Summary
Details
- Spain
Law 11/2018 is legally binding and imposes mandatory non-financial reporting obligations on in-scope companies.
A company must prepare a Non-Financial Information Statement if it:
Has an average workforce of more than 250 employees, and
Either total consolidated assets exceed 20 million euros or net turnover exceeds 40 million euros.
Key requirements:
Include the EINF within the management report or in a separate report explicitly referenced.
Use recognised frameworks (e.g. GRI) as guidance where appropriate.
Ensure the report is subject to approval, filing and publication like the financial statements.
Exceptions:
Subsidiaries may be exempt if they are included in a consolidated non-financial statement at group level that meets legal requirements.
Small and micro enterprises below thresholds are not directly covered.
Certain entities can rely on equivalent statements already prepared under other applicable EU or national regulations, if they fully meet the law’s content requirements.
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What’s Required
Law 11/2018 requires certain companies to prepare and publish an annual Non-Financial Information Statement (EINF).
The statement must include information, at a minimum, on:
Environmental matters (emissions, resource use, pollution, circularity).
Social and employee-related issues.
Human rights.
Anti-corruption and bribery.
Diversity in management and governance bodies.
It must be approved together with the management report, signed by directors and published.
Important Deadlines
Annual obligation applying to financial years starting from 2018 onward.
Progressive extension: by the 2021 financial year, the law applies to all companies with more than 250 employees meeting defined financial thresholds.
Current Status
Law 11/2018 remains in force and is currently the main national non-financial reporting law, while Spain is in the process of adapting to the EU CSRD and ESRS.
Guidance has been issued by the Spanish accounting regulator on how to prepare EINF reports.
Penalties for Non-Compliance
Non-compliance is treated under the general regime for financial reporting and company law:
Possible sanctions for failing to file or for incomplete reporting.
Potential liability of directors for approving false, misleading or incomplete statements.
Public scrutiny and reputational risk are also key enforcement drivers, since the reports are public.
Examples of Known Violations
There is no centralised public list of fines specifically tied to Law 11/2018. However:
Supervisory bodies and investors have repeatedly flagged deficiencies in the quality, completeness and comparability of non-financial statements.
In practice, enforcement has focused more on improving disclosure quality than on imposing high-profile sanctions.
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