Spain has just raised the stakes for corporate sustainability. Royal Decree 214/2025, effective June 12, 2025, transforms carbon reporting from a nice-to-have into a legal requirement for thousands of Spanish companies. This is a big change in how Spanish businesses approach decarbonisation, with mandatory scope 1 and 2 reporting starting immediately and scope 3 following by 2028.
The decree locally implements key elements of the Corporate Sustainability Reporting Directive (CSRD), casting a much wider net than previous voluntary frameworks. From large private companies to public entities and even event organisers, around 4,000 organisations must now prepare comprehensive carbon footprints and five-year reduction plans. Non-compliance carries a serious consequence: exclusion from public procurement processes—a risk no business can afford in Spain's substantial public sector market.
Zusammenfassung
Royal Decree 214/2025 represents Spain's most ambitious corporate carbon reporting mandate to date. The regulation expands mandatory reporting from a select group of companies already covered under Spain Law 11/2018 to include all large enterprises meeting specific thresholds, public entities, and event organisers managing gatherings over 1,500 attendees.
Key obligations include:
- Mandatory scope 1 and 2 emissions reporting from 2025
- Scope 3 emissions required for large entities from 2028
- Five-year quantified greenhouse gas reduction plans
- Public disclosure via national carbon register or online publication
- Annual compliance with MITECO technical specifications
The regulation takes effect immediately, with first reports due in the 2026 reporting cycle covering 2025 emissions data. Businesses have six months from fiscal year-end to publish their carbon footprints and reduction plans.
What is the regulation
Royal Decree 214/2025 establishes Spain's new national carbon reporting framework, building upon existing European sustainability directives while creating Spain-specific requirements. The Ministry for Ecological Transition and Demographic Challenge (MITECO) serves as the enforcement authority, setting technical requirements and overseeing compliance.
Unlike purely voluntary sustainability initiatives, this decree carries legal weight. While specific financial penalties aren't detailed, non-compliance results in exclusion from public procurement processes—a significant business risk given that public sector spending represents approximately 18% of Spain's GDP.
Legal foundation and scope
The decree implements portions of the CSRD at national level, creating a comprehensive carbon accounting framework that extends beyond traditional large corporation reporting. It requires affected entities to calculate their greenhouse gas emissions using internationally recognised methodologies, establish quantified reduction targets spanning at least five years, and publicly disclose their progress.
The regulation mandates use of the Greenhouse Gas Protocol framework, ensuring consistency with global standards while incorporating Spain-specific emission factors. This approach provides businesses with locally relevant data whilst maintaining international comparability—crucial for multinational companies operating across borders.
Reporting methodology requirements
Organisations must structure their emissions data according to the three-scope framework: direct emissions from owned sources (scope 1), indirect emissions from purchased energy (scope 2), and all other value chain emissions (scope 3). The decree requires detailed breakdown by emission categories, enabling granular analysis of carbon hotspots across operations.
For companies seeking maximum accuracy, activity-based calculations using specific emission factors are preferred. However, the regulation acknowledges data availability challenges, permitting spend-based calculations where primary activity data isn't accessible. This flexibility ensures comprehensive reporting whilst organisations build more sophisticated data collection systems.
Who does it concern?
The decree significantly expands Spain's carbon reporting landscape, affecting approximately 4,000 entities across three main categories. This represents a substantial increase from previous voluntary frameworks, bringing thousands of organisations into mandatory compliance for the first time.
Large private enterprises
Private companies must comply if they meet any threshold for two consecutive years: more than 250 employees, more than €20 million in assets, or more than €40 million in annual turnover. This captures medium-to-large businesses across all sectors, from manufacturing and retail to professional services and technology companies.
These thresholds align with existing non-financial reporting requirements under Spain Law 11/2018, ensuring consistency across sustainability reporting frameworks. Companies already subject to these requirements will find familiar ground, though carbon-specific obligations represent new territory requiring specialised expertise and systems.
Public entities and administration
All Spanish public entities face mandatory compliance, regardless of size or budget. This encompasses central government departments, regional administrations, municipalities, and state-owned enterprises preparing consolidated financial statements. Public entities must lead by example, demonstrating commitment to decarbonisation across government operations.
Public sector compliance extends beyond internal operations to procurement practices. Public entities must consider suppliers' carbon reporting status when evaluating tenders, creating ripple effects throughout Spanish supply chains. Businesses seeking public contracts must demonstrate carbon transparency or risk exclusion from lucrative government opportunities.
Event organisers
A unique aspect of Spain's regulation covers events with more than 1,500 attendees, recognising the significant carbon footprint of large gatherings. Event organisers—whether private companies, public entities, or non-profit organisations—must calculate and report emissions from venue energy use, participant travel, catering, waste generation, and accommodation.
This requirement reflects growing awareness of events' environmental impact, from corporate conferences and trade shows to cultural festivals and sporting competitions. Event carbon footprints often reveal substantial scope 3 emissions from attendee travel, creating opportunities for meaningful reduction through venue selection, transport encouragement, and hybrid formats.
How to report
Spanish carbon reporting follows a structured approach designed to ensure consistency, accuracy, and comparability across all reporting entities. The framework balances international standards with Spain-specific requirements, creating a comprehensive system that serves both regulatory compliance and business decision-making.
Data collection and calculation methodology
Successful reporting begins with systematic data collection across all emission sources. Organisations must gather activity data from energy bills, fuel consumption records, travel expenses, waste disposal contracts, and supplier information. The regulation permits various calculation approaches depending on data availability and accuracy requirements.
Activity-based calculations provide the highest precision, using specific consumption data multiplied by appropriate emission factors. For example, a manufacturing company would multiply electricity consumption in kilowatt-hours by Spain's grid emission factor to calculate scope 2 emissions. When activity data isn't available, spend-based calculations use financial expenditure multiplied by sector-specific emission factors.
Key data sources include:
- Energy bills and meter readings for scope 2 calculations
- Fuel consumption records for company vehicles and facilities
- Travel booking systems for business trip emissions
- Waste disposal contracts and tonnage records
- Supplier sustainability reports and primary data requests
- Financial expenditure across emission-relevant categories
Scope-specific calculation requirements
Scope 1 emissions encompass direct emissions from sources owned or controlled by the organisation. For most businesses, this includes natural gas heating, company vehicle fuel, and any on-site combustion processes. Manufacturing companies must also account for process emissions and fugitive emissions from refrigeration equipment.
Scope 2 emissions cover indirect emissions from purchased electricity, heating, cooling, and steam. Spain's evolving energy grid, with increasing renewable energy penetration, requires careful attention to location-based versus market-based calculation methods. Companies purchasing renewable energy certificates can use market-based methods to reflect their clean energy choices.
Scope 3 emissions, mandatory for large entities from 2028, present the greatest complexity. The regulation requires assessment across 15 categories, from purchased goods and services through to end-of-life treatment of products. Most organisations find that scope 3 emissions represent 70-80% of their total carbon footprint, making accurate measurement critical for effective decarbonisation.
Publication and disclosure requirements
Organisations must publish their carbon footprints and reduction plans within six months of fiscal year-end through one of two channels: Spain's national carbon register or online publication via company websites or sustainability reports. Publishing through the national register provides official recognition through a carbon reporting label.
Reports must include comprehensive emissions data broken down by scope and category, methodology explanations, data quality assessments, and five-year reduction plans with quantified targets. The disclosure format must align with MITECO technical specifications whilst remaining accessible to stakeholders including investors, customers, and community members.
Platforms like Plan A streamline this process by automatically generating reports that meet Spanish regulatory requirements whilst providing the granular insights needed for effective decarbonisation planning. The platform's Spain-specific emission factors ensure accurate calculation whilst integrated reporting tools simplify the publication process.
Verification and assurance requirements
Large companies and entities meeting specific criteria must obtain third-party verification of their carbon footprints and reduction plans. This requirement ensures data accuracy whilst building stakeholder confidence in reported emissions. Verification covers calculation methodologies, data sources, emission factors, and the reasonableness of reduction targets.
The verification process typically involves document review, site visits, and testing of key data sources. Verifiers assess whether organisations have appropriate systems and controls for carbon data collection, whether calculations follow recognised standards, and whether reported emissions fairly represent actual performance.
Getting ready for the regulation
Preparing for Spain's new carbon reporting requirements demands strategic planning, system development, and organisational capability building. Companies that start early will find compliance more manageable whilst gaining valuable insights for business decision-making and competitive advantage.
Immediate preparatory steps
Begin by conducting a preliminary carbon footprint assessment to understand your organisation's emission sources and data availability. This diagnostic exercise reveals gaps in data collection systems, identifies major emission hotspots, and provides baseline understanding for target setting. Even rough calculations help prioritise preparation efforts.
Establish a cross-functional team bringing together sustainability, operations, finance, procurement, and IT expertise. Carbon accounting touches every business function, requiring coordination across traditionally separate departments. Assign clear roles for data collection, calculation oversight, and reporting preparation to ensure nothing falls through organisational cracks.
Data infrastructure development
Robust carbon reporting requires systematic data collection and management processes. Many organisations discover that their current systems don't capture the granular information needed for accurate carbon accounting, particularly for scope 3 emissions requiring supplier engagement and supply chain transparency.
Start by improving data collection for scope 1 and 2 emissions, which offer the clearest measurement pathways. Install energy monitoring systems, improve travel booking procedures to capture emission-relevant information, and establish regular data collection schedules. These foundations support accurate reporting whilst building organisational carbon literacy.
For scope 3 preparation, begin supplier engagement early. Large entities must report scope 3 emissions from 2028, but building supplier relationships and data collection processes takes time. Start with major suppliers representing the largest share of procurement spend, gradually expanding coverage as systems mature.
Plan A's data collection platform automates much of this process, with intelligent data mapping that learns from your uploads and integrates with existing business systems. The platform's API enables seamless data transfer whilst AI-powered tools extract relevant information from invoices, bills, and supplier reports.
Building reduction plans and targets
Spanish regulation requires five-year quantified reduction plans, pushing organisations beyond measurement toward concrete action. Effective plans identify emission reduction opportunities, quantify potential impact, and establish implementation timelines with clear accountability measures.
Start target setting with science-based approaches aligned with Spain's national climate commitments and international agreements. The regulation encourages alignment with Science Based Targets initiative (SBTi) methodologies, ensuring targets contribute meaningfully to global decarbonisation goals whilst maintaining business realism.
Target development should consider:
- Absolute emission reductions across all scopes
- Intensity-based targets linking emissions to business growth metrics
- Interim milestones enabling progress monitoring and course correction
- Financial implications including investment requirements and operational savings
- Supply chain engagement requirements for scope 3 reductions
- Technology roadmaps for major decarbonisation initiatives
Leveraging technology for compliance
Modern carbon accounting platforms significantly reduce the administrative burden of regulatory compliance whilst providing strategic insights for business improvement. These solutions automate data collection, ensure calculation accuracy, and generate reports meeting Spanish regulatory requirements.
Plan A's platform offers particular advantages for Spanish compliance, including:
- Spain-specific emission factors reflecting local energy grid and transport system
- AI-powered insights highlighting reduction opportunities and financial implications
- Supplier engagement tools facilitating scope 3 data collection
The platform's measurement capabilities ensure accurate calculation across all emission scopes whilst providing the granular analysis needed for effective reduction planning. Built-in verification support prepares organisations for third-party assurance requirements.
Start your Scope 1 and 2 reporting now
Spain's new carbon reporting requirements create both challenges and opportunities for businesses ready to embrace systematic decarbonisation. Above all, it creates a sense of urgency.
Organisations that prepare thoroughly, invest in appropriate systems, and develop genuine reduction capabilities will find competitive advantages in an increasingly carbon-conscious marketplace. Those that treat compliance as a mere box-ticking exercise risk missing the strategic benefits of comprehensive carbon management.
Request a demo to discover how Plan A's platform and expertise can streamline your Spanish carbon reporting compliance whilst building the foundation for long-term decarbonisation success. With regulatory deadlines approaching quickly, early preparation ensures smooth compliance and positions your organisation for leadership in Spain's evolving sustainable business landscape.
