If your company files an EINF today, you already have the data, owners and verification habits that the CSRD builds on. But EINF vs CSRD is not a like-for-like comparison: the two frameworks differ in who they cover, which standards they use and how materiality is assessed. And since the EU approved the Omnibus I simplification package in 2026, the CSRD side has changed substantially.
This guide compares both frameworks as they stand today, explains what Omnibus I changed, and sets out what to do depending on where your company sits. For the EINF basics, see our guide on what the EINF is.
Key differences at a glance
| Aspect | EINF (Law 11/2018) | CSRD (Directive 2022/2464, as amended by Omnibus I) |
|---|---|---|
| Legal basis | Spanish law transposing the NFRD (Directive 2014/95/EU) | EU directive, amended by Directive (EU) 2026/470; must be transposed into Spanish law |
| Who must report | Companies with more than 250 employees that are also public-interest entities or, for two consecutive years, exceed €20M in assets or €40M in revenue | Companies with more than 1,000 employees and more than €450M in net turnover |
| Approximate scope | Around 1,600 companies in Spain | Around 5,000 companies across the EU after Omnibus I |
| Standards | No mandatory standard (GRI commonly used) | Mandatory ESRS, simplified from 1,073 to 320 data points |
| Materiality | Single materiality | Double materiality (impact and financial) |
| Assurance | Limited assurance by an independent provider | Limited assurance; the planned move to reasonable assurance was dropped |
| Format | Part of the management report, filed with the annual accounts | Part of the management report, in electronic format; digital tagging (XBRL) is not mandatory until its standards are adopted |
The biggest change after Omnibus I is scope. The CSRD now applies only to companies that exceed both thresholds, which removes roughly 90% of the companies originally expected to report. Many Spanish companies that file an EINF today fall well below the 1,000-employee and €450M marks. Our analysis of the Omnibus I approval covers the new thresholds in detail.
What stays the same
Both frameworks require disclosure on environmental, social and governance matters, and both are verified by an independent provider at a limited level of assurance. If you have been collecting data for your EINF, much of it carries over directly:
- Environmental metrics: energy consumption, Scope 1 and 2 emissions, water, waste.
- Workforce data: headcount by gender, age and contract type, turnover, training, health and safety.
- Governance information: anti-corruption policies, whistleblowing channels, board composition.
The evidence practices that make an EINF verification smooth (source documents, documented methodologies, approval trails) are exactly what a CSRD assurance provider will ask for. Our guide on EINF audit preparation explains how to build them.
What changes with the CSRD
Even with the Omnibus I simplification, companies in scope will need to add four things to an EINF-style process:
- Double materiality assessment: you evaluate both your impact on people and the environment and how sustainability issues affect your financial position. Under the EINF, single materiality is the norm. See our double materiality guide for the method.
- ESRS structure: disclosures follow the European Sustainability Reporting Standards rather than a freely chosen framework. The simplified ESRS have 320 data points, and sector-specific standards are no longer mandatory.
- Electronic format: the management report is filed in electronic format. Digital tagging (XBRL) is not mandatory until the EU adopts its standards, but it pays to define your indicators consistently from the start.
- Value chain data: more attention to impacts across the supply chain, especially Scope 3 emissions. Omnibus I also limits what CSRD reporters can request from smaller suppliers, which changes how you plan data requests.
Timeline and the situation in Spain
Omnibus I was published as Directive (EU) 2026/470 on 26 February 2026 and entered into force on 18 March 2026. Member States have until 19 March 2027 to transpose it, and the new CSRD scope applies to financial years starting on or after 1 January 2027, so the first reports under the new scope arrive in 2028.
Spain has not yet transposed the CSRD into national law. The transposition bill, in Parliament since November 2024, lapsed on 6 October 2026 when the Cortes were dissolved. Until there is a new law, Law 11/2018 remains in force: companies that meet the EINF thresholds keep filing their EINF. How the EINF and the CSRD will fit together once Spain transposes depends on that law, so avoid assumptions until it is published.
Spanish companies are not in a regulatory vacuum in the meantime. Royal Decree 214/2025 makes calculating the organisational carbon footprint mandatory for companies subject to Law 11/2018, with first publication due in 2026 using FY2025 data and a five-year reduction plan.
What to do now
Your next steps depend on which group you are in:
- Above both CSRD thresholds: keep filing your EINF while the law is in force, and use 2026 to run a double materiality assessment, map your EINF indicators to the simplified ESRS and close the gaps before FY2027.
- Subject to the EINF but below the CSRD thresholds: your EINF obligation continues under Law 11/2018, and so does RD 214/2025. Do not dismantle your data processes: banks, investors and large clients will keep requesting ESG data, and the voluntary standard for smaller undertakings gives you a lighter reference.
- Reporting voluntarily: an EINF-style report remains a credible way to answer client and tender questionnaires.
Transition checklist
- Confirm your position against both CSRD thresholds for the relevant financial years.
- List your current EINF indicators and map each one to the corresponding ESRS disclosure.
- Identify gaps: double materiality, value chain data, transition-related disclosures.
- Keep one source of truth for data and evidence, so the same figure feeds both reports.
- Follow Spain’s new transposition bill and adjust your plan when the final text is published.
How Dcycle helps
Dcycle supports EINF, GRI and CSRD projects in the same platform. Data collected for your EINF feeds your CSRD project without re-entering it, and the platform maps existing indicators to ESRS requirements so you can see which gaps remain. With multi-framework reporting, the same evidence-backed figure serves every report. Request a demo to see the mapping with your own data.
Frequently asked questions (FAQs)
Does the CSRD replace the EINF in Spain?
Not yet. Spain has not transposed the CSRD, so Law 11/2018 and the EINF obligation remain in force. How both regimes fit together will depend on the Spanish transposition law.
Which companies are in scope of the CSRD after Omnibus I?
Companies with more than 1,000 employees and more than €450 million in net turnover. Both conditions must be met, which leaves around 5,000 companies in scope across the EU.
Can I reuse my EINF data for the CSRD?
Yes. Environmental metrics, workforce data and governance information collected for the EINF form a solid base. You will need to add a double materiality assessment and follow the ESRS structure.
Is the assurance level different between the EINF and the CSRD?
Both currently require limited assurance by an independent provider. Omnibus I dropped the planned transition to reasonable assurance under the CSRD.
