Brussels has taken around nine in ten companies out of mandatory sustainability reporting. In Spain, however, the non-financial information statement (EINF) for financial year 2026 remains mandatory for every company already required to file it. The bill that was meant to bring Spanish law in line with the EU lapsed when Parliament was dissolved.
What changed in the EU. Directive (EU) 2026/470, the “Omnibus I” Directive, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. The CSRD now applies only to companies or groups with more than 1,000 employees and net turnover above €450 million, for financial years starting on or after 1 January 2027. Groups with a non-EU parent are in scope if they generate more than €450 million of EU turnover in each of the last two years and have an EU subsidiary or branch above €200 million. Companies with fewer than 1,000 employees are protected from excessive data requests by their larger customers. Member States must transpose the Directive by 19 March 2027.
What has not changed in Spain. Spain has not transposed the Directive. Royal Decree 806/2026 of 5 October dissolved Parliament and called a general election for 29 November, so the pending sustainability reporting bill lapsed. Law 11/2018 remains in force. On 22 October 2026, Spain’s securities regulator (CNMV) and audit regulator (ICAC) confirmed that companies within its scope must still publish an independently verified EINF for 2026. Spain did not adopt the optional exemption for 2025 and 2026.
Why it matters for international groups. A Spanish subsidiary may fall outside the CSRD at group level and still have to file and verify an EINF under Spanish law. Group finance teams that assume “the Omnibus took us out” may find a gap in their Spanish subsidiary’s annual accounts.
What to do now: confirm whether your Spanish entity is still within the scope of Law 11/2018, book the 2026 verification early, prepare 2027 data collection if you exceed the EU thresholds, and watch the political calendar after 29 November.
One Firm Auditores helps companies determine which reporting obligations apply to them in Spain and prepare robust, verifiable sustainability reports. Get in touch to discuss your case.