The EINF (Estado de Información No Financiera) is Spain’s mandatory non-financial reporting framework, established through Law 11/2018 as a transposition of the EU Non-Financial Reporting Directive (NFRD). It requires qualifying companies to disclose information on environmental, social, human rights, anti-corruption, and diversity matters alongside their annual financial reporting.
For companies operating in Spain, the EINF is not optional , it carries legal obligations, audit requirements, and board-level accountability. This comprehensive guide covers everything you need to know about the EINF: what it is, who must comply, what it requires, and how to prepare.
What does EINF stand for?
EINF stands for Estado de Información No Financiera, which translates to “Non-Financial Information Statement.” The term refers both to the legal obligation itself and to the document that companies produce to meet it.
The EINF was introduced by Spain’s Law 11/2018 of December 28, which modified the Commercial Code, the consolidated text of the Capital Companies Law, and the Audit Law. This law transposed the EU’s Directive 2014/95/EU (the Non-Financial Reporting Directive, or NFRD) into Spanish national legislation.
Before Law 11/2018, Spain had limited non-financial reporting obligations. The EINF significantly expanded the scope, detail, and enforcement of sustainability disclosures for Spanish companies.
Who must file an EINF?
The obligation applies to companies and consolidated groups that meet specific size thresholds. Understanding whether your company falls within scope is the first step.
Mandatory thresholds
Your company must file an EINF if it meets at least two of the following conditions for two consecutive financial years:
| Criterion | Threshold |
|---|---|
| Average number of employees | More than 250 |
| Total assets | More than €20 million |
| Net annual revenue | More than €40 million |
Public-interest entities
Companies classified as public-interest entities (listed companies, credit institutions, insurance companies) with more than 500 employees are subject to the EINF obligation regardless of the asset and revenue thresholds.
Group vs individual reporting
If your company belongs to a corporate group, the parent company can file a consolidated EINF that covers all subsidiaries. In this case, individual subsidiaries are exempt from filing separately , but only if the consolidated report explicitly covers their operations and data.
This is an important nuance: many companies assume they’re exempt because their parent files a group report, but if the group EINF doesn’t specifically include your subsidiary’s data, you may still need to file individually.
Voluntary reporting
Companies below the mandatory thresholds can file an EINF voluntarily. This is increasingly common, driven by:
- Client requirements , Large companies subject to EINF often ask suppliers for ESG data
- Public tenders , Government procurement increasingly evaluates sustainability criteria
- Investor expectations , ESG-conscious investors look for transparency regardless of legal obligation
- Competitive advantage , Early voluntary reporters are better positioned when thresholds are eventually met
When does the obligation start?
The obligation applies for the financial year in which the thresholds are met for the second consecutive year. If your company crossed two of the three thresholds in both 2024 and 2025, you must file an EINF for fiscal year 2025.
Conversely, if you fall below the thresholds for two consecutive years, the obligation ceases , but many companies choose to continue reporting voluntarily for stakeholder transparency.
What does the EINF cover?
The EINF requires structured disclosure across five pillars. Each pillar involves both quantitative data (metrics, KPIs) and qualitative descriptions (policies, risks, due diligence measures).
1. Environmental matters
This is typically the most data-intensive pillar. Required disclosures include:
- Greenhouse gas emissions , Scope 1 (direct) and Scope 2 (indirect from energy), and where material, Scope 3 (value chain)
- Energy consumption , Total consumption in MWh or GJ, breakdown by source (electricity, gas, diesel, renewables), energy efficiency measures
- Water consumption , Total water use, sources, wastewater discharge
- Pollution , Air, water, and soil pollution prevention and mitigation measures
- Circular economy , Waste generation by type (hazardous/non-hazardous), recycling rates, waste prevention initiatives
- Biodiversity , Impact on protected areas, biodiversity conservation measures
- Climate change , Risks and adaptation measures, carbon reduction targets
Companies should also report the methodology used for calculations (e.g., GHG Protocol for emissions) and provide year-over-year comparisons where data allows.
2. Social and employee matters
The social pillar covers the company’s relationship with its workforce:
- Employment , Total headcount by gender, age, country; contract types (permanent, temporary, part-time); employee turnover; new hires
- Work organisation , Working hours, flexible work arrangements, disconnection policies, work-life balance measures
- Health and safety , Occupational accident frequency and severity rates, work-related illness, prevention measures
- Social dialogue , Collective bargaining coverage, employee representation, consultation procedures
- Training , Total training hours, average hours per employee, professional development programs
- Accessibility , Measures for persons with disabilities, universal accessibility initiatives, integration programs
- Equal pay , Remuneration by gender and professional category, pay gap analysis
3. Human rights
The human rights pillar focuses on due diligence and risk prevention:
- Due diligence procedures , Human rights risk assessment processes, both internally and across the value chain
- Risk prevention , Measures to prevent and mitigate human rights violations
- Complaints mechanisms , Grievance channels, whistleblowing procedures, cases reported and resolved
- Supply chain oversight , Human rights considerations in supplier selection and monitoring
4. Anti-corruption and bribery
This pillar covers the company’s integrity framework:
- Policies , Anti-corruption and anti-bribery policies, code of conduct
- Compliance programs , Training, risk assessments, internal controls
- Whistleblowing , Channels for reporting irregularities, protections for whistleblowers
- Outcomes , Confirmed incidents of corruption, legal proceedings, sanctions imposed
- Political contributions , Donations to political parties, lobbying activities (where applicable)
5. Board diversity
The diversity pillar examines the composition and inclusivity of governance:
- Board composition , Gender, age range, professional background, nationality of board members
- Diversity policy , Objectives for board diversity, implementation measures, progress
- Pay gap , Remuneration differences by gender and job category
- Inclusion measures , Policies for promoting diversity beyond the board
How is the EINF verified?
Unlike some voluntary sustainability reports, the EINF must undergo mandatory independent verification by an authorised assurance provider.
Verification scope
The verifier checks:
- Completeness , Are all five pillar areas covered? Are mandatory data points included?
- Accuracy , Do reported figures match source documentation? Are methodologies applied correctly?
- Consistency , Do numbers align internally and with the company’s financial statements?
- Compliance , Does the report meet the requirements of Law 11/2018?
Assurance level
The current requirement is limited assurance, which provides a moderate level of confidence that the information is free from material misstatement. This is less rigorous than “reasonable assurance” (which is closer to a financial audit), but still requires substantial evidence and documentation.
Practical implications
For the verification to go smoothly, companies need:
- Evidence trails , Every data point should be traceable to a source document (invoice, meter reading, HR record)
- Calculation documentation , Emission factors, allocation rules, and conversion methodologies must be documented
- Approval chains , Clear records of who provided data, who validated it, and who approved it
How does the EINF relate to CSRD?
The EINF and the CSRD (Corporate Sustainability Reporting Directive) are closely related but differ significantly in scope and rigour.
Key differences
| Aspect | EINF | CSRD |
|---|---|---|
| Legal basis | Spain’s Law 11/2018 | EU Directive 2022/2464 |
| Scope | ~1,600 companies in Spain | ~50,000 across the EU |
| Standards | No mandatory standard | Mandatory ESRS |
| Format | Any format (part of management report) | XBRL-tagged digital format |
| Materiality | Single materiality | Double materiality |
| Data points | ~120 general disclosures | 800+ specific data points |
Transition timeline
As CSRD comes into effect in Spain, companies currently filing an EINF will need to transition to the more detailed ESRS (European Sustainability Reporting Standards):
- 2025 , Large listed companies (>500 employees) report under CSRD for FY2024
- 2026 , Other large companies meeting 2 of 3 thresholds report for FY2025
- 2027 , Listed SMEs can start reporting (mandatory from 2028)
The advantage of starting with EINF
If your company already files an EINF, you have a significant head start on CSRD preparation. The data you collect for environmental emissions, employment metrics, governance disclosures, and more feeds directly into CSRD reporting. The transition involves expanding your data collection (more granular data points), adopting ESRS structure, and implementing double materiality assessment , but the foundation is already built.
How to prepare your EINF report
Preparing an EINF involves several phases, typically spanning 2–4 months depending on company size and data readiness.
Phase 1: Scope and planning (weeks 1–2)
- Determine your reporting boundary (which entities, facilities, operations are included)
- Identify data owners for each pillar (HR, Operations, Legal, Finance)
- Review previous reports (if any) for baseline data
Phase 2: Data collection (weeks 3–6)
- Gather source documents: energy invoices, HR exports, compliance reports, board minutes
- Calculate derived metrics: carbon footprint, pay gap analysis, accident rates
- Validate data for completeness, accuracy, and internal consistency
Phase 3: Drafting (weeks 7–8)
- Structure the report across the five pillars
- Include both quantitative metrics and qualitative descriptions of policies and risks
- Maintain a clear evidence trail linking every claim to source data
Phase 4: Review and verification (weeks 9–12)
- Internal review by management and relevant department heads
- External verification by an authorised assurance provider
- Address any findings or recommendations before final approval
Phase 5: Approval and filing
- Board of directors approves the EINF
- File alongside annual financial statements as part of the management report
- Make available to shareholders and, where required, publicly accessible
Common mistakes to avoid
Based on our experience helping hundreds of companies with their EINF, these are the most common pitfalls:
- Starting too late , Data collection takes longer than expected. Start at least 3 months before your filing deadline.
- Missing evidence , Auditors need source documents for every data point. Retroactive evidence gathering is painful and error-prone.
- Inconsistent scope , Ensure all entities in your reporting boundary are consistently covered across all five pillars.
- Copy-paste from policies , The EINF requires actual outcomes and metrics, not just descriptions of policies. “We have a diversity policy” is not enough , you need the numbers.
- Ignoring Scope 3 , While not always mandatory, Scope 3 emissions (business travel, commuting, supply chain) are increasingly expected and demonstrate thorough reporting.
- No year-over-year comparison , Regulators and auditors expect trend data. If this is your first year, state that clearly and plan to include comparisons from year two onwards.
How Dcycle helps with EINF compliance
Dcycle is designed to make EINF reporting faster, more accurate, and less dependent on external consultants.
Automated data collection
Connect your ERP, upload invoices, or import spreadsheets. Dcycle’s AI reads, classifies, and maps data to EINF requirements automatically , no manual data entry.
Pre-mapped requirements
Every EINF disclosure requirement across all five pillars is pre-configured in the platform. You can see at a glance which data points are complete, which are pending, and who is responsible.
Built-in audit trail
Every data point links to its source document, calculation methodology, and approval chain. When your verifier asks for evidence, you provide it in one click.
Multi-framework data reuse
Data collected for your EINF automatically feeds other projects , carbon footprint, CSRD, EcoVadis, ISO 14064. Enter it once, use it everywhere.
Expert advisory
Dcycle combines technology with hands-on guidance. Our sustainability experts help you scope your obligation, plan your data collection, and prepare for verification , no generic templates, no guesswork.
Ready to simplify your EINF reporting? Talk to our team and see how Dcycle can help you go from scattered data to audit-ready reports in weeks, not months.
