG (Environmental, Social and Governance), workplace mobility provides a tangible way to align environmental responsibility, social impact and good governance.
For many years, commuting was considered largely a personal matter. However, there is growing recognition that it forms part of the wider corporate ecosystem. Commuting patterns can affect punctuality, work-life balance, road safety, indirect business costs, employee wellbeing, and the environmental footprint associated with business activities. Integrating mobility considerations into business management does not mean placing responsibility for all transport-related challenges on employers; rather, it acknowledges that organisations can play a meaningful role in improving mobility outcomes.
An effective sustainable mobility plan does not need to be overly complex, but it must be practical and fit for purpose. It should begin with a proportionate assessment of key factors: where employees live, shift patterns, available transport options, existing barriers to mobility, and the measures that may be realistic for each workplace. The solutions suitable for a well-connected urban office are unlikely to be the same as those required for an industrial facility located on a business park with limited public transport links. The true value of a mobility plan lies in its ability to reflect the specific realities of each organisation.
The global ESG debate provides useful context for understanding this shift. Corporate sustainability is no longer measured solely through ambitious environmental commitments; it is increasingly assessed through operational decisions that shape everyday business activities. Workplace mobility is one such area. When approached effectively, it can help reduce emissions, improve the management of commuting patterns, enhance the employee experience and strengthen alignment between corporate sustainability commitments and internal practices.
For this reason, the new legal requirement should not be perceived solely as an administrative burden. It can instead be seen as an opportunity to prepare in advance, organise previously fragmented information, identify inefficiencies and implement measures capable of delivering tangible results. In some cases, relatively simple adjustments may be sufficient. In others, businesses may need to collaborate with public authorities, transport operators or neighbouring organisations. In every case, however, the process has the potential to create value when approached with sufficient planning and a practical mindset.
Sustainable mobility is entering the workplace not to impose an external agenda, but to broaden the way we understand the organisation of work. The way people travel to and from work forms part of the overall employee experience and is increasingly becoming an aspect of modern corporate responsibility. Viewing this obligation as an opportunity rather than a constraint can help organisations become more efficient, more closely aligned with their ESG commitments, and better connected to the needs of both their workforce and the communities in which they operate.
José Miguel Mestre
Partner
