Because of rotating shifts, seasonality, and peripheral or island locations, the hotel sector is one of the major “silent” recipients of the new Law 9/2025.
Imagine a hotel where night-shift staff commute to work at 10:00 p.m. because there is no public transport at that time, or an isolated resort where 120 waiters or housekeeping staff share cars every morning with no planning at all.
What until now may have been an “operational” issue, under Law 9/2025 on Sustainable Mobility (LMS) also becomes an enforceable labour obligation that companies must comply with within 12 months of the law’s entry into force; that is, by 5 December 2026.
Why is the tourism sector one of those most affected by the LMS?
Article 26 of the LMS requires workplaces to have a sustainable commuting mobility plan in centres with more than 200 workers or more than 100 workers per shift.
The “shift” threshold is decisive: many hotels may not exceed 200 workers in total, but they may have more than 100 working at the same time during peak season (front desk, housekeeping, food and beverage, kitchen, maintenance, and spa), which directly affects large holiday establishments, resorts, and urban hotel chains.
In addition, the LMS defines the plan as a set of measures aimed at rationalising travel not only for staff, but also for customers, suppliers, and visitors.
An obligation that requires prior negotiation with the workforce
The plan cannot be approved unilaterally by the company: it must be negotiated at each work centre that exceeds the thresholds indicated with the employees’ legal representatives or, failing that, with the most representative trade unions and with trade unions representative of the hospitality sector.
Likewise, it can be expected that future collective bargaining agreements in the hospitality sector will establish new specific obligations in this area, since the LMS requires the bargaining committees for such agreements to address solutions such as promoting collective transport, low-emission mobility, active mobility, and shared or collaborative mobility, in order to meet air-quality and emissions-reduction objectives, avoid congestion, and prevent accidents when commuting to work.
What the plan must contain in a hotel environment
The plan must combine active mobility, collective transport, low-emission mobility, shared or collaborative mobility, charging infrastructure for zero-emission vehicles, and, where possible, remote work.
It must also include measures relating to improved road safety and the prevention of in itinere accidents and, where appropriate, compensation for the carbon footprint associated with greenhouse-gas-emitting mobility that could not be addressed.
Ultimately, the LMS is not a “transport” rule that is only tangentially related to the hotel sector: it reshapes the employment relationship around commuting and, given the very structure of tourist accommodation—dense shifts, potentially complex locations, and seasonal workforces—it has a direct impact on hotels, tourist apartments, and resorts.
In addition, these plans can be used to comply with each company’s sustainable development strategies and leveraged as a value proposition to strengthen each hotel brand.
The timetable is demanding (12 months, expiring on 6 December 2026) and negotiation requires advance preparation—diagnosis, analysis of public transport at the destination, etc.—which makes it urgent to start the work early to avoid having to act under time pressure.
