The transition to decarbonized corporate mobility is no longer just a matter of voluntary commitment or isolated CSR initiatives.
In 2026, the French regulatory framework imposes strict requirements on organizations to streamline employee travel. At the heart of this legal framework is the employer mobility plan (PDM), a strategic tool designed to optimize the efficiency of work-related travel. Initially introduced under different names, this mechanism was significantly strengthened by the Mobility Orientation Law (LOM).
For fleet managers, procurement directors, and business leaders, achieving compliance represents a significant operational challenge, but also a major financial opportunity.
This article details the 2026 mandatory PDM requirements, the structure needed for implementation, essential performance indicators, and concrete levers to turn this legal obligation into a powerful tool for reducing transport costs.
The corporate mobility plan is governed by specific legislative texts that define its scope of application. Understanding these rules is essential to avoid legal and operational risks.
Under the LOM law, the obligation to implement an employer mobility plan applies to companies with more than 50 employees at a single site. The text specifies that this obligation applies as long as the company is located within the territorial jurisdiction of a Mobility Organizing Authority (AOM) that has an approved or revised Urban Mobility Plan (PDU).
Headcount is calculated per site rather than at the company-wide level. In practice, an organization with several branches of 30 employees is not legally subject to the requirement for those sites, whereas a single establishment with 55 employees is immediately subject to it.
The regulatory landscape has undergone a major shift. The Inter-Company Mobility Plan (PDIE) and former corporate travel plans have been harmonized and modernized under the single designation of the employer mobility plan.
In 2026, the focus is on the obligation to negotiate mobility as part of the mandatory annual negotiations (NAO) on quality of life and working conditions (QVCT). In the absence of a Social and Economic Committee (CSE) or union agreement on this topic, the development of a unilateral mobility plan becomes a strict legal obligation for the employer.
Although the law does not provide for direct financial penalties or immediate flat-rate fines for the absence of a mobility plan, the indirect risks to organizations are significant.
A corporate mobility plan cannot be limited to a mere statement of intent. To be validated by the competent authorities, it must follow a rigorous methodology structured around specific deliverables.
The first mandatory step is to conduct a comprehensive assessment of home-to-work travel. This document maps out employee commuting habits, distances traveled, working hours, and the modes of transport used.
The assessment also analyzes the accessibility of the company site. It evaluates the availability of nearby public transport, the existence of bike paths, and the capacity of parking infrastructure. The analysis of business travel (client meetings, deliveries) is also included to provide a complete overview of the organization's mobility flows.
Following the assessment, the company must formalize a program of concrete actions that promote corporate multimodal mobility. This plan details alternatives to the individual use of solo internal combustion engine cars.
The measures must be accompanied by a precise deployment schedule, a projected budget, and the designation of internal leads for each project.
Once formalized, the draft mobility plan must be submitted for review to the local Mobility Organizing Authority (AOM) (for example, Île-de-France Mobilités, the metropolitan area, or the community of municipalities).
The AOM acts in an advisory and evaluative capacity. It verifies that the company's actions are consistent with the region's overall transport policy. Failure to submit the plan or filing an incomplete dossier is legally equivalent to non-compliance.
Managing a mobility plan requires the establishment of precise evaluation criteria. These metrics make it possible to validate the achievement of objectives and to adjust corrective actions.
Companies must define measurable mobility plan indicators. Quantitative indicators measure actual changes in commuting behavior on an annual basis. Examples include tracking the carpooling penetration rate, the number of employees using the Sustainable Mobility Package, or the usage rate of active travel modes.
Qualitative indicators assess employee perceptions and improvements in their quality of life. Satisfaction levels regarding flexible working hours or the accessibility of cycling infrastructure are key data points for measuring team buy-in for the transition project.
For fleet managers, the convergence between company vehicle management and mobility plans occurs through precise business indicators. Tracking vehicle turnover rates, parking space vacancy rates, and changes in the fleet's average fuel consumption are critical data points. To further refine the management of these metrics, a detailed analysis of essential KPIs for managing your fleet in 2026 provides an essential methodological foundation for correlating fleet performance with mobility plan objectives.
The mobility plan feeds directly into the company's CSR mobility reporting. The collected data makes it possible to calculate the carbon footprint associated with employee commuting (Scope 3 of the GHG inventory).
The annual publication of these results enhances the employer brand and meets the requirements of the CSRD directive for affected companies. Rigorous monitoring transforms an administrative requirement into a demonstration of environmental transparency for investors and clients.
Contrary to popular belief, an employer mobility plan is not just a cost center. When applied methodically, it serves as a major financial optimization lever for the organization.
Implementing remote work, carpooling, and mobility plans generates substantial direct savings. By reducing the frequency of home-to-work commutes through remote work, companies decrease the need for physical infrastructure, specifically the size and maintenance costs of corporate parking lots.
Promoting carpooling reduces the payment of individual mileage allowances. Fewer professional road trips also mean a direct decrease in accident rates, which translates into lower insurance premiums for the company fleet.
Oriway has even designed a solidarity carpooling initiative to reward shared trips in electric vehicles. Every kilometer driven via carpooling earns you €0.05 in charging credit.
The Sustainable Mobility Package (FMD) replaces former bicycle or carpooling mileage allowance schemes. In 2026, the FMD allows employers to cover all or part of the personal travel expenses of employees who use eco-friendly modes of transport (cycling, carpooling, shared transport).
This coverage is exempt from income tax for the employee and benefits from an exemption on social security contributions for the company, up to the current legal limits. This mechanism increases employee purchasing power at a lower net cost than a standard salary increase or fuel expense reimbursement.
The ROI of a mobility plan is calculated by comparing deployment costs (purchasing company bikes, setting up dedicated parking, management software tools) with the savings achieved in transport-related expenses.
Example of budget savings calculation: a company with 100 employees that reduces its combustion-engine car travel by 15% in favor of electric vehicles, cycling, and remote work saves an average of tens of thousands of euros per year in fuel costs, mileage allowances, and parking management.
To accurately assess these financial levers for your organization, you can simulate the financial impact of your mobility policy using dedicated analysis tools.
An effective mobility plan cannot function in a silo. It must be perfectly synchronized with the overall corporate fleet mobility policy to maximize its impact.
The role of the fleet manager is evolving to meet new legal requirements. They no longer just manage vehicles; they orchestrate the company's overall mobility. The mobility plan redefines how company and service vehicles are assigned.
Analyzing driver profiles through a mobility audit helps reassess the actual needs of each employee. Some staff members with low-usage company vehicles can transition to a mobility budget, providing access to a range of multimodal transport options (electric vehicles, trains, carpooling, and bike-sharing).
Fleet electrification within a mobility plan is a vital part of any operational roadmap. Energy transition laws mandate increasing quotas for low-emission vehicles when renewing fleets of over 100 vehicles.
The mobility plan facilitates this transition by scheduling the deployment of electric vehicle charging infrastructure (EVCI) at company sites. The mobility plan audit allows you to precisely calibrate the power and number of charging stations needed based on the actual parking times of your employees. To succeed in this energy transition without disrupting your standard logistics, the key is to switch to electric without disrupting your operations through expert support and a rigorous sequencing of your vehicle renewals.
Manually managing a mobility plan alongside a vehicle fleet quickly becomes complex and time-consuming. Using a SaaS platform centralized approach is essential for effectively managing compliance and budgets.
These tools allow you to track key performance indicators in real time, manage the allocation of mobility benefits (such as the sustainable mobility package or transit passes), oversee energy consumption for electric vehicle fleets, and automatically generate mandatory reports for government agencies or CSR auditors.
The employer mobility plan has become a cornerstone of B2B regulations in 2026. Far from being a mere administrative burden dictated by the LOM law, the mobility plan serves as a powerful lever for financial performance and operational optimization of the company's vehicle fleet.
By rigorously structuring the assessment, planning concrete multimodal actions, and integrating precise tracking indicators, decision-makers can sustainably transform how they manage travel. The successful convergence of traditional fleet policy and new soft mobility solutions not only ensures the organization's legal compliance but also generates substantial savings while improving employees' quality of life at work.
No, the employer mobility plan is only mandatory for companies or establishments with more than 50 employees at a single site, provided that the site is located within the jurisdiction of a Mobility Organizing Authority (AOM) that has an urban travel plan. Smaller organizations can, however, implement one voluntarily to optimize their costs.
If a company subject to the requirement fails to implement its mobility plan, it primarily faces indirect sanctions. It loses access to public subsidies from ADEME or local authorities for its energy transition. Furthermore, it risks labor disputes during mandatory annual negotiations (NAO) and increased scrutiny from the URSSAF regarding its transport expense exemptions.
To conduct an effective home-to-work travel assessment, it is recommended to use a specialized SaaS platform. These tools automate data collection through standardized employee questionnaires and instantly analyze distances, current modes of transport, and site accessibility without requiring complex manual processing.
The Sustainable Mobility Package (FMD) is not technically mandatory, but it is one of the most effective measures to include in a Mobility Plan's action plan. Its implementation must be negotiated with employee representatives. When deployed, it offers significant tax and social benefits for both the company and its employees.
A mobility plan generally leads to the optimization and reduction of a vehicle fleet. By analyzing commute patterns, companies can identify underutilized vehicles and replace company cars with alternatives such as mobility credits, company bikes, or car-sharing, thereby reducing total cost of ownership (TCO).
The obligation to implement an employer mobility plan (PDM) stems fromArticle L. 1214-8-2 of the Transport Code, initially created by the Energy Transition for Green Growth Act (2015), and subsequently significantly amended and strengthened byArticle 82 of the Mobility Orientation Act (LOM Act No. 2019-1428 of December 24, 2019).
The text states that the obligation applies to companies with more than 50 employees at a single site (establishment). It links this requirement to the obligation to negotiate mobility topics (improving employee commutes between home and work) during mandatory annual negotiations (NAO) on quality of life and working conditions (QVCT), as provided for inArticle L. 2242-17 of the Labor CodeIn the absence of an agreement, the company is required to develop this mobility plan.
