Legislative status as at 08/10/2026: Directive 2026/470 is in force in the EU but has not been transposed in Spain. The Bill on corporate sustainability reporting (121/000038) was never passed: following Royal Decree 806/2026 of 5 October dissolving the Cortes Generales and calling elections (BOE of 06/10/2026), the Congress record shows it as «Concluido – (Caducado)» (concluded, lapsed) from 06/10/2026. Transposition will require a new legislative initiative in the new parliamentary term, with no foreseeable date, and the EU deadline expires on 19/03/2027. We will update this article when the situation changes.
Will your company have to prepare a sustainability report under the EU Corporate Sustainability Reporting Directive (CSRD)? After Omnibus I, for the vast majority the answer is no. We explain what has changed, from when, and what remains in force in Spain. If your company is not in scope but your customers are asking for environmental or social data, you may also be interested in our guide on the sustainability data a customer may ask you for and the voluntary VSME standard.
What has changed with Omnibus I
Directive (EU) 2026/470 of the European Parliament and of the Council of 24/02/2026 was published in the Official Journal of the European Union on 26/02/2026. It amends, among others, Accounting Directive 2013/34/EU, Directive 2022/2464 (CSRD) and Directive 2024/1760 on corporate sustainability due diligence (CSDDD). According to the Spanish Institute of Accounting and Auditing (ICAC), it entered into force on 18/03/2026.
Its main effect is a drastic reduction in the number of companies in scope. The original CSRD covered all large undertakings under the size criteria of the Accounting Directive and listed SMEs. Omnibus I replaces that scope with two thresholds that must both be met and removes listed SMEs.
Before that, Directive (EU) 2025/794 of 14/04/2025, known as stop-the-clock, had already been adopted. According to the ICAC, it postponed application by two years for large undertakings that were not yet reporting (the so-called second wave) and for listed SMEs.
New thresholds: €450m and 1,000 employees
The new art. 19a of Directive 2013/34/EU requires sustainability information to be included in the management report by undertakings that, on their balance sheet date, have generated net turnover above €450,000,000 and exceed an average of 1,000 employees during the financial year. The same rule applies to groups on a consolidated basis (art. 29a). The balance sheet total criterion disappears.
The conjunction is worth stressing: exceeding just one of the two thresholds is not enough. A company with 1,200 employees and net turnover of €300,000,000 is out of scope, as is another with €600,000,000 and 800 employees.
| Aspect | Before Omnibus I | After Omnibus I | Position in Spain as at 08/10/2026 |
|---|---|---|---|
| Who reports | Large undertakings under the Accounting Directive and listed SMEs | Net turnover above €450,000,000 and more than 1,000 employees | CSRD not transposed; the EINF under Law 11/2018 applies |
| Balance sheet criterion | Yes, as one of the size criteria | Removed | The EINF still uses total assets and turnover |
| Listed SMEs | Included (application postponed) | Excluded | No specific obligation |
| First financial year of the new scope | — | Financial years beginning on or after 01/01/2027 | Awaiting a Spanish law |
| Transposition | — | By 19/03/2027 (reporting provisions) | Pending: Bill 121/000038 lapsed on 06/10/2026 without being passed |
Incorrect figures in circulation
Some industry publications still quote thresholds of 500 employees or turnover of €250,000,000, which do not match the adopted text. The figures in the Official Journal, also reported by the ICAC, are €450,000,000 and 1,000 employees.
Timetable: entry into force, transposition and first financial years
- 26/02/2026: publication in the Official Journal of the EU.
- 18/03/2026: entry into force, twenty days after publication.
- 19/03/2027: deadline for Member States to transpose the sustainability reporting provisions.
- Financial years beginning on or after 01/01/2027: application of the new scope.
- 26/07/2028 and 26/07/2029: transposition and application of the amended due diligence rules (CSDDD).
What happens to the first wave and to listed SMEs
The first-wave regime (large public interest entities that were already reporting) is maintained only for financial years beginning between 01/01/2024 and 31/12/2026; from 2027, those that do not exceed the new thresholds fall out of scope. In addition, the directive allows Member States to exempt those that do not exceed the new thresholds for financial years beginning between 01/01/2025 and 31/12/2026. Whether Spain uses that option will depend on the transposing law, if and when one is passed.
Listed SMEs drop out of the mandatory scope and, like other SMEs, are left with the voluntary route.
In Spain: the EINF remains in force and the bill has lapsed
Spain has not transposed the CSRD. The Bill on corporate sustainability reporting, which amended the Commercial Code, the Spanish Companies Act (LSC) and the Spanish Audit Act (LAC), was introduced on 31/10/2024 and was being processed with full legislative powers in the Justice Committee, where it remained at the amendment stage with successive extensions of the deadline. With the dissolution of the Cortes Generales by Royal Decree 806/2026 (BOE of 06/10/2026), the Congress record shows it as lapsed from 06/10/2026, without having been passed. Its text, moreover, pre-dated Omnibus I.
Transposition of the CSRD and of Directive 2026/470 will require a new legislative initiative in the new parliamentary term, whose content and timing are not known today. The deadline for transposing Directive 2026/470 as regards sustainability reporting remains 19/03/2027.
In the meantime, the EINF under Law 11/2018 remains in force. Under that regime, it must be included in the management report by companies with more than 250 employees that either are public interest entities (except those classed as small and medium-sized under Directive 2013/34/EU) or, for two consecutive financial years, meet at the reporting date at least one of the following conditions: total assets above €20,000,000 or net turnover above €40,000,000. The EINF information must be verified by an independent assurance services provider.
In addition, the statutory auditor checks in the auditor’s report that the EINF has been included in the management report or in a separate report. Some companies currently required to prepare the EINF could fall outside the EU obligation once Omnibus I is transposed; until there is a law, they must continue to comply.
Due diligence (CSDDD): new thresholds
Omnibus I also narrows the scope of the due diligence directive: in the EU it will apply to companies with an average of more than 5,000 employees and net worldwide turnover above €1,500,000,000. It will apply from 26/07/2029.
What about companies in the province of Alicante?
Very few companies headquartered in the province exceed both €450,000,000 of turnover and 1,000 employees. The real impact will come in two ways: the EINF for companies with more than 250 employees while there is no Spanish law, and data requests from customers, banks and in-scope groups along the value chain, something common in the footwear supply industry of Elche and Elda or among suppliers to large retailers. For most of the companies we serve as auditors in Alicante, the question is no longer «am I in scope?» but «how do I organise the data I am being asked for?».
Remember too that the bill on audit thresholds (121/000075), which referred to the sustainability bill for the definition of large undertaking and micro-undertaking, has also lapsed without being passed. We explain this in our article on the bill on new audit thresholds.
Frequently asked questions
Will my company, with 300 employees, have to submit a CSRD report?
Under Omnibus I, no, unless it also exceeds €450,000,000 of net turnover and 1,000 employees. The EINF is a different matter: if it has more than 250 employees and exceeds €20,000,000 of total assets or €40,000,000 of turnover for two consecutive financial years, it is still required to prepare one in Spain today.
From which financial year do the new thresholds apply?
Under the directive, from financial years beginning on or after 01/01/2027, once transposed. In Spain it will depend on the law that is passed and its transitional arrangements; the bill that was going through Parliament lapsed on 06/10/2026, so a new legislative initiative will be needed.
Can I stop preparing the 2026 EINF because Omnibus is already in force?
No. The directive requires transposition and, as at 08/10/2026, there is no Spanish law incorporating it: the applicable rule remains Law 11/2018. Seek advice on your case before taking any decision.
Official sources
- Directive (EU) 2026/470, text published in the Official Journal of the EU (copy on boe.es)
- Directive (EU) 2026/470 on EUR-Lex
- Directive (EU) 2025/794 (stop-the-clock), Official Journal of the EU (copy on boe.es)
- ICAC: sustainability reporting
- Law 11/2018 on non-financial information and diversity (BOE)
- Congress of Deputies: Bill 121/000038, legislative record
- Royal Decree 806/2026 of 5 October dissolving the Cortes Generales and calling elections (BOE-A-2026-20742)
If you need to know whether your company is required to prepare the EINF or how to prepare for transposition, our sustainability reporting assurance team, led by partner José Antonio Valiente Velasco (ROAC 12609), an economist specialising in sustainability reports, can analyse your case. If we also audit your accounts, we coordinate this review with the audit of annual accounts. Contact us and we will get back to you.
Article prepared by Controlaudit’s technical team. Updated 08/10/2026. This content is for information only and does not replace professional advice on your specific case.