Law 9/2025, of 3 December, on Sustainable Mobility and its impact on the decarbonisation of the economy

On 5 December last, Law 9/2025 of 3 December on Sustainable Mobility (the "Sustainable Mobility Law") came into force: a new legal framework that aims to establish the necessary conditions for citizens and entities to have a sustainable, fair and inclusive mobility system, prioritising decarbonisation and energy efficiency.

This extensive regulatory package especially affects medium and large companies and, transversally, various sectors, including the electricity, rail and road transport sectors, addressing issues such as low-emission zones, self-consumption, electric vehicle charging services, climate change and energy transition, among others. The Sustainable Mobility Law leaves room for subsequent regulatory development by the competent administrations.

A new sustainable mobility

The Sustainable Mobility Law promotes a paradigm shift in terms of mobility: from a vehicle-centred approach to a model that prioritises people. To this end, it creates the General Sustainable Mobility System (SGMS), which establishes a framework for cooperation between the State, the autonomous communities and local authorities, with the active participation of civil society, the private sector and academia. Its bodies include the Territorial Forum for Sustainable Mobility and the High Council for Sustainable Mobility, responsible for coordinating policies, drawing up plans and supervising their implementation.

To develop its activity, the SGMS will have two tools: (i) the Integrated Mobility Data Space as a digital instrument that systematises information on the functioning of the transport and mobility system, guaranteeing its availability through open data; and (ii) the Document of Guidelines for Sustainable Mobility (DOMOS), which contains the guidelines for the planning and sustainable management of transport and mobility.

The regulation establishes a stable financing framework for the operation of the system and the planned actions, complemented by the creation of the State Fund for Sustainable Mobility Contribution, aimed at public transport and sustainable mobility projects at different territorial scales.

Planning and management

A hierarchy of mobility planning instruments and obligations is established. The DOMOS will be approved by agreement of the Council of Ministers and is binding for all public policies of the General State Administration, especially conditioning the state aid policy on mobility.

Subsequently, the State Strategic Mobility Planning Instrument (IPEEM) sets the state priorities, consistent with the objectives of decarbonisation, cohesion and efficiency.

At the regional level, the autonomous communities may approve the transport and mobility planning instruments they deem appropriate, while municipalities with more than 20,000 and less than 50,000 inhabitants must adopt sustainable mobility plans within one year of the entry into force of the Law.

At the business level, plans are introduced for large centres of activity and business mobility plans. Centres with a high flow of people and companies with certain staff thresholds will have to implement mobility plans (collective transport, active mobility, low emissions, carpooling/carsharing, working from home where possible, road safety).

Railway sector

The Sustainable Mobility Law introduces important innovations in the railway sector. A shock plan will be approved with the necessary resources to reduce, in the short and medium term, incidents in medium and long distance services, as well as Cercanías/Rodalies, in two phases: within a maximum period of two months, all existing temporary limitations on the track due to incidents in the infrastructure will be identified in each province, and within a maximum period of four months, the rest of the necessary measures will be identified.

The Ministry of Transport and Sustainable Mobility will promote the reduction of domestic flights on those routes where there is a rail alternative with a duration of less than two and a half hours, except in cases of connection with airports linking with international routes.

Road transport

Within one year of the entry into force of the regulation, the Council of Ministers must approve the new concession map, which will include all regular public passenger transport services for general use by road in Spain. Within two years of its approval, the service concession contracts for all state concessions in this area must be put out to tender.

For the first time, a definition of collaborative mobility services has been introduced into the Land Transport Law, classifying them as "private transport" when they are provided for free, except for the sharing of costs. Collaborative mobility services or carpooling are defined as "services in which several users share a tourist vehicle on the same journey, carried out for free, except for the sharing of costs, by contacting each other through an intermediation platform".

The regulation encourages innovation through a regulatory sandbox for pilot projects and the creation of the Office for the Facilitation of Automated Vehicle Testing (OFVA), in order to gradually introduce automated vehicles on public roads.

Port system

Port authorities will actively promote the implementation of measures to reduce pollutant emissions through the provision of alternative energy sources for ships, vessels, port machinery and vehicles in ports. By 2030, electricity supply service should be available in passenger and container terminals.

Within six months of the entry into force of the regulation, the State Port Authority will have to publish the list of facilities available for the supply of electricity and alternative fuels in each port, while the port authorities will draw up a framework for action to guarantee energy efficiency and the provision of the alternative energy supply service.

Renewable energy production facilities within a port will have the status of "production facilities close to those of consumption", allowing renewable generation to be shared throughout the port area without distance limitation, and Port Authorities will be able to participate in partnerships for the development of electricity assets linked to the supply of energy to ships when justified by efficiency reasons linked to decarbonisation objectives.

Law 9/2025 of 3 December on Sustainable Mobility, in force since 5 December, establishes a new legal framework that prioritises decarbonisation and a people-centred mobility model over the vehicle. As it requires extensive subsequent regulatory development, it will be essential to closely monitor the legislative developments published over the coming months, on which we will continue to keep you informed from our department.

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