Spain's Royal Decree 214/2025: What the New Carbon Reporting Rules Mean for Businesses

Royal Decree 214/2025 places a clear set of carbon duties on a defined group of companies in Spain. Those in scope must calculate their carbon footprint every year, hold a plan to reduce their emissions over at least five years, and publish both. The decree doesn’t expand who reports, but significantly expands what they must report and do, most notably by requiring a formal reduction plan rather than just the disclosure of voluntary targets.

The reach of the decree extends past Spain's borders. A subsidiary of a UK, US or Canadian group can fall within it, and the way the rules treat parent companies based outside the EU means a consolidated report from head office does not always settle the question.

Here is what the decree is, the obligations it creates, the key dates, who it affects directly and indirectly, and the wider framework it connects to.

What is Spain's Royal Decree 214/2025?

Royal Decree 214/2025, of 18 March, was published in Spain's official gazette, the Boletín Oficial del Estado (BOE), on 12 April 2025 and entered into force on 12 June 2025. It develops Spain's Climate Change and Energy Transition Law (Law 7/2021) and is administered by the Ministry for the Ecological Transition (MITECO) through the Spanish Office for Climate Change (OECC). The full text is published in the BOE.

It replaces Royal Decree 163/2014, which set up a national register where organisations could choose to log their carbon footprint, offsetting and CO2 absorption projects. Under those rules, taking part was voluntary.

The big change in the 2025 decree is that it makes carbon reporting compulsory for certain companies. Those in scope must now measure their carbon footprint every year, hold a plan to reduce their emissions, and publish both. The register still exists, and the decree expands it, adding absorption projects such as blue carbon and allowing the footprints of organised events to be logged, but for private companies joining it remains optional. Their obligation is to publish, not to register.

State public-sector bodies sit outside that pattern. For them, registering their footprint in the MITECO register each year is itself mandatory.

What does Royal Decree 214/2025 require?

For private companies in scope, the decree sets out three core obligations.

Calculate an annual carbon footprint. This covers Scope 1 and 2, which are mandatory, while Scope 3 (the value chain emissions that sit largely with a company's suppliers) is voluntary. The footprint can run over any 12 consecutive months, aligned to the calendar or financial year, and must use the official emission factors published on the MITECO register's website.

Produce a reduction plan. This goes further than stating a target. It must set a quantified reduction target over a horizon of at least five years, with the measures to achieve it, in line with the Paris Agreement and the EU's objective of climate neutrality by 2050. The target applies to the total footprint, though it can also be broken down by scope. A group already running a reduction plan of at least five years can keep it, provided that plan meets the decree's requirements.

Publish both. The footprint and reduction plan must be free and accessible on the company's website within six months of the financial year-end, and kept available for five years. Including the information in the company's non-financial or sustainability report satisfies this.

A short summary of the three steps:

Key timelines for Royal Decree 214/2025

The decree is already in force, and the first reporting cycle that reflects its specifics covers the 2025 financial year, reported during 2026.

Because the timing tracks the existing non-financial reporting calendar, the publication deadline falls within six months of a company's financial year-end rather than on a single fixed national date.

Who does Royal Decree 214/2025 affect?

The decree creates direct legal duties for one set of organisations, and reaches others indirectly through procurement and supply chains. It helps to take the two separately.

Who is directly affected?

Spanish companies already in non-financial reporting scope. The decree does not invent a new population of reporters. It attaches the carbon obligation to companies that are already required to publish a non-financial information statement (the EINF) under Spanish company law, specifically article 49.5 of the Code of Commerce and article 262.5 of the Capital Companies Act. Under the rules currently in force, through the transitional provision of Law 11/2018, that captures companies with more than 250 employees that also meet one of the following:

• They qualify as a public-interest entity under Spanish audit legislation, excluding those classed as small or medium-sized enterprises under EU Directive 2013/34, or
• Over two consecutive financial years, they meet at least one of two financial tests: total assets above €20 million, or net annual turnover above €40 million.

Some summaries still cite a 500-employee threshold. That reflects the older figure, under the original EU Non-Financial Reporting Directive and the first phase of Law 11/2018, before the threshold was phased down to more than 250 employees from 2021. MITECO's interpretive note ties the decree to the current non-financial reporting regime, so more than 250 employees is the figure in force.

Spanish subsidiaries of overseas groups. This is the point most likely to catch out a UK, US or Canadian business, and it is direct scope, not a knock-on effect. Where a group's ultimate parent sits outside the EU and it has subsidiaries in Spain, those Spanish subsidiaries are themselves obligated if they cross the thresholds, either as the dominant company of a subgroup or individually. A Spanish subsidiary can be exempted if its overseas parent already complies, in its own country, with reporting requirements equivalent to Law 11/2018 and includes the carbon footprint and reduction plan in that reporting. The important nuance, set out in MITECO's interpretive note, is that a consolidated report from a non-EU parent does not automatically grant the exemption. If the parent's report does not include the footprint and reduction plan, the Spanish subsidiary has to prepare and file its own statement in Spain containing that information. For groups headquartered in the UK or US, the practical message is that local Spanish entities cannot be assumed to be out of scope.

State-level public-sector bodies. Alongside private companies, the decree brings in central government departments, their autonomous bodies, Social Security entities and other state administrative bodies. These must calculate their footprint and register annually, with their first registration in 2026 for the 2025 footprint.

Who is indirectly affected?

Businesses bidding for Spanish public contracts. The decree reinforces the role of the carbon footprint in public procurement. Contracting authorities may include a footprint among the environmental considerations in a tender, which a bidder can evidence through registration in the MITECO register or an equivalent certificate. A business that competes for Spanish public-sector work, wherever it is based, may find a measured footprint becomes an advantage, or a requirement set by the buyer. The duty here sits with the contracting authority, not the bidder, so the effect is a knock-on one.

Suppliers to in-scope companies. Because Scope 3 is voluntary under this decree rather than mandatory, the pull on suppliers is softer than under regimes that require full value chain reporting. It is real all the same. Companies that choose to include Scope 3, or that face procurement criteria tied to emissions, will look to their suppliers for data. A supplier that can provide a credible footprint makes itself the easier business to work with.

How Royal Decree 214/2025 links to other rules

The decree does not sit on its own. It is one piece of a connected set of Spanish and EU climate and reporting rules.

• Law 7/2021, the Climate Change and Energy Transition Law. The decree develops this law, which is where the power to define which companies must calculate and publish their footprint comes from.
• Law 11/2018, on non-financial and diversity information. This is Spain's transposition of the EU's old Non-Financial Reporting Directive. The decree borrows its scope and timing wholesale, which is why the companies affected are those already filing an EINF.
• The CSRD (Corporate Sustainability Reporting Directive, EU Directive 2022/2464). The decree mirrors the EU's wider shift from the Non-Financial Reporting Directive to the CSRD. MITECO's note confirms that once Spain transposes the CSRD, a company that publishes its footprint and reduction plan within its sustainability report will be treated as having met the decree's publication duty. For a fuller explanation, see The CSRD Explained.
• The EU Climate Law (Regulation 2021/1119). The reduction plan's alignment with climate neutrality by 2050 traces back to this regulation and the Paris Agreement.
• Public procurement law (Law 9/2017). This is the route through which the footprint can feature as an environmental consideration in Spanish public tenders.
• Royal Decree 163/2014. The decree it replaces, which established the original voluntary register.

Why carbon reporting sits at the centre

Every obligation in the decree runs on emissions data. A footprint cannot be published before it has been measured, and a five-year reduction plan with a quantified target has no foundation without an accurate baseline. The same is true of the indirect effects: a Spanish subsidiary, a bidder for public work, or a supplier asked for figures all need a footprint they can stand behind.

Two qualities matter most. The first is coverage. Scope 1 and 2 are the mandatory floor, but a footprint that only reaches those scopes leaves out the part of the picture, the value chain, where the majority of most companies' emissions sit. The second is the quality of the underlying data. A reduction plan is only credible if the baseline it works from reflects what a business does, not just what it spends.

The decree leans the same way on methodology. It requires the mandatory Scope 1 and 2 footprint to be calculated using MITECO's official emission factors, which are activity-based: they convert physical consumption, such as kilowatt-hours of electricity or volumes of fuel, into emissions, rather than estimating from spend. That makes activity data the foundation for the part of the footprint the decree requires. It is also what lets a business show a genuine reduction against its target over time, since figures built on physical activity move when a company actually decarbonises, rather than shifting with prices.

Spain does offer an official route for the basics. MITECO publishes the required emission factors and a free Scope 1 and 2 calculator, and runs the register where footprints and plans can be filed. It is a downloadable spreadsheet built for the legal minimum, though. It does not reach Scope 3, pull in data, produce reports for other frameworks, or come with any support. And while it can show a basic before-and-after reduction figure, it does not build the five-year reduction plan, with a quantified target and the measures behind it, that the decree requires. For a full-scope footprint and a credible plan to reduce it, businesses tend to need more. 

FAQs

Is Royal Decree 214/2025 a law?

It is a royal decree, a binding piece of Spanish legislation that develops the Climate Change and Energy Transition Law (Law 7/2021). It places a legal duty on the companies and public bodies within its scope.

Does Royal Decree 214/2025 make Scope 3 reporting mandatory?

No. For companies, Scope 1 and 2 are mandatory and Scope 3 is voluntary. Some summaries claim a future Scope 3 mandate, but MITECO's own interpretive note confirms Scope 3 remains voluntary for companies.

Which companies are directly affected?

Companies who are already required to publish a non-financial information statement under Spanish company law. Under the current rules, that means companies with more than 250 employees that are either a public-interest entity or, over two consecutive years, meet at least one of two financial tests: total assets above €20 million, or net turnover above €40 million. 

Does a company have to register in the MITECO register?

No. Registration in the register is voluntary for private companies. The obligation the decree creates is to calculate and publish the footprint and reduction plan, which does not require registration. State public-sector bodies, by contrast, must register annually.

Does Royal Decree 214/2025 apply to a business based outside Spain?

It can. A Spanish subsidiary of an overseas group may be directly in scope if it crosses the thresholds. A consolidated report from a parent based outside the EU does not automatically exempt the Spanish subsidiary, so groups headquartered in the UK, US or elsewhere should not assume their Spanish entities are out of scope.

When does Royal Decree 214/2025 take effect?

It entered into force on 12 June 2025. The first reporting cycle reflecting its specifics covers the 2025 financial year, reported during 2026, with publication due within six months of a company's financial year-end.

Where can the official text be read?

The decree is published in the BOE as BOE-A-2025-7439, and MITECO has issued an interpretive note clarifying scope, obligations and deadlines. Both are the primary sources.

‍