Sustainable mobility plans in Catalonia

The Air Quality Plan, Horizon 2027 was approved by Decree 132/2024, of July 30 and published in the Official Journal of the Catalan Government on August 9, 2024. It establishes a short-term action plan for high levels of air pollution and the regulatory determinations to achieve air quality objectives ("Decree 132/2024").

Under Decree 132/2024, certain companies in Catalonia must prepare sustainable mobility plans before August 9, 2025, to reduce pollution and promote sustainable transport.

Companies in Catalonia that meet the following criteria must have a sustainable mobility plan:

• a workplace with over 500 employees—internal or external—or over 250 employees per shift; or
• a workplace with over 200 employees—internal or external—located in an area where air quality exceeds the limit values or corresponding target values established in Royal Decree 102/2011, of January 28.

To comply with the regulation, these workplaces must have plans that:

• are based on sustainability criteria and aimed at reducing pollution;
• include measures to reduce the inefficient use of private vehicles by both employees and supplier companies, visitors, and clients (under article 12 of Decree 132/2024, trips must be made using sustainable transport, with priority given to collective transport);
• are prepared with employees’ participation (Decree 132/2024 does not specify how or with who this participation must be carried out); and
• are subject to informing the competent regional mobility authority (the plan is required for processing administrative permits for activities, as well as for modifications and revisions).

Every two years companies must submit a follow-up report on the plan to the competent regional authority.

Decree 132/2024 reaffirms the political interest in driving more sustainable and environmentally friendly business environments that, above all, promote sustainable mobility. Although Decree 132/2024 only affects workplaces in Catalonia, we cannot forget that the Sustainable Mobility Bill has been undergoing parliamentary processing since 2023, which could possibly impose similar obligations. While the bill establishes a clear obligation to negotiate these plans with the workers' representatives, Decree 132/2024, although providing for necessary employee participation, does not specify how this participation should be implemented.

Companies with workplaces in Catalonia that reach the established threshold of employees must meet this obligation. It is important for companies to be aware of this obligation, since there is a specified period to prepare and approve the corresponding plans.