Spain's Sustainable Mobility Law sets out calendar of obligations and opportunities to 2030
Published on 30th January 2026
The new law introduces milestones with mandatory deadlines for companies, administrations and transport operators
The entry into force of Law 9/2025 of 3 December on Sustainable Mobility triggers a very demanding schedule of regulatory milestones. What is changing and when and how might it impact businesses?
Sustainability Mobility Law: deadlines, milestones and obligations
| Deadline | Milestone or obligation | Detailed description |
1 January 2026 (Immediate) | RENFE punctuality criteria | Reinstatement of Spain's state railway RENFE's punctuality criteria with effect from this date, including 50% refunds for delays of 15 minutes and 100% refunds for delays of 30 minutes on high-speed and long-distance services. AP 31. |
31 January 2026 (56 days) | Certification of island transport discounts 2026 | Certification of the 100% discount on public transport passes in the Canary Islands and Balearic Islands for the year 2026, applicable to residents on regular public passenger transport services. AP 34. |
4 February 2026 (60 days) | Soria–Calatayud connection | Establishment by resolution of the conditions for the high-speed rail connection between Soria and Calatayud, guaranteeing Soria's connection to the high-speed network. AP 14. |
6 February 2026 (2 months) | Railway emergency plan - phase 1 | Identification of priority passenger traffic lines (LTV) by province for infrastructure and service improvements. This takes into account the LTV's speed limitations, track condition and rolling stock. AP 30. |
| Emergency passenger care plan | Preparation of an emergency response plan for rail passengers in the event of incidents, establishing protocols for information, assistance and alternative transport. AP 30. | |
| Incident analysis protocol | Approval of the protocol for analysing rail incidents and corrective measures, with regular publication of information on incidents and actions taken. AP 30. | |
6 March 2026 (3 months) | Vehicle fleet renewal plan | Regulatory development of the vehicle fleet renewal plan, establishing measures to support the replacement of old vehicles with low- or zero-emission vehicles. AP 21. |
| Renewable energy targets | Proposal for provisions on binding renewable energy targets and greenhouse gas intensity reduction in transport, transposing the RED III Directive. AP 23. | |
6 April 2026 (4 months) | Railway emergency plan - phase 2 | Remaining measures of the railway emergency plan not included in phase 1, completing the improvements to railway infrastructure and services. AP 30. |
6 June 2026 (6 months) | Study on domestic flights | Presentation of the technical, economic, social and environmental study to rationalise short domestic flights with rail alternatives of less than 2 hours and 30 minutes, including a public hearing and possible regulatory proposal. AP 16th.3. |
| Railway study in Galicia | Preparation of a study on daily rail mobility in Galicia, analysing the feasibility of new services and improvements to the Galician rail network. AP 19. | |
| Electricity network capacity map | Publication of the national map of electricity grid capacity for electric vehicle charging points; distribution companies must submit the necessary information within the same timeframe. AP 28. | |
| Public transport financing strategy | Preparation and presentation to the Sectoral Conference on Transport and Sustainable Mobility of the public passenger transport financing strategy. AP 36. | |
| Report on rural transport on demand | Diagnostic report on the legal and operational situation of on-demand transport in rural areas, analysing its regulation, operation and proposals for improvement. AP 37.2. | |
| List of facilities in ports | Puertos del Estado will publish a list of facilities and services supplying electricity or alternative fuels available in ports of general interest. Article 35.4 | |
| 30 June 2026 | Regulations of the Sandbox Office | Approval of the regulations governing the operation and powers of the Management Office of the controlled testing area for innovation in mobility. FP 13. |
6 October 2026 (10 months) | Digitisation of control documents | The road freight transport control document and the road passenger transport route sheet must be available in digital format. TP 8. |
6 December 2026 (12 months) | Municipal sustainable mobility plans | Municipalities with between 20,000 and 49,999 inhabitants must approve a simplified sustainable mobility plan, with measures for active mobility, public transport and urban goods distribution, reviewable every six years with triennial monitoring. Article 24.1-2. |
| FECMO regulatory bases | Publication of the regulatory bases for subsidies from the State Mobility Costs Fund to finance urban transport operating costs and mobility investment projects. FP 10. | |
| New state bus concession map | Approval by the Council of Ministers of the new concession map for regular road passenger transport, defining all state services in accordance with the new principles of the Law and providing for coordination with the autonomous communities. TP 2.1. | |
| Regulatory development National Access Point | Regulatory development of the method of use of data from the multimodal National Access Point, establishing formats, protocols and conditions of access. Article 91. | |
| Multimodal ticket regulations | Regulatory development of the conditions for agreements with multimodal ticket providers and the supervisory powers of the CNMC, Spain's competition regulator, over these services. Article 92. | |
| Methodology for emissions in ports and airports | Scope and methodology .for estimating atmospheric emissions in ports and airports, agreed upon by the ministries responsible for transport and the environment. Article 37. | |
| "Freight 30" targets | Approval of estimated greenhouse gas reduction targets until 2030 linked to the increased use of rail freight. AP 9. | |
| Ultra-fast charging signage | Update of standards and instructions for the signage of ultra-fast recharging stations on the state road network. AP 18. |
| 1 January 2027 | Digitisation of open data | Mobility service providers and infrastructure managers must ensure digital access to the static, dynamic and historical data defined in annex I of the Sustainable Mobility Law in standard and interoperable formats. Articles 85.2 and 86.2. |
6 June 2027 (18 months) | First DOMOS | Approval of the first sustainable mobility guidance document by the Council of Ministers, which sets out general guidelines, objectives, paths and milestones, planning criteria and indicators; it will be binding on the General State Administration and will condition its aid. AP 2; Article 15. |
6 September 2027 (21 months) | Charging points in large facilities | Installation of charging groups of at least 400 kilowatts (kW) (with at least one 150 kW direct current point) in existing large fuel supply facilities. FP 20. |
6 December 2027 (24 months)
Until 6 December 2028 (24 months from approval of the map) | Commuting plans | Companies and public entities with centres employing more than 200 workers or more than 100 per shift must have a sustainable mobility plan for work, negotiated with employee representatives, with hierarchical solutions (active mobility, collective transport, low-zero emissions), biennial monitoring and registration in the EDIM (Integrated Mobility Data Space). Article 26.1-2. |
| Framework for action in ports | Port authorities must develop a framework for action on energy efficiency and the supply of alternative energies in their ports that are coordinated with company plans. Article 35.5. | |
| Infrastructure assessment methodologies | Approval by ministerial order of ex ante and ex post infrastructure assessment methodologies, including socio-economic, environmental and greenhouse gas emissions analysis. Article 50.4. | |
| State Strategy against Transport Poverty | Preparation and approval of the State Strategy against Transport Poverty, establishing measures to guarantee access to mobility for people in vulnerable situations. AP 10. | |
| Tendering of concessions for the new map | Tendering of all concession contracts for the new bus concession map (two years from approval of the map); tendering must begin within the first 6 months of the map's approval (1 year from the entry into force of the Sustainable Mobility Law). TP 2.3. | |
| 31 December 2029 | Electricity supply to aircraft | European milestone on electricity supply to aircraft parked at airports in the Trans-European Transport Network. Article 34.1. |
| Before 2030 | Electricity supply in TEN-T ports | Electricity supply to ships available at passenger and container terminals in ports in the trans-European transport network, in accordance with European regulations. Article 35.2. |
6 December 2030 (5 years) | Ex-post evaluation of investments since 2015 | Socio-economic and environmental assessment of railway lines and major road infrastructure put into service since 2015, analysing their actual profitability and compliance with objectives. AP 8. |
| From 2030 | Electricity supply in other ports | Supply at passenger ship and container ship terminals in other ports where the port's governing body has so decided. Art. 35.2. |
* AP stands for additional provision, FP stands for final provision and TP stands for transitional provision.
Post-Adamuz review
Following the railway accident that occurred in Adamuz on 18 January, a comprehensive review of both the Emergency Passenger Care Plan and the Incident Analysis Protocol established in the 13th additional provision of the Sustainable Mobility Law, with a deadline for preparation and approval set for 6 February 2026, is widely anticipated.
The Emergency Passenger Care Plan must establish protocols for information, assistance and alternative transport for rail passengers in the event of incidents, while the Incident Analysis Protocol aims to analyse rail incidents and define corrective measures, with regular publication of information on incidents and actions taken.
Osborne Clarke comment
The tragic event in Adamuz highlights the urgent need for robust and effective mechanisms that not only respond adequately to rail emergencies but also enable the identification of systemic failures and the adoption of preventive measures.
It is therefore to be expected that both instruments will incorporate lessons learned from this accident and reinforce safety, communication and crisis response standards for incidents of this magnitude in the railway sector.
If you would like to know more about the issue discussed in this note, please do not hesitate to contact one of our experts listed below or your usual contact at Osborne Clarke.
