Companies need to implement a plan to reduce the impact on environment for the home-work travel

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By 23 November 2021 (and by 31 December of each year, for the following years) companies with local units with more than 100 employees in a regional capital, or in a metropolitan city, or in a provincial capital or in a municipality with more than 50,000 inhabitants, shall appoint a Mobility Manager and implement a Home-Work Travel Plan according to guidelines that have been issued recently.

By 23 November 2021 (and by 31 December of each year for the following years) companies with local units with more than 100 employees in a regional capital, or in a metropolitan city, or in a provincial capital or in a municipality with more than 50,000 inhabitants, shall:

  • appoint a Mobility Manager; and
  • implement a Home-Work Travel Plan (Piano degli Spostamenti Casa-Lavoro, the “Plan”).

For the purposes of calculating the 100 employees threshold also employees of third-party companies that stably operate at the local unit (e.g. on the bases of a contract, secondment, staff leasing or other) shall be taken into account.

The Plan and the Mobility Manager’s role

The Plan shall include an informative part and a planning one, and is aimed at reducing the use of private transport by employees, encouraging forms of sustainable mobility to improve the accessibility of workplaces, optimizing travels to and from the workplace (e.g. by discouraging the individual use of private cars, encouraging the use of public transport, cycling or micro-mobility). The Plan must be sent  to the Mobility Manager of the competent Municipality, the Area Mobility Manager.

The Mobility Manager, on the basis of the resources made available by the company: (i) drafts the Plan and work for its implementation, also by informing employees and involving them; (ii) supervises the effective implementation of the Plan, also liaising with the Area Mobility Manager, and (iii) identifies any critical issues finding solutions.

The Mobility Manager may be an employee already in force, a new employee or an external consultant but, in any case, s/he must have adequate professional skills in the field of sustainable mobility and environmental protection, as well as the possibility of discuss with the workforce on a daily basis. 

No sanctions for violations

Currently, the relevant legislation does not provide any sanction for non-compliance with those obligations (see Law Decree No. 34/2020, and Decrees No. 179 of 12 May 2021 and No. 209 of 4 August 2021 of the Ministry of Ecological Transition and the Ministry of Infrastructure and Sustainable Mobility, and the so-called "European Green Deal": European Commission Communication of 11 December 2019.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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