Home  /  Services  /  Sustainability and non-financial information

Comply 01

Preparation and verification of non-financial information statements and sustainability reports

We help you prepare your non-financial information statement or sustainability report, and we verify it as an independent assurance provider, with the rigour of an audit firm registered with the ROAC.

AreaComply
CoverageThroughout Spain
FrameworkLaw 11/2018 · CSRD
FirmROAC no. S1604
In briefThe non-financial information statement (EINF) is mandatory in Spain for companies with more than 250 employees that are public-interest entities or that exceed €20,000,000 in total assets or €40,000,000 in turnover, and it must be verified by an independent assurance provider (art. 49 of the Spanish Commercial Code and art. 262.5 of the Spanish Companies Act (LSC), as worded by Law 11/2018). The EU Corporate Sustainability Reporting Directive (CSRD), scaled back by the Omnibus I Directive (more than 1,000 employees and more than €450,000,000), has not yet been transposed in Spain, so the EINF still applies today. For SMEs receiving requests for ESG data, the voluntary VSME standard is the recommended route.

Reviewed by Controlaudit's audit team · Firm registered with the ROAC under no. S1604 · Updated 13 October 2026

What it involves

The non-financial information statement (EINF) is the part of the management report, or a separate report forming part of it, in which the company explains its business model and its policies, risks and indicators on environmental and social matters, employee matters, respect for human rights and the fight against corruption and bribery, together with information about the company (commitments to sustainable development, suppliers, consumers and tax information). It is governed by art. 49.6 of the Spanish Commercial Code (Código de Comercio), to which art. 262.5 of the Spanish Companies Act refers for individual accounts.

The law requires this information to be verified by an independent assurance services provider. This is a different engagement from the audit of accounts: the statutory auditor only checks that the EINF has been included in the management report or that the latter refers to the separate report (art. 5.1.f) of the Spanish Audit Act, Law 22/2015). Verification, by contrast, reviews the content and its supporting evidence.

At Controlaudit we work on two fronts. We support the company in preparing the EINF or its sustainability report (materiality analysis, choice of framework, indicators and drafting) and, where we have not prepared it ourselves, we provide the independent assurance service. We never do both on the same information, because that would mean reviewing our own work.

Who it is for

  • Companies with more than 250 employees that exceed €20,000,000 in total assets or €40,000,000 in turnover for two consecutive years and must include and verify the EINF.
  • Groups that prepare consolidated accounts and must present a consolidated EINF (art. 49.5 of the Spanish Commercial Code).
  • Public-interest entities with more than 250 employees that do not qualify as small or medium-sized enterprises.
  • Companies that want to anticipate how the transposition of the CSRD following the Omnibus I Directive will affect them.
  • SMEs that receive ESG questionnaires from customers, financial institutions or buyers and want to respond with a well-organised VSME report.

Who is required to prepare the EINF today. Art. 262.5 LSC and art. 49.5 of the Spanish Commercial Code, as worded by Law 11/2018, initially set the threshold at more than 500 employees. Its transitional provision, section 3, extended the obligation, three years after its entry into force (30/12/2018), to companies with more than 250 employees that either are public-interest entities (except those qualifying as small and medium-sized enterprises under Directive 2013/34/EU) or, for two consecutive years, meet at least one of the following conditions at each year-end: total assets exceeding €20,000,000 or net turnover exceeding €40,000,000. The obligation ceases if the requirements are no longer met for two consecutive years.

Content, approval and verification. Art. 49.6 of the Spanish Commercial Code sets out the minimum content and requires the statement to be based on national, EU or international frameworks (stating which), to be presented as a separate item on the agenda of the general meeting and to be verified by an independent provider. Art. 49.7 allows a separate report subject to the same approval and filing regime.

CSRD and the Omnibus I Directive. Directive (EU) 2026/470 of 24/02/2026 limits mandatory sustainability reporting to companies with net turnover exceeding €450,000,000 and more than 1,000 employees on average, for financial years beginning on or after 01/01/2027. The transposition deadline for this part is 19/03/2027. In Spain, the Bill on corporate sustainability reporting (121/000038) lapsed on 06/10/2026 when the Spanish Parliament (Cortes Generales) was dissolved (Royal Decree 806/2026). Until a new law is passed, the EINF under Law 11/2018 remains in force.

SituationRuleWhat it means
Company with more than 250 employees and total assets > €20,000,000 or turnover > €40,000,000 (two years)Art. 262.5 LSC; Transitional Provision 3 Law 11/2018EINF in the management report or in a separate report, verified by an independent provider
Group required to consolidate that meets the same requirementsArts. 49.5 to 49.7 of the Commercial CodeConsolidated EINF; separate item on the general meeting agenda
Audit of accounts of a company required to prepare the EINFArt. 5.1.f) Law 22/2015The auditor only checks that the EINF is included or referred to
Company with more than 1,000 employees and net turnover above €450,000,000Directive (EU) 2026/470 (pending transposition)Sustainability report under the CSRD once Spain transposes it
SME supplier with no legal obligationVoluntary VSME standardVoluntary report to respond to customers, banks and investors

What is included

Obligation assessment

Using your accounts for the last two years, we check whether you are required to prepare the EINF, whether you can rely on the group exemption and how the transposition of the CSRD with the Omnibus I thresholds would affect you.

Non-financial information statement (Law 11/2018)

Materiality analysis, choice of reference framework, definition of indicators, data collection and drafting of the EINF or separate report, coordinated with the management report and the timetable for preparing the accounts.

Sustainability reports (CSRD)

Gap analysis against the European Sustainability Reporting Standards for companies that will exceed the new thresholds, and a roadmap for adapting data systems and controls.

Independent ESG assurance

Verification of the EINF or of voluntary sustainability reports: review of data capture processes, testing of indicators, interviews with those responsible and an independent assurance report.

VSME reports for SMEs

Preparation of a report under the voluntary standard for SMEs (Basic or Comprehensive module) that serves as a single response to questionnaires from customers, lenders and investors.

How we work

  1. 01

    Initial meeting and obligation assessment

    We review size, group structure and third-party requirements, and confirm whether the engagement is for preparation or verification. We assess independence before accepting. Indicative timing: 1-2 weeks.

  2. 02

    Materiality analysis and framework

    We identify the matters relevant to your business and stakeholders and agree the reference framework to be cited in the report. Indicative timing: 2-4 weeks.

  3. 03

    Collecting data and indicators

    We work with those responsible for each area (HR, environment, procurement, compliance) and document the sources and calculations. This is best started before the year-end.

  4. 04

    Drafting or reviewing the report

    We draft the EINF or, in verification engagements, review the entity's draft and report any issues so that management can correct them before the accounts are prepared.

  5. 05

    Assurance report

    We issue the independent assurance report with the conclusion reached, in time for the preparation of the accounts (three months from year-end, art. 253.1 LSC) and for the general meeting.

Documentation and deliverables

What we will ask you for

  • Annual accounts and management report for the last two years
  • Workforce data: average number of employees, contracts, remuneration, absenteeism, accidents and training
  • Energy, water and materials consumption, and utility bills
  • Greenhouse gas emissions inventories or calculations, if available
  • Internal policies: code of ethics, anti-corruption, equality, environment, procurement
  • Tax information: profits by country, corporate income tax paid and grants received
  • ESG questionnaires received from customers, banks or investors (for VSME engagements)

What you will receive

  • Obligation assessment report (EINF and CSRD outlook)
  • Draft EINF, separate report or VSME report (preparation engagements)
  • Independent assurance report (verification engagements)
  • Letter of recommendations on data processes and internal control
  • Indicator matrix with sources and owners

Frequently asked questions

It is if it has more than 250 employees on average and, in addition, is a public-interest entity (other than an SME) or, for two consecutive years, exceeds €20,000,000 in total assets or €40,000,000 in net turnover. If it belongs to a group whose consolidated report already includes it, it may be exempt by stating this in its management report.

The Spanish Commercial Code requires an independent assurance services provider. What matters is independence from the information verified: whoever prepared the EINF must not verify it. Controlaudit provides this service as an audit firm registered with the ROAC under no. S1604 and assesses independence before accepting each engagement.

Not as regards its content. Art. 5.1.f) of the Spanish Audit Act limits the statutory auditor’s task to checking that the EINF is included in the management report or that the latter refers to the separate report. Reviewing the content is the job of the independent assurance provider.

In Spain, not yet: the CSRD has not been transposed and the bill that was to do so lapsed on 06/10/2026 when the Spanish Parliament was dissolved. When it is transposed together with the Omnibus I Directive, it will only affect companies with more than 1,000 employees and net turnover of more than €450,000,000, probably for financial years beginning on or after 01/01/2027. Until then, the EINF requirements must be met.

No. Until a Spanish law amending the regime is passed, the obligations under art. 262.5 LSC and art. 49 of the Spanish Commercial Code remain in force, including verification. The situation should be reviewed when the transposing law is published.

No legislation currently requires an SME to respond; the requirement arises from the contract or the business relationship. The practical approach is to prepare a report under the voluntary VSME standard and use it as a common response. Once Omnibus I is transposed, companies with up to 1,000 employees will be able to refuse to provide information beyond the voluntary standard.

Request your proposal for sustainability and non-financial reporting

Tell us about your situation and one of the firm’s auditors will contact you.