Who is required to have the 2026 accounts audited
Under art. 263.2 of the Spanish Companies Act (LSC), companies are exempt if, for two consecutive financial years, they meet at least two of the following criteria at the closing date of each year:
- Total assets not exceeding €2,850,000.
- Net turnover not exceeding €5,700,000.
- Average number of employees not exceeding 50.
In the first financial year after incorporation, conversion or merger, it is sufficient to meet two of the three criteria at the year-end (art. 263.3). In addition, size is not the only reason: the Regulation implementing the Spanish Audit Act (Royal Decree 2/2021) requires an audit for entities that, in a given financial year, receive public grants or aid of more than €600,000 (second additional provision) or enter into contracts with the public sector for more than €600,000, if that amount exceeds 50% of their turnover (third additional provision). If you manage EU funds, also review the final stretch of the Recovery Plan.
About the new thresholds. Bill 121/000075, amending company size criteria for financial reporting purposes, proposed raising the thresholds in art. 263.2 to €3,565,000 in total assets, €7,125,000 in turnover and 50 employees. It lapsed on 6 October 2026 with the dissolution of the Spanish Parliament, without having been passed, so you should plan using the thresholds in force.
Deadlines and rules for the appointment
Art. 264.1 LSC provides that the auditor shall be appointed by the general meeting “before the end of the financial year to be audited”, for an initial period of between three and nine years from the beginning of the first financial year audited. Once that period has ended, the Spanish Audit Act allows it to be extended for successive periods of up to three years (art. 22.1 LAC).
If the general meeting fails to appoint the auditor in time when it is required to do so, or the appointed auditor does not accept or is unable to act, the directors or any shareholder may ask the Companies Register (Registro Mercantil) registrar to appoint one (art. 265.1 LSC). Companies that are not required to be audited may also end up being audited: shareholders holding at least 5% of the share capital may request an auditor from the registrar within three months of the year-end (art. 265.2 LSC).
For entities required to be audited because they receive grants or contract with the public sector, the fourth additional provision of Royal Decree 2/2021 states that the appointment “shall, in any event, be made before the end of the financial year to be audited”. It is advisable to act early.
Indicative timetable for a financial year ending on 31/12/2026
| When | Action |
|---|---|
| Before 31/12/2026 | General meeting resolution appointing the auditor and engagement letter |
| October-December 2026 | Planning meeting and, where appropriate, preliminary review |
| 31/12/2026 | Physical stock count attended by the auditor |
| January-February 2027 | Sending and follow-up of confirmations from banks, customers, suppliers and lawyers |
| By 31/03/2027 | Preparation of the annual accounts by the directors (art. 253.1 LSC) |
| By 30/06/2027 | Ordinary general meeting approving the accounts (art. 164.1 LSC) |
| Month following approval | Filing with the Companies Register together with the auditor’s report (art. 279.1 LSC) |
On the last two stages, see our guides on the ordinary general meeting and approval of the accounts and on filing the accounts and the closure of the registry sheet.
What to plan with your auditor
- Stock count. If inventories are material, the auditor must attend the count unless this is impracticable (NIA-ES 501). Set the date, the instructions and the cut-off of transactions.
- External confirmations. Prepare the lists of banks, customers, suppliers and legal advisers in advance (NIA-ES 505).
- Timetable and people responsible. Agree delivery dates for the trial balance, reconciliations, the fixed asset register and documentation on significant transactions.
- Going concern. Prepare cash flow forecasts with explicit assumptions. The ICAC has a new standard on this matter out for public consultation; we explain it in our article on revised NIA-ES 570.
Frequently asked questions
Can I appoint the auditor in 2027 to audit 2026?
The general meeting must do so before the end of the financial year to be audited. If it does not, the directors or any shareholder may ask the Companies Register registrar to make the appointment.
How long does the appointment last?
The initial period is three to nine years. It can then be extended for periods of up to three years.
Will the new thresholds already affect me in 2026?
No. The bill lapsed on 6 October 2026 with the dissolution of Parliament. The thresholds in art. 263.2 LSC apply to the 2026 year-end.
Official sources
- Spanish Companies Act, consolidated text (BOE)
- Law 22/2015, Spanish Audit Act, consolidated text (BOE)
- Royal Decree 2/2021, Regulation implementing the Spanish Audit Act (BOE)
- BOCG, Congress, Series A, no. 75-1: Bill 121/000075
- Spanish Institute of Accounting and Auditing (ICAC)
If you need to appoint an auditor for the 2026 financial year or want to organise the year-end in good time, our audit of annual accounts team can help. Contact us before the financial year ends.
If what you need is the full timetable of deadlines (preparation, general meeting, filing and appointment), see our guide to the annual accounts and auditor appointment calendar.
Article prepared by Controlaudit’s technical team. Published on 15 September 2026. Reviewed on 8 October 2026. This content is for information purposes only and is not a substitute for professional advice on your specific case.