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A structure for the plan: ten sections and a measure card
A working index for a Sustainable Commuting Plan, aligned with the OTLE monograph — what goes in each section, and the fields every measure card should carry.
There is no official template, so this is a structure, not a form. It follows the three phases of the OTLE monograph (Vision → Measures → Management) and covers every mandatory subject in art. 26.3 of Law 9/2025. For a group with several obligated sites, one corporate document with a chapter per site is normally the right shape — 35–50 pages plus annexes.
You no longer have to build it yourself
Since 16 September 2026 this structure ships inside Dcycle. When you create a report in a mobility project you can pick the plan template and get the whole document, with a colour-coded guide inside every section: black for the text you can keep, orange for the gaps that change from company to company, and small blue type explaining what that section is for. You delete the blue as you go.
It behaves like any other report, with the same editor, version history and export, and it takes eleven visualizations built on your own commuting and accident data. The rest of this article still applies: it is the reasoning behind each section, and it helps you decide what to cut.
The ten sections
| # | Section | What goes in it |
|---|---|---|
| 01 | Scope and legal basis | Census of workplaces with average and peak headcount, the art. 72 Workers’ Statute calculation, shift structure, and which sites are obligated and why. State the boundary: which journeys are in scope (in itinere commuting, business travel) and which are not (inbound logistics, product distribution, on-site machinery). This is what justifies why there are N plans and not N+2 |
| 02 | Governance and negotiation | Plan owner, a mobility manager per site, a Mobility Committee, and the internal team: HR, health and safety, facilities, finance. Employee representation per site and, where none exists, the union negotiating committee. Calendar and minutes — without minutes there is no evidenced negotiation (art. 26.2) |
| 03 | Diagnosis of current mobility | Modal split per site and season, origin–destination by postcode, distances and times, average vehicle occupancy, arrival and departure times per shift, parking occupancy, own fleet. A dedicated subsection for any seasonal workforce |
| 04 | Accessibility of the surroundings | The actual public transport offer to each site, pedestrian and cycling routes, access safety, lighting and night-time risk stretches, and the municipal mobility plan where one exists (art. 26.3) |
| 05 | Road safety and accident record | In itinere and business-travel accidents over three years, by site, shift and season. Site risks: driving after a night shift, fatigue, conventional roads, wildlife. Link to the risk assessment and training plan. Required explicitly by art. 26.3 — use the DGT models |
| 06 | Carbon footprint of commuting | Scope 3 Category 7 from the survey, separating ordinary season from peak, with methodology and emission factors declared. Not required by art. 26, but it is the bridge to the GHG inventory you already maintain |
| 07 | Objectives and strategic axes | Quantified objectives at 2, 4 and 6 years against the baseline, organised by the six OTLE axes (collective transport, active mobility, shared and high-occupancy mobility, cleaner vehicles, fewer journeys, safer journeys) and respecting the art. 28 priority order |
| 08 | Measure cards | One per measure, same fields throughout. Format below |
| 09 | Scheduling, resources and budget | Timeline per measure and site, investment and operating cost, a named owner, and where there is a seasonal peak, the campaign protocol: what activates when seasonal staff arrive (welcome pack, carpooling enrolment, safety briefing) |
| 10 | Monitoring, communication and review | Indicator dashboard with baseline, target, owner and source. The biennial report commitment. Internal communication plan. Record of the communication to the region and its receipt. Criteria for early review. Arts. 26.2 and 27.3 — the most forgotten section |
Sections 01 and 10 decide whether you comply, and both are frequently thin.
The measure card
Fields recommended by the OTLE monograph. Use the same ten throughout so measures can be compared and prioritised.
| Field | What to put in it |
|---|---|
| Code and title | Short, action-oriented, coded to its axis (e.g. TC-03, SEG-01) |
| Type | Which axis or axes it responds to |
| Description and objective | What you do, and which diagnosis problem it solves |
| Scope and groups | Which sites; permanent and seasonal staff, visitors, suppliers |
| Actors and governance | Internal owner and external actors, with a contact person |
| Timeline and phases | Start date, milestones, and if seasonal, when it activates |
| Resources | Investment, operating and maintenance cost, internal staff time |
| Ease of implementation | Scale 0–5, same criteria across all measures |
| Estimated impact | Quantified where possible: modal shift points, tCO₂e avoided, euros saved |
| Monitoring indicators | With baseline, target and data source |
Use the card as a filter
If you cannot fill in the resources, impact and indicator fields, the measure is not ready to commit in a negotiated plan. Move it to an "under study" annex — that distinction also protects you in the negotiation.
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Up next
What the plan must contain: mandatory, optional, and recommendedLaw 9/2025 describes the content of a commuting plan in a single paragraph full of "for example". Here is what is genuinely mandatory, what is discretionary, and what is good practice.
Read more → The mobility survey and the indicator dashboardThe minimum a commuting survey has to ask, why seasonal sites need two waves, the participation rate that makes a diagnosis defensible, and the indicators to track.
Read more → Choosing measures that actually work at your kind of siteThe official measure catalogue is written mostly for urban offices. How to filter it for an industrial estate, a rural site or one with a seasonal peak.
Read more →