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Royal Decree 214/2015 on Carbon Footprint: Summary Table of Obligations

Jordi Martínez May 27, 2025

We clearly and graphically present the new requirements that the different types of organizations must meet in relation to the carbon footprint.

Royal Decree 214/2025 has introduced new obligations for certain organizations regarding the carbon footprint. In the following table, we summarize, for each type of organization, which requirements are mandatory and which are voluntary. The table is supported by several explanatory notes.

Empresas que deben elaborar estados de Información No Financiera EINF 1
  1. Capital companies that prepare individual accounts or companies that prepare consolidated accounts which, in either case, have more than 250 employees and are either considered public interest entities, or meet at least one of the following two criteria: annual net turnover exceeding €40 million or total assets exceeding €20 million.
  2. Organization that does not meet the requirements to be considered a micro or small enterprise and that does not exceed at least two of the following three criteria: €20 million total assets, €40 million net turnover, and 250 employees.
  3. Organization that does not exceed two of the following three criteria: €4 million total assets, €8 million net turnover, 50 employees.
  4. Includes: ministerial departments of the General State Administration, their autonomous bodies, as well as the managing entities and common services of Social Security, and other entities within the state public administrative sector.
  5. If mandatory, the emission reduction plan must set a minimum five-year reduction target and be aligned with the Paris Agreement.
  6. If this requirement is mandatory, information on the carbon footprint and the reduction plan must be made freely and publicly accessible on the organization’s website.
  7. The carbon footprint calculation must include Scopes 1 and 2. Scope 3 is voluntary.
  8. The carbon footprint calculation must include Scopes 1 and 2, and from the 2028 footprint calculation onward, Scope 3 must also be included.
  9. The carbon footprint calculation must include Scopes 1, 2, and 3.
  10. Registration in the MITECO Carbon Footprint Register is voluntary. If the organization registers, the footprint calculation must include, at a minimum, Scope 1 and 2 emissions.
  11. Registration in the MITECO Carbon Footprint Register is mandatory and must initially include Scope 1 and 2 emissions. From the 2028 footprint calculation onward, Scope 3 must also be included.
  12. External verification is voluntary, except when the carbon footprint is registered in MITECO, in which case external verification is mandatory.
  13. External verification is voluntary. If the organization registers its carbon footprint in MITECO, verification remains voluntary if public emission factors are used for any scope, and mandatory if Scope 3 is included and/or no public emission factors exist.
  14. If an event is registered in the MITECO Carbon Footprint Register, external verification is only mandatory if the event has more than 1,500 in-person attendees.
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