Commuting to work is no longer just an operational issue, but a management issue that affects employee experience, internal organisation and, increasingly, compliance. Under Law 9/2025 of 3 December on Sustainable Mobility, companies with certain workplaces must have a Sustainable Mobility to Work Plan (PMST), negotiate it with employee representatives, implement measures and be able to demonstrate its progress through regular monitoring.
Therefore, knowing how to implement the Sustainable Mobility Act in your company will be key in the near future. And no, not everything will work: it is not enough to draw up a nice plan that is then not used. A useful SMWP is built on the reality of the workplace (location, shifts, access, habits), implements measures that can be activated without friction, and is supported by data so that monitoring is not a last-minute rush. At this point, having a tool that organises the roll-out and facilitates monitoring makes the difference between ‘an initiative’ and a stable programme.
In this implementation, there is one measure that usually yields results before any other: carpooling to work. The law itself includes ‘shared and collaborative’ mobility solutions as examples of measures within the plans, and the public conversation around the regulation is pushing carpooling as a quick lever to reduce single-occupant car use.
This is where Hybo.app fits in naturally. If carpooling is going to be part of your PMST, you need it to be easy for the user, organised for the company and measurable for reporting. A carpooling module within a corporate platform allows you to turn ‘an idea’ into a sustainable programme that can be scaled across locations or shifts and provides traceability for monitoring the plan.
What is the Sustainable Mobility Act and when will it come into force?
Law 9/2025 establishes a comprehensive framework to promote more efficient, accessible and decarbonised mobility, and introduces planning and monitoring tools that also apply to employment-related mobility. For companies, what matters is not only that the law exists, but also what specific obligations it imposes on travel to the workplace and how these measures are expected to be implemented and measured.
The law is dated 3 December 2025 and was published in the Official State Gazette (BOE) on 4 December 2025; it comes into force the day after its publication, i.e. on 5 December 2025.
Law 9/2025: what it regulates and why it affects commuting
In the workplace, the law pushes for the professionalisation of something that many companies already managed on a piecemeal basis: daily commutes to the office. When a workforce depends on cars, recurring problems arise (rush hour traffic jams, parking shortages, stress, tardiness, rising costs). The PMST turns this chaos into a system: diagnosis, measures, adoption and continuous improvement. And the easier it is to turn this system into routine, the easier it will be to sustain it over time.
Entry into force and adaptation period for companies
The key date in the business calendar is not only the entry into force, but also the legal deadline for having a plan in place. The regulation establishes a period of 24 months from the date of entry into force for companies to have an OHS plan in place at centres that meet the thresholds. This puts the horizon for ‘serious’ implementation at the end of 2027, but the sooner the diagnosis and a pilot programme of measures are activated, the easier it will be to achieve real results in the follow-up. If you support the deployment of a tool from the outset (e.g. to centralise communications, boost participation or consolidate data), you reduce friction and gain speed.
What the Sustainable Mobility Law requires of companies
The law does not simply state that ‘you must have a document’. It sets out very specific obligations: who must have a PMST, how it is negotiated, what it must include and how it must be monitored. This changes the internal conversation because isolated actions or one-off campaigns are no longer enough: a plan is needed that can be sustained and demonstrated, and that does not depend on manual efforts every time a report is due.
PMST: who it applies to and what obligations it introduces
According to Article 26, within 24 months of the law coming into force, companies must have sustainable mobility plans in place for workplaces with more than 200 employees or 100 per shift (as defined by the law).
In addition, the same article requires that the plans be negotiated with the legal representatives of the workers; and if there is no representation, it provides for a negotiating committee with union participation according to representativeness. This conditions the project: you need to arrive with a diagnosis, defensible measures and an approach that improves day-to-day life, not just formal compliance.
The article also states that the plans must include sustainable mobility solutions, citing examples such as active mobility, public transport, low-emission mobility and, very relevant here, both shared and collaborative mobility solutions, as well as facilitating the use and recharging of zero-emission vehicles and teleworking where possible. On this point, carpooling is often a ‘highly implementable’ measure because it allows changes to be made without construction and with rapid impact, especially if managed with a solution such as Hybo that facilitates adoption and order.
Monitoring, reporting and non-compliance risks
The PMST does not end once it has been approved. The law requires monitoring and establishes a cycle that many companies overlook: within two years of the plan’s approval, a monitoring report must be prepared, and this report must be repeated every two years during the plan’s validity period. In practice, this means that you must define from the outset what you are going to measure and how you are going to obtain data consistently.
In terms of risks, the law itself classifies as an offence (among others) failure to comply with the obligation to have the PMST in place on time or to prepare the monitoring report, when this causes damage to the mobility system. And in the chapter on penalties, it sets the amount: minor offences are punishable by fines of £101 to £2,000 and serious offences by fines of £2,001 to £6,000. In this context, relying on a platform that simplifies monitoring (for example, by centralising activity and metrics) can prevent reporting from becoming a ‘separate project’ every two years.
How should I implement the new Sustainable Mobility Law in my company?
Implementing the law realistically means turning it into an easy-to-execute process: diagnosis, objectives, measures, adoption and data. If there is no adoption, there is no impact. And if there is no data, there is no defensible monitoring. The good news is that you don’t need to start with the most complex aspects: you can activate quick levers (such as carpooling) while you develop medium-term measures. If you also have a solution such as Hybo, you can structure the roll-out and make it more scalable by location, shift or group.
Diagnosis and objectives: how to start on a solid footing
It all starts with knowing where you are. The diagnosis does not have to be endless, but it does have to be useful: percentage of people who come alone by car, most frequent areas of origin, actual peak hours, differences between shifts, public transport limitations and barriers perceived by staff. With this picture, it is much easier to decide which measures make sense and, above all, to define measurable objectives.
Here, it is advisable to set objectives that connect with the centre’s real problems. For example, reducing parking pressure at certain times, increasing average occupancy per vehicle, reducing congestion at entrances, or improving punctuality. These objectives are what will then allow you to build a coherent follow-up two years after the plan’s approval.
Action plan and deployment: measures, negotiation and timetable
With defined objectives, the plan must be translated into an implementation timetable. An effective PMST combines ‘quick’ measures with structural measures. Quick measures are those that can be activated without depending on third parties and that change habits in a matter of weeks; structural measures usually require more coordination (infrastructure, agreements, operational redesigns).
At the same time, there is a key task: internal communication and negotiation. As the PMST is negotiated, it is not enough to simply announce it. You have to explain why it is being implemented, what problem it solves, how to participate, what rules apply and what support will be available. Here, a practical advantage of relying on Hybo is that it provides a clear ‘channel’ and experience for employees, preventing the plan from becoming diluted in scattered messages and processes.
How to create a carpooling strategy for commuting to work with Hybo
Corporate carpooling works when it is designed as a programme: it has rules, support and continuity. People do not need “motivation”; they need predictability. If the programme reduces uncertainty (changes, coordination, cancellations), adoption grows because it fits into the routine.
Furthermore, carpooling fits perfectly into the legal framework because Article 26 includes shared and collaborative mobility solutions as examples of measures within the PMST. And media coverage of the law has reinforced precisely this idea of ‘car sharing’ as a necessary or highly desirable lever within the plans of large companies.
Programme design: adoption, trust and clear rules
In order to be used, the programme must address typical obstacles: ‘What if I leave early one day?’, ‘What happens if it is cancelled?’, ‘Who will I be paired with?’, ‘How is it coordinated?’. Therefore, what determines success most is not the ‘launch’ itself, but rather clear rules and support. A well-chosen pilot (location, shift, or group with similar patterns) allows the design to be adjusted before scaling up.
When carpooling is integrated into the culture of the centre as a practical solution, it ceases to be a sustainable gesture and becomes an operational improvement. It is this change in perception that makes it sustainable, and tools such as Hybo help to maintain that operational order so that the habit is repeated.
How to deploy it with Hybo and turn it into a PMST metric
Hybo provides structure: carpooling is no longer informal coordination but becomes a measurable corporate programme. This is key for two reasons. The first is adoption: the experience is more orderly, less chaotic, and that makes it easier for people to repeat. The second is compliance: if the PMST requires monitoring and biannual reporting, you need consistent data, not manual reconstructions.
The approach that usually works is to start with a pilot, iterate rules and communication during the first few weeks, and scale up with a clear reading of results. This way, carpooling is not just ‘another action’, but a central measure of the plan, with a tool (Hybo) that helps to sustain and demonstrate it.
Carpooling to work: the quickest measure to implement
In corporate mobility, a quick measure is one that can have an impact without construction work, tenders or waiting for third parties. Carpooling achieves this because it optimises existing routes: people who travel to the same centre, at similar times, from recurring areas.
This type of measure is usually particularly effective in centres with limited parking, offices in industrial estates or areas where public transport does not adequately cover the actual working hours of the workforce. In these environments, the benefits are quickly apparent: easier parking, shorter queues at entrances, more reliable arrival times and less stress during rush hour. And, if managed with a tool such as Hybo, it is easier to prevent daily coordination from becoming a source of friction.
When does it work best and what results does it usually bring at the beginning?
It works best when there are repeated patterns: stable shifts, fixed start/finish times or geographical concentration of residence. In these cases, carpooling is not about ‘changing modes of transport’, but rather switching from driving alone to driving with more efficient occupancy. That’s why it’s quickly noticeable in everyday life, even before it translates into environmental metrics.
Typical barriers and how to overcome them so that it doesn’t ‘deflate’
Carpooling deflates when it is launched without structure. Informal coordination creates friction with the unexpected, and friction kills repetition. The solution is simple: clear rules, support, communication without saturation, and minimal measurement to detect which location/shift needs adjustment. With structure, the programme is sustainable and scalable; with Hybo, that structure is also maintained more consistently and does not depend so much on manual management.
KPIs and reporting: what to measure and how to generate reports with Hybo
If the PMST requires monitoring and periodic reports, measurement is not optional. Measurement is what allows you to demonstrate implementation, justify internal decisions, and improve the programme over time.
In carpooling, there are three layers that should always be visible: adoption, usage, and impact. Adoption is how many people join and, above all, how many repeat. Usage is actual activity over time. Impact is how that translates into understandable results: estimated number of cars avoided, average occupancy, or relief of pressure on parking and access (according to your internal methodology).
Essential KPIs for carpooling and commuting
A programme can have many indicators, but if you want a simple and defensible system, prioritise metrics that connect with the plan’s objective. If the problem is parking, measure what helps you free up parking spaces. If the problem is congestion at access points, measure what reduces peak hour traffic. And if the objective is sustainability, define a consistent methodology for estimating impact so that you can compare trends over time and report them in a stable manner.
How to convert data into useful reports with Hybo
When carpooling is managed within Hybo, reporting is much more sustainable because it does not depend on capturing data manually. This facilitates analysis by location or shift, allows trends to be seen, and makes it easier to explain ‘what was implemented and how it evolved’ when it is time for the follow-up report two years after the plan’s approval (and every two years thereafter). It also helps carpooling to be understood internally as a corporate programme, rather than a series of informal agreements.
Frequently asked questions about sustainable mobility and carpooling in companies
Does the PMST obligation apply per company or per workplace?
It applies per workplace and depends on the staff/shift thresholds set out in Article 26. This means that a company with several locations may have some centres that are obliged to comply and others that are not, and that implementation must be adapted to different realities depending on location or shifts.
What is the deadline for having a Sustainable Mobility Plan for Work in place?
The law sets a deadline of twenty-four months from the date of entry into force for the SMWP to be in place in the workplaces that are required to have one.
Does the SMWP have to be negotiated with the legal representatives of the workers?
Yes. Article 26 establishes that the plans shall be subject to negotiation with the legal representatives; and if there are none, it provides for a negotiating committee with union participation according to representativeness.
Is car sharing mandatory or an option within the SMWP?
The law requires an SMWP and states that it must include sustainable mobility solutions, including shared and collaborative mobility solutions, which is where carpooling fits in. Furthermore, in the media, it has been interpreted as one of the most likely measures for large workplaces due to its speed of implementation.
What minimum KPIs should be measured from the first month?
To avoid getting lost, start with indicators that allow you to demonstrate implementation and progress: adoption (recurring use), usage (sustained activity) and impact (average occupancy or estimated number of cars avoided, according to methodology). With this, you can iterate the programme and prepare for biannual monitoring on a solid basis.
What does Hybo offer compared to organising carpooling informally?
It provides structure, continuity and traceability. If carpooling is going to be part of the PMST, the difference between “existing” and “implementing” is that it is sustainable, easy for the user and generates consistent data for monitoring and reporting.
