Workplace mobility plans, what the rules actually require

Since Spanish sustainable mobility legislation introduced the obligation to produce a Workplace Sustainable Mobility Plan, the question we get most often is the same: "does it apply to us?" And the answer is almost always more nuanced than the company expects.

The obligation is measured per site

This is the point that causes most confusion. The threshold does not apply to the company's total headcount but to each worksite separately, also taking into account how many people are concentrated in a single shift.

There are three practical consequences:

• A mid-sized company with one large site can be covered, while a much bigger company with fifteen small sites may not be covered at any of them.
• A group with sites in several autonomous communities will need one file per site, submitted to the corresponding regional authority in each case.
• Adding a new shift or moving to larger premises can trigger the obligation without anyone noticing.

It is not a report: it is a negotiated file

The second common surprise is that the plan is not written and filed away. It is negotiated with the workers' representatives, and the agreed measures become enforceable.

That changes entirely how it should be prepared. Arriving at the table with a solid diagnosis, calculated costs and prioritised measures is not methodological luxury: it is what stops commitments being agreed that cannot later be sustained.

The fine is the least of it. The real problem is agreeing a measure the company cannot deliver, which from that moment on is enforceable.

The three pieces most often neglected

In the files we have reviewed, the weak points repeat:

The survey. This is the piece the inspectorate and the workers' representatives look at first. A survey without guaranteed sampling by shift and without documented anonymity verification invalidates, in practice, the whole diagnosis built on it.

Accessibility. The plan must address access conditions for workers with disabilities. It is often dispatched with a generic paragraph when it requires specific analysis of the complete journey, not just the car park.

Funding. Many measures can be paid for wholly or partly through energy-saving certificates, regional grants and the tax advantages of collective company transport. If that is not quantified, the negotiation turns into a pure cost argument and the ambitious measures fall first.

What to do if you have not started

Three steps you can take this week, without contracting anything:

1. List the worksites with their assigned headcount and their real distribution by shift.
2. Check, site by site, whether the thresholds are exceeded.
3. Identify who the counterpart will be on the workers' side at each one.

With that done, the rest of the process stops being an unknown and becomes a calendar.