The Sustainable Commuting Plan (PMST): what it is and who answers for it

Law 9/2025 on Sustainable Mobility created a new obligation for employers in Spain: the Plan de Movilidad Sostenible al Trabajo (PMST). If any of your workplaces is above the headcount threshold, you need a plan negotiated with employee representatives — and proof of it.

What is a PMST?

A document that diagnoses how people get to and from a workplace, sets objectives to shift those journeys towards more sustainable and safer modes, and commits to measures with a budget, an owner and indicators. Three things separate it from a voluntary initiative:

It must be negotiated with the legal employee representation (art. 26.2). A plan written by the sustainability team alone does not comply.
It must be communicated to your regional government within three months of approval (art. 27.3).
It must be reviewed with a follow-up report two years after approval, and every two years after that (art. 26.2).

Approval remains a management decision — negotiation is not a veto — but the documented trail proving it happened is mandatory.

The deadline is 5 December 2026

Milestone	Date	Basis
Law enters into force	5 Dec 2025	Law 9/2025, of 3 December
Original deadline (24 months)	5 Dec 2027	Original art. 26.1
Deadline in force (12 months)	5 Dec 2026	Art. 63, RDL 7/2026
Communication to the region	+3 months from approval	Art. 27.3
First follow-up report	+2 years, then every 2	Art. 26.2

Careful with the date going around

The Ministry and most media coverage say "before 31 December 2026". Art. 63 of Royal Decree-Law 7/2026 sets the period at twelve months from entry into force, which lands on 5 December 2026. Work to 5 December: the difference is 26 days and no upside.

Four bodies, and only one receives the document

There is no single national portal where you upload the plan.

Role	Who	What they do
Receives the document	Your regional government	The plan, its revisions and follow-up reports go to the authority the region designates, within 3 months of approval (art. 27.3)
National registry	EDIM — Ministry of Transport	Registers PMSTs and their most relevant indicators (art. 26.8). You do not upload directly; it arrives via the region
Sanctions	State Secretariat for Transport	Enforcement is state-level, not the Labour Inspectorate (art. 110.1)
Negotiates	Legal employee representation	Art. 26.2. Where a site has no works council, a negotiating committee is formed with the most representative and sector trade unions

You must also take the municipal mobility plan into account, where one exists (art. 26.3). Most regions have not published their designated authority yet. File with the regional department responsible for transport and mobility and keep the receipt: it is your only proof of compliance with art. 27.3.

The real financial risk is not the fine

Missing the deadline or the follow-up report is a minor infraction: €101–€2,000. Significant harm to the mobility system is serious: €2,001–€6,000. Two final minor infractions within a year turn the next one into a serious one.

Where the money actually is

Art. 64 of Royal Decree-Law 7/2026 ties the obligation to public funding: an obligated company that received the direct aid granted under that decree-law and has no plan must repay the aid received. If you have taken any of that funding, that is the exposure to manage — not the €2,000 fine.

The plan will be public

Art. 27.2 makes the communicated documents publicly accessible, including data aggregated by gender and age. Write it assuming a trade union, a customer and a competitor will read it — and collect postcode or municipality of origin in the survey, never home addresses. See The mobility survey and the indicator dashboard.