The EINF (Non-Financial Information Statement) is a legal compliance and transparency requirement for financial institutions in Spain and across the EU.
If your organisation is a credit institution, insurer, asset manager, or is subject to supervision by the Banco de España or the CNMV, the non-financial information report is not optional. It directly affects reputation, access to finance, and the expectations of supervisors and investors.
For the financial sector, the EINF goes beyond a standalone document. It assesses and communicates the environmental, social and governance impact of the entity, as well as the ESG risks and opportunities linked to the business model. Entities with weak or poorly traceable reports face greater supervisory scrutiny, investor questions, and competitive disadvantage compared to those with structured, auditable ESG data systems.
Those that integrate the EINF into data governance turn non-financial information into a strategic asset: better dialogue with supervisors, smoother compliance, and data that can be reused for double materiality under CSRD, EU Taxonomy, or sustainable finance frameworks.
This guide explains everything financial institutions need to know about the EINF: what the law requires, who is in scope, what content must be included, how to prepare evidence, and how to build a system that serves both the EINF and other reporting frameworks without duplicating effort.
Need EINF, CSRD and supervisor-ready evidence from one ESG data base? Book a Dcycle demo for financial institutions.
Request a demoWhat the EINF is and why it matters for the financial sector
The EINF is not a voluntary sustainability report: it is a legal obligation
The Non-Financial Information Statement is regulated in Spain by Law 11/2018 of 28 December, which transposes Directive 2014/95/EU (NFRD).
The report must include information on environmental, social and employee, human rights, anti-corruption and bribery, and compliance matters, to the extent necessary to understand the company’s development, performance and position. For the financial sector, this translates into ESG risks in the portfolio, impact of financial activity, sustainable lending policies, and transparency towards supervisors and markets.
The CNMV supervises the EINF of issuers with securities admitted to trading and carries out compliance reviews and, for a defined set of entities, more substantive reviews. The Banco de España integrates sustainability into its prudential supervision framework. In practice, a well-founded, traceable EINF reduces the risk of supervisory observations and additional requests.
Who is required to publish the EINF in the financial sector
Capital companies that meet two of three criteria for two consecutive financial years must prepare the EINF: more than 250 employees on average, net turnover exceeding 40 million euros, or total assets exceeding 20 million euros.
Public-interest entities (PIEs) under audit legislation are also required. In the financial sector these include credit institutions, insurance undertakings, managers of collective investment schemes, and listed companies. Thus, most material players in the sector fall within scope.
For consolidated accounts, the thresholds apply on a consolidated basis and the report may be consolidated, covering group entities. Subsidiaries may be exempt if they are covered by the parent’s report.
Minimum content required by law
Law 11/2018 requires the EINF to describe, as a minimum:
- Business model and description of policies applied in non-financial areas, including ESG data and due diligence.
- Outcomes of those policies.
- Main non-financial risks related to the undertaking’s activity and, where relevant, to its operations, supply chain or business relationships.
- Key non-financial performance indicators relevant to the business.
In the financial sector, this typically covers climate risk, sustainable finance, financial inclusion, human rights in the supply chain, and compliance (anti-corruption, conflicts of interest, etc.). The information must be consistent, traceable, and, where the entity is subject to verification, auditable.
Tip: Start with indicators you already report to supervisors or in governance disclosures. If each figure has a methodology, owner and evidence file, verification becomes predictable instead of reactive.
The 4 thematic pillars of the EINF and what they mean for the financial sector
1. Environment
For financial institutions it is not only about the operational footprint (premises, energy, travel). What matters most is impact through the business: project finance, loan book, investments, and underwriting.
- Energy consumption and greenhouse gas emissions (Scopes 1, 2 and 3).
- Resource use, environmental performance, and decarbonisation pathways.
- Sustainable financing and investment policies and alignment with the EU Taxonomy.
- Physical and transition climate risks and how they are managed.
2. Social and employee matters
This includes working conditions, diversity, training, and health and safety, both for the workforce and, where applicable, for the supply chain and relations with clients and communities.
- Employment, equality, non-discrimination and inclusion policies.
- Training and development, occupational health and safety.
- Information on human rights and due diligence in operations and business relationships.
3. Human rights and anti-corruption and bribery
The financial sector is subject to strict integrity and anti-money-laundering rules. The EINF must reflect policies, controls and results in:
- Prevention of corruption and bribery.
- Whistleblowing channels and management of conflicts of interest.
- Human rights due diligence where relevant to the business.
4. Society and corporate governance
- Composition and functioning of the administrative body.
- Remuneration policies, internal control and risk management.
- How non-financial information links to strategy and governance.
For supervised entities, consistency with the governance and risk reports already submitted to supervisors is critical: the EINF must not contradict that information and must be supported by verifiable data.
How the process works in practice: deadlines and verification
Preparation and publication cycle
The EINF is prepared as part of the annual report for the financial year, together with the annual or consolidated accounts. It must be approved by the management body and published with the management report and accounts, and must remain available on the company’s website.
Deadlines align with the approval and filing of the accounts. In practice, financial institutions often close ESG data in parallel with the financial close so that the EINF can be integrated into the annual reporting package.
Independent verification
Law 11/2018 requires the EINF to be verified by an independent assurance services provider in accordance with audit regulation. For public-interest entities, this is mandatory. The verifier issues a report that accompanies the EINF and must be available to supervisors and investors.
This means that every statement and every indicator in the EINF must be supported by evidence: documented methodologies, data sources, responsible parties, and traceability from source data to the report. Without a centralised, governed ESG data base, verification becomes costly and slow.
Link to CSRD and Taxonomy
Entities that already prepare information under double materiality under CSRD or report Taxonomy alignment can reuse much of that information for the EINF. In Spain, the EINF remains the main legal reporting obligation for many entities until full CSRD application by profile. A single ESG data system can feed the EINF, CSRD, Taxonomy and other frameworks without duplicating work.
Building one ESG data base for EINF, CSRD and Taxonomy? We show how financial institutions connect risk systems and reporting in Dcycle.
See the platform5 common mistakes financial institutions make with the EINF
1. Generic documents not anchored in the business
The problem: Policies or descriptions copied from templates that do not reflect the business model, actual risks, or the indicators the entity actually measures.
Why it fails: Supervisors and verifiers quickly spot reports that do not fit the activity, portfolio or structure of the entity.
Solution: Tailor each section of the EINF to the specific financial business: products, channels, materially relevant ESG risks, and indicators with defined methodology and sources.
2. Indicators without traceability or evidence
The problem: Figures or statements in the EINF that cannot be traced back to a source, owner or documented calculation process.
Why it fails: Independent verification requires evidence. Without traceability, the verifier cannot accept the figure and the entity is exposed to observations or a qualified report.
Solution: Define an ESG indicator dictionary, calculation methodologies, data sources and owners. Maintain evidence (exports, interim reports, approvals) that allows every number to be reconstructed.
3. Dispersed data and last-minute manual collection
The problem: Non-financial information sits in spreadsheets, emails and different systems. EINF preparation becomes an annual rally with high risk of errors and inconsistencies.
Why it fails: There is no single source of truth. Deadlines are tight and verification requires consistency and orderly documentation.
Solution: Centralise ESG data in a single platform or process that feeds the EINF and, where applicable, CSRD, Taxonomy and internal reports. Automate collection from ERP and operational systems, risk systems and other sources where possible.
4. Disconnect between the EINF and supervisory reporting
The problem: The EINF tells one story and the reports sent to the Banco de España or CNMV tell another, or there is no explicit link between them.
Why it fails: Supervisors expect consistency. Inconsistencies trigger questions and undermine trust.
Solution: Align definitions, scope and figures between the EINF and regulatory reports. Reuse the same data and methodologies wherever possible.
5. Treating the EINF as a one-off report instead of part of data governance
The problem: The EINF is approached as a document to fill in once a year, without integrating it into ESG data strategy or risk, compliance or reporting processes.
Why it fails: Efficiency is lost, effort is duplicated with other frameworks (CSRD, Taxonomy, SBTi targets), and no lasting capability is built.
Solution: Treat the EINF as an output of an ESG data management system: a single base that serves the legal report, verification, supervision and decision-making.
4-phase preparation plan for the EINF in the financial sector
Phase 1: Quick diagnostic by EINF pillar
Build an inventory by thematic pillar (environment, social, human rights, anti-corruption, governance):
- What documentation and data already exist.
- What is outdated or missing.
- What can be demonstrated with current systems (risk, ERP, HR, etc.).
Deliverable: Gap matrix: current state vs EINF and verification requirements.
Phase 2: Close the highest-impact gaps
Focus on what most affects the quality and verifiability of the report:
- Signed, dated policies with clear scope (entities, countries, activities).
- Assigned owners for each pillar and indicator.
- Definition of key indicators with methodology and sources.
- Evidence of implementation (training, controls, reviews).
Deliverable: Minimum set of documentation and data covering all four pillars and auditable.
Phase 3: Evidence and traceability
Build an evidence folder per criterion: policy, actions and results. For each indicator: methodology, source, frequency and owner. Full traceability from source data to the published figure.
Deliverable: Evidence repository ready for the verifier and for future updates.
Phase 4: Coherence review before submission
Check that every statement in the EINF has documentary support, that scope is consistent with other reports, and that there are no contradictions between sections or with supervisory reports.
Deliverable: Final package ready for management body approval and submission to the verifier.
When done this way, the EINF stops being an annual chore and becomes the result of an ongoing ESG data and reporting discipline.
Why Dcycle is the right solution for the EINF in the financial sector
Choosing an ESG management platform for the EINF in the financial sector means being able to centralise data from multiple sources, maintain full traceability, and produce reports aligned with the law and with verification, without adding unsustainable operational burden.
We are not auditors or consultants. We are a solution for companies and entities that need to centralise, manage and communicate their ESG information with rigour and efficiency. Our goal is for each organisation to collect all its non-financial information and distribute it to the right use cases (EINF, CSRD, Taxonomy, SBTi, carbon footprint) without duplication or manual processes.
Dcycle is an enterprise platform for ESG reporting and double materiality under CSRD and EINF compliance, with ISO 27001 certification and recognised as Friends of EFRAG. We combine European and Spanish regulatory expertise, enterprise-grade capability, and a customer success team focused on helping entities get the most value from their ESG data.
How Dcycle works for EINF preparation
Centralise ESG data from any source (risk systems, ERP, spreadsheets, suppliers) and turn it into standardised, traceable metrics ready for the report and for verification.
Generate documentation compatible with the EINF, CSRD, EU Taxonomy, SBTi or other frameworks in minutes, from the same dataset.
For financial institutions in Spain, aligning internal non-financial reporting with the EINF and with supervisor expectations (CNMV, Banco de España) reduces friction and allows the same evidence to be reused for verification and other frameworks.
Why financial institutions choose Dcycle
Built for rigour and verification: every indicator links to its source, methodology and evidence. The same level of control required for compliance and financial reporting, applied to non-financial information.
One base for multiple frameworks: generate outputs for the EINF, CSRD, Taxonomy, carbon footprint, SBTi and other standards from a single dataset. No duplication, no inconsistency.
Integration with existing systems: we connect to ERP, risk systems and other sources to automate collection and reduce manual effort.
Full traceability: every metric links to underlying evidence. That is required for independent verification and for responding to supervisors and investors.
3 critical success factors for EINF in the financial sector
1. Traceability and verification readiness
Every indicator must link to a source, methodology and owner. Without that chain, independent verification becomes costly and the risk of qualifications increases.
2. One ESG data base for multiple frameworks
The same governed dataset should feed the EINF, CSRD, EU Taxonomy and sustainable finance frameworks without rebuilding calculations each cycle.
3. Integration with risk and reporting systems
ESG data in the financial sector sits in risk systems, portfolios, HR and the supply chain. A useful solution connects to those sources instead of relying only on manual input at year-end.
Conclusion
The EINF is not just a document to file: it is the entry point to ESG data governance that enables compliance with the law, verification and the expectations of supervisors and investors.
Financial institutions that organise and centralise their non-financial information do not only meet the EINF with less effort; they improve dialogue with supervisors, prepare for CSRD and turn ESG data into input for strategy and risk.
If you do not measure and manage your environmental, social and governance impact with traceable, verifiable data, you fall behind in a market that demands transparency, comparability and evidence. Dcycle helps you move from the EINF as a chore to the EINF as the outcome of an ESG data system.
Ready to connect risk, ERP and ESG evidence for your next EINF cycle? Talk to our team about a financial-sector demo.
Talk to our teamFrequently asked questions (FAQs)
What should a financial institution prioritise when preparing the EINF?
Prioritise traceability and evidence. Financial institutions often already have policies and processes; the critical point is demonstrating them with data, documented methodologies and identified sources. Start with the indicators already reported to supervisors or internally and ensure each has a methodology, owner and evidence. Then close gaps in the pillars required by law (environment, social, human rights, anti-corruption, governance).
How does the EINF relate to CSRD in the financial sector?
The EINF is the current legal obligation in Spain under Law 11/2018. CSRD broadens and harmonises sustainability reporting in the EU with ESRS standards. Entities that already report under CSRD can reuse much of that information for the EINF; those not yet in CSRD scope must comply with the EINF minimum content. In both cases, a single ESG data base can feed the EINF and CSRD without duplicating work.
What do supervisors (CNMV, Banco de España) expect regarding the EINF?
The CNMV supervises the EINF of issuers with securities admitted to trading: it reviews formal compliance and, for a set of entities, carries out substantive reviews (quality, consistency, evidence). It has highlighted areas for improvement: clarity of the business model, materiality process, report scope, breakdowns of carbon footprint (including Scope 3) and climate targets. The Banco de España integrates sustainability into its prudential supervision framework. A well-documented, traceable EINF reduces the risk of observations.
Is independent verification mandatory for the EINF?
Yes for public-interest entities under Spanish audit regulation. Law 11/2018 requires verification by an independent assurance services provider. The verifier’s report accompanies the EINF and must be available to supervisors and investors. That makes evidence folders, methodology documentation and data lineage essential, not optional.
Can one dataset support EINF, CSRD and Taxonomy reporting?
Yes. A structured ESG data model with governed definitions and linked evidence can feed multiple frameworks from one collection effort. Platform solutions like Dcycle map the same underlying metrics to EINF disclosures, ESRS outputs and Taxonomy alignment without duplicate manual work.
Why is Dcycle a good fit for the EINF in the financial sector?
Because it is built for rigour, traceability and multi-framework use. We are not auditors or consultants; we are a platform that lets you centralise ESG data from risk systems, ERP and other sources, maintain full traceability to evidence, and generate reports compatible with the EINF, CSRD, Taxonomy, SBTi and other standards. We serve mid-sized and large entities that need the same level of control for ESG data as for financial and compliance reporting.