New Royal Decree on Carbon Footprint Published

Royal Decree 214/2025 regulates the new Carbon Footprint Registry and requires certain companies and institutions to calculate and disclose their carbon footprint.

Would you like to know whether it applies to your organization and learn about its main updates?

On April 10, 2025, the Official State Gazette (BOE) published Royal Decree 214/2025, which creates the Carbon Footprint, Offset, and CO₂ Absorption Projects Registry and establishes an obligation for certain organizations to calculate their carbon footprint and develop and publish greenhouse gas (GHG) emission reduction plans.

This new regulation builds upon Royal Decree 163/2014, which, until now, had allowed organizations—on a voluntary basis—to calculate and register their carbon footprint through a platform managed by the Ministry for the Ecological Transition and the Demographic Challenge (MITERD). The registry also offered the possibility of offsetting all or part of a carbon footprint through national forestry projects, also registered in the same system.

Currently, the Carbon Footprint Registry includes 14,250 registered carbon footprints, more than 23,000 hectares of reforested land, and recognized offsets equivalent to over 150,000 tons of CO₂.

After ten years, it was considered appropriate to review and update the regulation to improve its functioning, clarify certain aspects, streamline administrative procedures, and introduce new requirements.

The main highlights of this new Royal Decree are:

1. From now on, the MITERD carbon footprint register is structured in three sections:

• Carbon footprint section
• CO₂ absorption projects section
• Carbon footprint offset section

2. In relation to the carbon footprint section:

1. The registry allows organizations or events to register their carbon footprints. In the first case, organizations must at least include direct greenhouse gas emissions (scope 1) and indirect emissions associated with the generation of electricity and energy (scope 2). Non-significant emission sources from scope 1 or 2 may be excluded as long as the total of exclusions does not exceed 5% of the total scope 1+2 emissions. The inclusion of scope 3 emissions (other indirect emissions) is voluntary. For event carbon footprints, both direct and indirect emissions must be included. In all calculations, the emission factors published by the Spanish Office for Climate Change must be used.
2. Organizations wishing to register must submit the following documentation when applying for registration:

• Carbon footprint report, describing the organization or the event, calculation boundaries, emission sources included and excluded, activity data, and emission factors used.
• Carbon footprint verification report issued by an accredited entity, with the following details:
  - Scope 1 and 2 footprints: external verification is not mandatory if all emissions declared by the organization use emission factors published by the Spanish Office for Climate Change and, in addition, it is an SME, cooperative, foundation, association, or public administration (see note 1 below).
  - Footprints including scope 3: verification is not mandatory if it is a microenterprise, small enterprise, or public administration, and the Spanish Office for Climate Change has published emission factors corresponding to all significant declared emissions.
• A carbon footprint reduction plan. The document must include, at least, a quantified reduction target compared to a base year, together with the measures for its achievement. From January 1, 2026, and corresponding to the 2025 carbon footprint, this target must be set for a time horizon of at least five years.

3. In relation to the carbon footprint offset section, only offsets from projects registered in the CO₂ absorption projects section or projects recognized by MITERD can be registered.

4. Certain organizations will be required to calculate their carbon footprint and prepare an emissions reduction plan. Specifically, the companies subject to this obligation are:

a. Capital companies (public limited companies, limited liability companies, partnerships limited by shares) that prepare individual accounts and meet the following criteria:

• Have more than 250 employees during the year.
• Be considered public interest entities (listed companies, credit institutions, insurance companies, etc.) or meet at least one of these two financial criteria:
  - That total assets exceed 20 million euros, or
  - That the annual net turnover exceeds 40 million euros. 

b. Capital companies that prepare consolidated accounts: the parent company of the group that prepares consolidated accounts must calculate the carbon footprint when the group, as a whole, meets the same criteria described for capital companies.

c. All institutions of the General State Administration: ministerial departments and their autonomous agencies, Social Security management entities, etc.

All these organizations must publish their carbon footprint and greenhouse gas emissions reduction plan on their website. Registration with MITERD is mandatory for organizations in section b) and voluntary for those in section a).

In summary, the calculation of the footprint is mandatory for all those already required to prepare a Non-Financial Information Statement (EINF), as well as for all institutions of the General State Administration.

The Royal Decree enters into force on June 12, 2025.

Beyond being a new obligation for certain organizations, calculating the carbon footprint offers many additional benefits:

• It helps reduce greenhouse gas emissions and makes companies less dependent on fossil fuels.
• It provides a competitive advantage in tenders and supply chains, as more and more clients request emissions information from their suppliers.
• It allows for reduced operating costs and improved efficiency through improvement plans that optimize consumption (electricity, fuel, etc.) and processes.
• It improves corporate image and strengthens environmental commitment to stakeholders.

For all these reasons, at Baker Tilly we encourage you to calculate your carbon footprint, whether your organization is required to do so or not. Without a doubt, doing so will help you enhance competitiveness, improve efficiency, and contribute to the fight against climate change.This is the spirit of the newly approved Royal Decree.

Note 1:

• A small enterprise is one that, at the balance sheet date, does not exceed at least two of the following three limits: a) total assets: €4 million; b) net turnover: €8 million; c) average number of employees during the year: 50.
• A medium-sized enterprise is one that does not meet the requirements to be considered a micro or small enterprise and, at the balance sheet date, does not exceed at least two of the following three limits: a) total assets: €20 million; b) net turnover: €40 million; c) average number of employees during the year: 250.