Spain’s Law 11/2018 introduced the EINF obligation, but not every company is required to report. The thresholds are clear, though edge cases and group structures can make determination tricky.
Mandatory reporting thresholds
Your company must file an EINF if it meets at least two of the following conditions for two consecutive years:
| Criterion | Threshold |
|---|---|
| Average employees | More than 250 |
| Total assets | More than €20 million |
| Net annual revenue | More than €40 million |
These thresholds apply to both individual companies and consolidated groups. It is important to note that the employee count is based on the annual average, not a single headcount date, so seasonal fluctuations can influence whether a company crosses the threshold.
Public-interest entities
Companies considered public-interest entities (listed companies, banks, insurance firms) with more than 500 employees must report regardless of the size thresholds above.
Group vs individual reporting
If your company belongs to a group, the parent company can file a consolidated EINF covering all subsidiaries. In this case, individual subsidiaries are exempt , but only if the consolidated report explicitly covers their operations.
When a parent company is based outside Spain, the Spanish subsidiary may still be required to file individually if the group does not produce a consolidated non-financial report meeting the requirements of Law 11/2018. Organizations with complex group structures should carefully evaluate which entity bears the reporting obligation.
Voluntary reporting
Companies below the thresholds can file voluntarily. This is increasingly common as clients, investors, and public tenders require ESG disclosure from suppliers of all sizes. Voluntary reporting also helps organizations build the internal processes and data infrastructure they will need if they grow into the mandatory thresholds , or when the CSRD extends its reach to additional companies in the coming years.
When does the obligation start?
The obligation applies for the financial year in which thresholds are met for the second consecutive year. If your company crossed the threshold in 2024 and 2025, you must file an EINF for fiscal year 2025.
Relationship with the CSRD
Companies already subject to the EINF should be aware that the CSRD is progressively replacing national non-financial reporting requirements across the EU. Spanish companies meeting CSRD thresholds will eventually transition from EINF to ESRS-based reporting. Understanding your current EINF obligation is the first step in preparing for this broader European framework.
How Dcycle helps
Not sure if you need to report? Dcycle’s onboarding assessment evaluates your company structure and determines your EINF obligation in minutes. If you do need to report, the platform guides you through every requirement , from data collection across your facilities to generating the final disclosure document ready for verification. Request a demo to get started.
