Spain Races Ahead on CSRD: 2025 Data, 2026 Publication for Large Companies

Spain is not waiting for Brussels. With a new national climate decree and its CSRD transposition bill on a fast track, the country is pulling forward key sustainability reporting obligations for non-listed companies that might have expected more time.

In March 2025, Spain adopted Royal Decree 214/2025, which turns carbon footprint reporting from a voluntary initiative into a legal requirement. The decree requires companies in scope to calculate their 2025 organizational footprint, publish a five-year greenhouse gas reduction plan with concrete measures, and make both public in 2026. The law also brings certain public bodies into scope and introduces an “event footprint” obligation for major events with more than 1,500 participants.

At the same time, the bill to transpose the Corporate Sustainability Reporting Directive (CSRD) — known as Ley de Información Empresarial sobre Sostenibilidad (LEIS) — is moving quickly through the Spanish Parliament under an urgent procedure. While this law is not yet in force, Spain’s securities and accounting regulators (CNMV and ICAC) have confirmed that, since 1 January 2025, companies may already report using the European Sustainability Reporting Standards (ESRS) provided they also meet the requirements of Law 11/2018.

What Companies Must Do
For companies operating in Spain, the message is clear:

• Determine if you are in scope. The decree applies to companies already subject to Spain’s non-financial reporting law (Law 11/2018), which generally includes large companies and public-interest entities.
  
  
• Collect 2025 data. Set up systems now to gather Scope 1 and Scope 2 emissions data for the 2025 reporting year. Scope 3 reporting remains voluntary for now, but companies may benefit from starting to map their value-chain emissions early.

• Publish a reduction plan. Prepare a quantified five-year greenhouse gas reduction plan with actions and targets to be disclosed alongside the footprint.

• Align with ESRS. Use ESRS now to make the transition to CSRD smoother once Spain’s law takes effect.

Why This Matters
By pressing ahead, Spain is accelerating the timeline for many companies, pushing them to get their ESG data collection and reporting processes in place much sooner than expected. Those that act early will avoid last-minute compliance pressure, be better positioned for assurance once CSRD is fully in force, and demonstrate climate leadership to stakeholders.

And for large companies outside Spain, this is a clear signal: moving ahead of national deadlines can turn compliance into competitive advantage.