What data your Sustainable Mobility Plan needs to comply with RD-Law 7/2026

The problem is no longer understanding the rule, but knowing what data a Sustainable Mobility Plan needs to comply with it. With the timeline brought forward by Royal Decree-Law 7/2026, many organisations have discovered that the real challenge is not designing the plan, but building a solid base of information. Because without data, there is no diagnosis. And without a diagnosis, no plan will withstand an audit.

In practice, most organisations do not start from scratch, but neither do they start from a solid base. Information is scattered across HR, operations and suppliers. There are old surveys, internal policies that are rarely updated and, above all, a lack of traceability that complicates any attempt to quantify impact.

This article lands on that critical point: what data a Sustainable Mobility Plan really requires, where companies tend to fall short, and how to structure the information to comply with Spain's Sustainable Mobility Law 9/2025 without turning the process into an endless project.

What deadline does RD-Law 7/2026 set and which companies must comply?

Law 9/2025 of 3 December on Sustainable Mobility introduced the obligation to draw up a Workplace Sustainable Mobility Plan (PMST). Royal Decree-Law 7/2026 of 20 March (the omnibus rule approving the Comprehensive Response Plan to the Middle East Crisis) amended its article 26 to cut the term from 24 to 12 months. In practice, the deadline was brought forward from 5 December 2027 to 5 December 2026.

The obligation does not affect all organisations equally. It is concentrated on companies and public-sector entities with workplaces of more than 200 employees, or more than 100 per shift, where that site is the employee's usual place of work. The plan must also be negotiated with the workers' representatives.

You can find more on the context and timelines in our article on the new deadline for the Sustainable Mobility Plan.

What data does a Sustainable Mobility Plan require?

The regulation does not ask for a theoretical document, but for a plan grounded in real commuting patterns. That means working with concrete, up-to-date and representative data. Many companies try to build it from estimates or sector averages: understandable, but insufficient, because the regulation points towards measurable and justifiable actions.

In practice, the data for a Sustainable Mobility Plan is organised into four main blocks that make it possible to understand, measure and improve commuting.

1. How people actually travel

This is the core of the diagnosis. It is not enough to know where the office is; you need to understand how people get to it. Key data:

• Employees' place of residence (at least by postal code)
• Usual mode of transport
• Distance travelled and commuting frequency
• Start and end times

The problem here is usually not technical but methodological: many companies rely on internal surveys with low participation or imprecise questions. Without this layer, any later measure becomes a hypothesis.

2. What impact those journeys have

Once the mobility pattern is understood, the next step is to translate it into impact. Data needed:

• Emissions associated with each mode of transport, applying the correct emission factors
• Energy consumption linked to commuting
• Direct and indirect costs for the company

This is where technical complexity comes in: it is not just about gathering data, but about applying consistent methodologies. It is the point where many organisations lose precision or comparability.

3. What alternatives exist and are viable

The plan does not stop at describing the current situation: it has to propose realistic measures. For that you need data such as:

• The availability of sustainable and public transport in the areas where employees live
• Available infrastructure (parking, bike lanes, charging points)
• Existing internal policies (remote work, flexible hours, incentives)

This block is usually fragmented across different areas or simply undocumented.

4. How improvement will be measured

The regulation insists on monitoring. It is not enough to define actions; you have to demonstrate their impact over time:

• Clear indicators (emissions reduction, modal shift, use of collective transport)
• Systems for periodic data collection
• Reporting capability aligned with ESG objectives

Here another common problem appears: many companies design the plan but not the measurement system. And without that system, compliance is left hanging.

The problem is not a lack of data, but its structure

One of the most widespread mistakes is to assume there is no data. In reality, in most organisations it does exist, but it is scattered, incomplete or in formats that make it unusable. HR has addresses, finance has transport expenses and operations knows the logistics, but nothing is connected.

The challenge, then, is not only to gather information but to shape it: turning loose data into a system that allows you to analyse, decide and report. And with the deadline of 5 December 2026, time is exactly what is in short supply.

How to structure the data of a Sustainable Mobility Plan

The important leap is not about measuring more, but measuring better: building a data model that can answer three basic questions:

• Where are we
• What can we change
• What impact that change has

As regulatory demands grow, so does the need for tools that structure the process. Centralising data, automating emissions calculations and keeping continuous tracking is no longer an operational improvement: it is a condition for compliance.

If you want to centralise your organisation's scattered information and quantify commuting emissions before 5 December 2026, you can rely on Manglai's service footprint. Because in this scenario the risk is not failing to understand the rule, but failing to arrive in time with the data that lets you comply with it.