Scope of application of the Royal Decree

The explanatory note confirms that the obligations of RD 214/2025 affect only companies subject to the reporting of non-financial informationThe decree is a clarification of the Commercial Code and the Capital Companies Law. This clarification corrects the confusion generated after the publication of the decree and identifies companies that exceed the size thresholds or are public interest entities.

These companies must calculate their carbon footprint on an annual basis and must include the following scopes 1 and 2while Scope 3 remains optional. The note also recalls the obligation to use the emission factors published by the official registry, provided that they are compatible with non-financial reporting standards.

Reduction plan requirements

The decree requires the preparation of an emissions reduction plan with a minimum horizon of five years.The note clarifies that it incorporates a quantified objective and associated measures. The note clarifies that groups that already have a plan in force may maintain it, provided that it meets the requirements of the standard. provided that it meets the requirements of the standard.

This plan must be aligned with national and European climate objectives, especially climate neutrality by 2050.

Timetable and publication obligations

The reporting obligation applies from 2021 and maintains the schedule of Law 11/2018. The and the plan must be presented within six months after the end of the fiscal year, coinciding with the presentation of the Statement of Non-Financial Information (SNFI).The calculation and plan must be presented within six months after the end of the fiscal year, coinciding with the presentation of the Statement of Non-Financial Information (SNFI).

In addition, companies must publish free of charge and accessible on its website both the carbon footprint and the reduction plan. Once the sustainability directive (CSRD) is transposed, this obligation will be considered fulfilled if the information is integrated into the corresponding sustainability report.

Application in multinationals

The note clarifies how the obligations should be applied by groups with an international presence:

• Groups with headquarters in Spain

The group is an obligated entity if it exceeds the thresholds of the Commercial Code. The obligation is fulfilled by the Consolidated EINFprovided that it includes the footprint calculation and reduction plan.

For the official registrationFor the official registry, only emissions emissions generated in Spanish territory and the associated and the associated plan .

• EU parent company and subsidiaries in Spain

Spanish subsidiaries may be exempted from exempted from submitting their own NIFS, as long as the parent companyprovided that the parent company reports in accordance with its country’s regulations and includes the mandatory elements of RD 214/2025.

Only the footprint of the Spanish subsidiaries with their corresponding plan is registered in the registry.

• Parent company outside the EU

The Spanish subsidiary will be an obligated entity if it meets the legal thresholds.

It may be exempted from preparing its own EINF if the parent company meets the requirements equivalent to Law 11/2018 and includes the calculation and reduction plan.

If the parent company does not provide this information, the subsidiary should prepare its own PFIA in Spain, including the calculation and reduction plan.including the calculation and reduction plan.
The registry only accepts the footprint and plan of Spanish subsidiaries.