Who needs to file an EINF?

EINF filing is triggered by two distinct routes. If you meet either, you have to file.

Route 1 — Public-interest entities (PIEs)

If you are a public-interest entity with more than 500 employees, you file regardless of asset or revenue size. PIEs include:

• Companies listed on EU-regulated markets.
• Credit institutions (banks).
• Insurance and reinsurance undertakings.

The 500-employee count applies to the consolidated group, not the standalone entity.

Route 2 — Large companies

Outside PIEs, the obligation kicks in when you meet at least two of these three thresholds for two consecutive years:

Criterion	Threshold
Average employees	> 250
Total assets	> €20 million
Net annual revenue	> €40 million

The obligation activates for the financial year in which the thresholds are met for the second consecutive year.

Consolidated vs standalone

Structure	Who files
Standalone company	The company itself
Spanish parent of a group	A single consolidated EINF covers all subsidiaries
Subsidiary of a Spanish group	Exempt if the parent’s consolidated EINF covers its operations
Spanish subsidiary of a foreign parent	Files individually unless the foreign parent’s report meets Ley 11/2018 standards

Exemptions

There are no blanket exemptions for companies meeting the thresholds. Specific case-by-case exemptions:

• Subsidiaries explicitly covered by a parent’s consolidated EINF.
• Companies that drop below thresholds for two consecutive years (the obligation lapses).

Voluntary EINF

Companies below the thresholds increasingly file voluntarily because:

• Customers and investors request ESG disclosure regardless of legal mandate.
• Public tenders often require it.
• It’s the easiest on-ramp to a future CSRD obligation.

If you’re below thresholds today but expect to cross them (or expect to fall under CSRD), starting voluntarily is a low-risk way to build the muscle.

CSRD transition

Once CSRD applies to you, it supersedes EINF. The Spanish timeline tracks the EU timeline (modified by Omnibus I). See EINF vs CSRD for which wave you’d land in.