Law 11/2018 on non-financial information expanded ESG reporting to large companies and listed groups. The CSRD Directive (EU) 2022/2464, in force from 2024, goes much further: expands scope, requires independent assurance and adopts ESRS standards. We analyse the ESG compliance roadmap for Spanish companies.
Law 11/2018 of 28 December transposed Directive 2014/95/EU on non-financial information. Listed companies and large non-listed companies with > 500 employees must prepare a Non-Financial Information Statement (EINF).
The Corporate Sustainability Reporting Directive (CSRD) progressively replaces Law 11/2018:
Phase 1 (2024): Large listed companies already subject to NFRD (>500 employees) → first report 2025 (2024 data). Phase 2 (2025): Large non-listed companies (>250 employees AND assets >€25M OR turnover >€50M) → first report 2026 (2025 data). Phase 3 (2026): Listed SMEs (simplified standard) → first report 2027. Phase 4 (2028): Third-country companies with significant EU activity → first report 2029.
ESRS standards: 12 mandatory thematic standards (E1-E5 Environment, S1-S4 Social, G1 Governance).
Double materiality: Companies must report on both their impact on the environment AND ESG risks/opportunities affecting them.
Independent assurance: Required from an independent auditor (initially limited assurance, escalating to reasonable assurance).
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