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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 Team 4 min EINF 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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