How to prepare your EINF, step by step

Below is the workflow that lands a clean EINF, filed on time, signed off by the board and validated by your verifier. Run it in this order — the steps are sequenced because each depends on the previous.

1. Define the scope

Reporting entity — single company or consolidated group? If you’re part of a Spanish group, confirm whether the parent files consolidated and your individual obligation is satisfied.
Reporting period — calendar year vs fiscal year (typically aligns with annual accounts).
Materiality boundary — which sites, business units and subsidiaries are in scope?

Document the scope in writing. Your verifier will reference it.

2. Map requirements

Cross-walk Ley 11/2018 against your existing data. The five pillars (environmental, social, human rights, anti-corruption, society/diversity) contain ~120 disclosure items. Many you already have somewhere — they just live in different systems.

If you’re using GRI Standards as the underlying framework, your GRI content index doubles as the requirement map.

3. Assign ownership per pillar

EINF cuts across departments:

Pillar	Typical owner
Environmental	Operations / Facilities / EHS
Social and employment	HR
Human rights	Legal / Compliance
Anti-corruption	Legal / Compliance / Internal Audit
Society and diversity	Corporate Secretary / HR

A central sustainability lead coordinates and consolidates. Don’t run it as a one-person project — gaps appear in pillars where there’s no domain owner.

4. Collect and validate data

Gather:

Source documents — invoices, HR records, energy bills, compliance reports, audit minutes.
Quantitative metrics with year-on-year comparisons.
Qualitative policies — written, dated, signed.

Validate before drafting:

Are the units correct? (kWh, tCO2e, % of workforce)
Are the boundaries consistent across metrics?
Are the YoY trends explainable? (a 40% drop will need a footnote)

5. Draft the report

Structure each pillar with:

Policies — what you’ve decided to do.
Due diligence procedures — how you identify and prevent risks.
Results (KPIs) — what you achieved this period.
Key risks — what could go wrong and how you mitigate.
Key indicators — typically a year-on-year comparison table.

Use comply-or-explain rigorously: if you don’t disclose something material, the report must justify why.

6. Get independent verification

The verifier is appointed at the General Shareholders’ Meeting. Provide them with an evidence pack that links each reported data point to a source document. They’ll issue a limited assurance opinion as a separate document.

Address findings in writing — keep the trail for next year.

7. Board approval and filing

The board of directors must formally approve the EINF before filing. Final steps:

File at the Mercantile Registry with the annual accounts.
Publish on the company website within 6 months of fiscal year-end.
Keep the report accessible for at least 5 years.

Year-on-year discipline

EINF gets easier each cycle if you:

Maintain a single source of truth for ESG data (not 20 spreadsheets).
Carry forward the structure and only update the numbers and narrative.
Resolve verifier findings before the next reporting period starts.