What has been published
Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026 amends Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting and due diligence requirements. It was published in the Official Journal (L series) on 26/02/2026 and enters into force twenty days after publication, that is, on 18/03/2026.
Who will be required to report
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. Art. 29a applies the same rule to groups, on a consolidated basis. The balance sheet total criterion disappears.
| Aspect | What Directive (EU) 2026/470 provides |
|---|---|
| CSRD thresholds | An average of more than 1,000 employees and net turnover above €450,000,000 (both at once) |
| Application of the new scope | Financial years beginning on or after 01/01/2027 |
| «First wave» companies | Their obligation is limited to financial years beginning between 01/01/2024 and 31/12/2026; Member States may exempt those that do not exceed the new thresholds for financial years beginning in 2025 and 2026 |
| Listed SMEs | Outside the mandatory scope |
| Value chain | Companies with an average of up to 1,000 employees («protected undertakings») may refuse to provide information beyond the voluntary standards |
| Transposition (CSRD) | By 19/03/2027 |
| Due diligence (CSDDD) | More than 5,000 employees and net worldwide turnover above €1,500,000,000; transposition by 26/07/2028 and application from 26/07/2029 |
What it means for Spanish companies
A directive does not apply directly to companies: it requires a national transposing law. And in Spain the original CSRD has not yet been transposed. The Bill on corporate sustainability reporting (file 121/000038), which would have amended the Commercial Code, the Spanish Companies Act and the Spanish Audit Act, was then going through the Congress of Deputies; it lapsed on 06/10/2026 with the dissolution of the Cortes Generales (see the update at the end). Its text was introduced in October 2024, before Omnibus I, so the new transposing law will now have to be adjusted to the new thresholds.
Until the new transposing law is passed, Spain continues to apply the non-financial information statement (EINF) under Law 11/2018, with verification by an independent provider. Companies currently required to prepare the EINF must continue to do so for their 2025 accounts, regardless of whether they may fall outside the CSRD in the future.
SMEs and data requests from their customers
For the business community of Alicante and the Valencian Community, made up mostly of SMEs, the message is clear: the legal obligation to report on sustainability is reserved for very large companies. That does not mean the issue goes away:
- Banks and large customers will continue to ask their suppliers for sustainability data; the voluntary standards for SMEs will be the reference for responding.
- Companies that already report should check whether they remain within the new scope and what Spain will decide on the optional exemption for the 2025 and 2026 financial years.
If your company is required to prepare the EINF or wishes to provide reliable sustainability information to its customers, our sustainability reporting assurance service can help. And if you need to build these changes into your planning, you can rely on our corporate strategy team. We work as auditors in Alicante, registered with the ROAC under no. S1604.
Frequently asked questions
Do I no longer have to submit the non-financial information statement?
If your company is required to prepare the EINF under Law 11/2018, it must continue to submit it until a Spanish transposing law changes the regime.
When will the CSRD stop applying to companies that do not exceed the new thresholds?
The new scope applies to financial years beginning on or after 01/01/2027. For financial years beginning in 2025 and 2026, the directive allows Member States to exempt first-wave companies that do not exceed the new thresholds. It remains to be seen what the Spanish legislator decides.
Does it affect my SME if it supplies a large company?
It will not be required to report. Once the directive has been transposed, it may refuse to provide information beyond the voluntary standards if it does not exceed 1,000 employees.
Official sources
- Directive (EU) 2026/470 of 24 February 2026 (EUR-Lex, OJ L of 26/02/2026)
- ICAC: sustainability reporting
- Congress of Deputies: Bill on corporate sustainability reporting (121/000038)
- Law 11/2018 of 28 December on non-financial information and diversity (BOE)
If you would like to know whether your company is or will be required to report on sustainability, contact our team and we will analyse your situation.
Article prepared by Controlaudit’s technical team. Published 27/02/2026. Reviewed 08/10/2026. Information only; it does not replace professional advice on your specific case.