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EINF vs CSRD: differences and transition
How EINF and CSRD compare across scope, standards, materiality, assurance and format — and what the transition looks like for Spanish companies.
Dcycle Team4 minEINF and CSRD overlap significantly but are not the same framework. If you’re in Spain, you’ll likely report under both during the transition years.
Side by side
| EINF | CSRD | |
|---|---|---|
| Legal basis | Ley 11/2018 (Spain) | EU directive |
| Companies in scope | ~1,600 Spanish companies | ~5,000 EU companies (post-Omnibus) |
| Reporting standard | Free (GRI common) | Mandatory ESRS |
| Materiality | Single (financial only) | Double (impact + financial) |
| Data points | ~120 disclosure items | ~320 mandatory (post-Omnibus, was 1,073) |
| Assurance | Limited (independent verifier) | Limited (no escalation to reasonable post-Omnibus) |
| Format | PDF in management report | XBRL-tagged in management report |
| Filing | Mercantile Registry | Mercantile Registry |
What’s actually different
Standards
EINF lets you pick a framework — GRI is the de-facto standard but you can deviate. CSRD imposes a single set: the European Sustainability Reporting Standards (ESRS), with defined data points and definitions. Comparability across companies and across years becomes structural.
Materiality
The biggest conceptual shift. EINF uses single materiality: which issues affect us financially? CSRD requires double materiality: that question PLUS how do we affect people and the environment. You’ll need a fresh DMA — the EINF materiality matrix doesn’t carry over.
Data depth
EINF asks for ~120 items at the policy/KPI level. CSRD asks ~320 specific data points across topical standards. Same underlying themes, much more granularity, more required calculations (especially around climate and scope 3).
Format
EINF is a narrative PDF. CSRD is XBRL-tagged so machines can query it. Tagging is new work for most teams and harder to retrofit than to design in.
What stays the same
- The five thematic areas of EINF map cleanly onto the ESRS topical standards.
- The data sources (HR records, energy bills, supplier surveys, policies) are the same.
- The need for independent verification is the same — just different assurance scope.
In other words, ~70% of the EINF data structure carries forward. The work is in extending depth and re-doing materiality.
Spanish transition timeline
Post-Omnibus I:
| Wave | First reporting year | Triggers |
|---|---|---|
| 1 | FY 2024 (filed 2025) | Large PIEs > 500 employees |
| 2 | FY 2027 (delayed by Omnibus) | Large companies meeting the dual threshold |
| 3 | FY 2028 | Listed SMEs (opt-out until 2028) |
If you fall under CSRD, file CSRD — you don’t also need an EINF for the same year. If you’re below the new CSRD thresholds, you keep filing EINF.
Transition tactics
- Keep your EINF data infrastructure — it’s the starting point for ESRS.
- Run the DMA early (it’s the new gate).
- Map your existing GRI content index to ESRS data points to see your gap.
- Engage your audit firm with both frameworks in mind so the assurance scope is clear.
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Related articles
What is the EINF?Spain's Non-Financial Information Statement explained — the legal basis (Ley 11/2018), the five mandatory pillars, and how it's verified.
Read more →What is CSRD? A complete guideThe Corporate Sustainability Reporting Directive explained — what it is, who reports, when, and what the ESRS structure looks like.
Read more →