A roadmap from today to 5 December 2026

A negotiated plan is not a two-week document, and the step that runs out of runway first is not the writing — it is constituting the negotiating body. If a seasonal peak falls inside your window, that is an advantage: it is the only chance in the year to measure the real peak.

The sequence

Stage	Work	Output
Week 1	Site census and scope decision: average and peak headcount per site with the art. 72 Workers’ Statute calculation, plus shift structure	How many plans, which sites, what perimeter — and where you need to check whether employee representation exists
Weeks 1–2	Constituting the negotiating body: convene existing representation; where there is none, notify the most representative and sector unions	A convened body with a meeting calendar
Weeks 2–6	Survey and fieldwork, ideally during the peak: permanent and seasonal staff, access flows on peak days, vehicle occupancy, access routes on a night shift	The diagnosis dataset
Weeks 6–9	Diagnosis, footprint and objectives: modal split by season, Scope 3 Category 7, three years of in itinere accidents, first conclusions to the table	A diagnosis the table can argue with
Weeks 9–12	Measure cards and negotiation: draft the cards, cost them, run two or three sessions	The committed measure list and the “under study” annex
Before 5 Dec 2026	Management approval. Approval is management’s responsibility; the negotiation is not a veto, but the documented trail is mandatory	An approved plan, with minutes
Within 3 months	Communication to the regional authority in every region with an obligated site	The filing receipt — your only proof of compliance with art. 27.3

If your busy season falls inside these twelve weeks

If the site’s busiest period — a harvest, a high season, a Christmas peak — happens while you are preparing the plan, use it: it is the only point in the year when you can measure how people travel with the site full. Four things worth doing then:

• Run the survey during the campaign, and do it as each person is taken on rather than by email. Response rates among temporary staff go up sharply.
• Count vehicles and occupants at the entrance on the busiest days: how many vehicles come in, and how many people are in each. That figure is what any carpooling measure rests on later.
• Walk the access routes at shift change, at night too if there is a night shift, noting the points where cars and people on foot share the same space: the gate, the loading area, the weighbridge if there is one.
• Check the lighting and signage at those same points.

None of this can be reconstructed from records later. Miss the campaign and the plan gets built on estimates, with the next chance to measure a year away.

What to get out of the kick-off meeting

Beyond the census data in week 1, three things to settle in the room:

Process: which sites have a works council or elected delegates? Is there a company-level agreement, and when does its negotiating committee renew? Who is the single point of contact, and the mobility manager per site?

Points to make explicit: the deadline is 5 December 2026, not “end of year”; a seasonal peak triggers the obligation even if it lasts six weeks; and if the company has received direct aid under RDL 7/2026, non-compliance is paid in clawback of that aid, not in a €2,000 fine.

Decisions to close: one group document with per-site chapters, or independent plans; and whether the survey launches this campaign or you accept working from estimates.