The complete guide to the EINF for the financial sector in 2026
Everything financial institutions need to know about the EINF: legal obligations, content requirements, verification, and how to turn ESG data into a strategic asset.
What the EINF is and why it matters for the financial sector
The 4 thematic pillars of the EINF and what they mean for the financial sector
How the process works in practice: deadlines and verification
5 common mistakes financial institutions make with the EINF
4-phase preparation plan for the EINF in the financial sector
4 critical factors when choosing a solution for the EINF in the financial sector
Frequently Asked Questions (FAQs)
The EINF (Non-Financial Information Statement) has become a 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 is a legal obligation that 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 sustainable governance impact of the entity, as well as the ESG risks and opportunities linked to the business model. The reality is clear: 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.
Meanwhile, those that integrate the EINF into their 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 CSRD, 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.
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.
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.
Law 11/2018 requires the EINF to describe, as a minimum: the business model and policies applied in non-financial areas, outcomes of those policies, main non-financial risks related to the undertaking's activity, and 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. The information must be consistent, traceable, and, where the entity is subject to verification, auditable.
Most financial entities already have ESG data in risk systems, ERP, and HR platforms. The challenge is turning that into auditable evidence for supervisors and verifiers.
Quick win: start by mapping the indicators you already report internally and define methodology, owner and source for each one.
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.
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.
The financial sector is subject to strict integrity and anti-money-laundering rules. The EINF must reflect policies, controls and results in:
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.
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.
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.
Entities that already prepare information under double materiality 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.
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.
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 that allows every number to be reconstructed.
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.
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.
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), 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.
A figure without methodology and source documentation does not exist for the verifier. EINF scoring improves when every indicator links to a documented calculation, a responsible owner, and traceable source data.
Rule: every claim should be traceable to a metric and a document.
Build an inventory by thematic pillar (environment, social, human rights, anti-corruption, governance):
Deliverable: Gap matrix: current state vs EINF and verification requirements.
Focus on what most affects the quality and verifiability of the report:
Deliverable: Minimum set of documentation and data covering all four pillars and auditable.
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.
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.
Level 1: dispersed data and manual last-minute collection.
Level 2: centralized ESG data with documented methodologies.
Level 3: audit-ready evidence, traceability, and multi-framework reuse.
The key question: Does the solution connect to the systems where data already lives (risk, ERP, HR, operations)?
ESG data in the financial sector sits in risk systems, portfolios, billing, human resources and the supply chain. A useful solution must integrate with those sources and not rely only on manual input.
What to look for: Connectors or APIs to risk and reporting systems, data validation and traceability to source.
The question: Can every indicator be traced back to a source, methodology and owner?
Law 11/2018 requires independent verification. Without traceability, verification is costly and the risk of qualifications increases.
What to look for: Indicator dictionary, methodology versioning, change history and evidence linked to each figure.
The question: Can the same data feed the EINF, double materiality CSRD, EU Taxonomy or other standards?
In the financial sector, a single source of truth reduces duplication and ensures consistency with supervisors and investors.
What to look for: Configurable outputs by framework, mapping to ESRS if CSRD applies, and ability to export or integrate with existing reporting systems.
The question: Does the solution meet the security and data handling standards required in the financial sector?
Supervised entities must ensure confidentiality, integrity and availability of information. An ESG platform must align with those requirements.
What to look for: Certifications (e.g. ISO 27001), contracts that address data processing, and access auditability.
Dcycle is the leading enterprise platform for ESG reporting and double materiality CSRD and EINF compliance, with ISO 27001 and TÜV certification (the only ESG platform with TÜV certification globally) 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.
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, ISO standards or other frameworks in minutes, from the same dataset.
1. 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.
2. 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.
3. Integration with existing systems — We connect to ERP, risk systems and other sources to automate collection and reduce manual effort.
4. Full traceability — Every metric links to underlying evidence. Required for independent verification and for responding to supervisors and investors.
5. Strategic, not just compliance — Centralising ESG data enables better decisions, faster reporting and more efficient compliance.
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).
The EINF is the current legal obligation in Spain (Law 11/2018). The CSRD broadens and harmonises sustainability reporting in the EU with the 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 and while keeping consistency.
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. 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.
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. With ISO 27001 and TÜV certification and recognised as Friends of EFRAG, we serve mid-sized and large companies and entities (from 250 employees) that need the same level of control for ESG data as for financial and compliance reporting.
Carbon footprint calculation analyzes all emissions generated throughout a product’s life cycle, including raw material extraction, production, transportation, usage, and disposal.
The most recognized methodologies are:
Digital tools like Dcycle simplify the process, providing accurate and actionable insights.
Some strategies require initial investment, but long-term benefits outweigh costs.
Investing in carbon reduction is not just an environmental action, it’s a smart business strategy.
.png)
