What the plan must contain: mandatory, optional, and recommended

Art. 26.3 of Law 9/2025 sets out the content of a commuting plan in one paragraph, using phrases like “for example”. That wording matters: the law fixes the subjects you must address, not a closed list of measures.

What is mandatory is the process (negotiate, follow up, communicate) and the thematic coverage. Which measures you choose is yours, provided you can justify them against your diagnosis.

Mandatory, optional, recommended

Art. 26.3 makes these nine subjects mandatory. You must address each one; you choose how.

• Active mobility (walking, cycling)
• Collective transport
• Low-emission mobility
• Shared and collaborative mobility
• Use and charging of zero-emission vehicles, as amended by RDL 7/2026
• Remote work where feasible
• Road safety, accident prevention and training in both
• Visitors, suppliers and anyone accessing the site
• Coherence with the municipal mobility plan, where one exists

Mandatory beyond art. 26.3: the priority order of art. 28; negotiation with employee representation (art. 26.2); the follow-up report at two years and every two years (art. 26.2); communication to the regional authority within three months (art. 27.3); and peak-hour measures at sites over 1,000 people in municipalities over 500,000 inhabitants (art. 26.5).

Optional: offsetting the residual carbon footprint (art. 26.3), and appointing a mobility manager — which art. 26.4 allows to become mandatory by regulation later.

Recommended, not required: the diagnosis, survey, measure cards, indicators and governance that the OTLE monograph builds its method around.

The priority order of art. 28

Art. 26.3 refers to art. 28, which sets a hierarchy. Order your measures by it, and where you skip a level, say why:

1. Active mobility — walking and cycling
2. Public and collective transport
3. High-occupancy mobility — carpooling, company shuttles
4. Cleaner vehicles — electric and low-emission

For a rural industrial estate the honest answer is often “there is no usable public transport”. Saying so, with evidence, is a valid diagnostic result. Skipping the level without addressing it is not.

There is no official template

Neither the law nor the Ministry has approved a model, a form or a file format. Companies are free to define their own measures, negotiated with the unions. One thing is worth anticipating: EDIM will register “the most relevant parameters and indicators” (art. 26.8), and sites over 200 people are among those obligated to supply data to it (art. 104.a). So the plan needs numbered indicators and a dashboard, not just prose.

Reference documents worth your time

There are no published Spanish company plans to model yourself on — the publicity obligation only dates from 2025, and the first ones will surface as regions feed EDIM. Two official documents are the de facto standard.

The OTLE monograph on Sustainable Commuting Plans (Ministry of Transport) is the closest thing to an official guide: three phases (Vision → Measures → Management), a measure card model, governance built around a Mobility Committee, and a measure catalogue organised by six strategic axes. Available from the OTLE monographic reports page.

Plan tipo de movilidad segura y sostenible en la empresa (DGT, INSST and the Labour Inspectorate) is pragmatic and field-tested, with ready-to-use mobility and accident survey models. It covers the road safety block that art. 26.3 requires and that most plans handle poorly.