MITECO 2026: everything changing in the Carbon Footprint Register

In April 2026, MITECO published version 18 of the support document for registration in the Carbon Footprint Register, incorporating the changes introduced by Royal Decree 214/2025, which replaces RD 163/2014 — in force for over a decade.

What is changing?

The most immediate change is operational: the email channel closes on 11 May and all procedures move to the electronic office, which introduces five separate procedures where there was previously just one. But beyond the procedural, RD 214/2025 introduces a substantive shift: the register is no longer purely voluntary and now imposes legal obligations on certain entities — including the Spanish state public sector and companies required to submit a non-financial information statement (EINF). New SME definitions may also affect who needs external verification, and new requirements apply to reduction plans.

Operational changes

1. The email channel closes From 11 May 2026, submissions to HC-OECC@miteco.es will not be processed. Only registrations via the electronic office will be accepted. If you have registrations in preparation, submit them by email before 10 May or arrange access to the electronic office (entity digital certificate, or authorisation via Cl@ve/REA if acting through a representative).

2. One procedure becomes five The single procedure splits into five distinct processes in the electronic office: carbon footprint, absorption projects, compensation, transfer, and cancellation. Excel forms will progressively migrate to online forms.

3. New movement types for absorption units Five movement types are now formalised: transfer, cancellation, compensation, annulment, and guarantee pool backing. This mainly affects clients with absorption projects (Compenso seal).

Substantive changes under RD 214/2025

RD 214/2025 replaces RD 163/2014. The register moves from being exclusively voluntary to a system with legal obligations for certain entities.

1. Spanish state public sector: mandatory registration from 2026 Ministerial departments of the General State Administration, autonomous bodies, Social Security management entities, and the state administrative public sector are required to register their footprint and reduction plan annually.

2. Entities required to submit the EINF: mandatory adaptation in 2026 Companies that must submit a non-financial information statement (EINF) must adapt their footprint and reduction plan to RD 214/2025 in the report covering fiscal year 2025. A common error: these entities are obligated to calculate and publish their footprint, but they are not required to register it. Registration remains voluntary for private entities.

3. Reduction plan: minimum 5-year horizon From 1 January 2026, the reduction plan must include a quantified target with a horizon of 5 years or more, aligned with the Paris Agreement and 2050 climate neutrality. A generic plan without a fixed horizon is no longer accepted.

4. New SME definition from 2026 The reference directive has changed. Financial thresholds have been lowered: turnover drops from ≤€50 million to ≤€40 million, and total balance from ≤€43 million to ≤€20 million. The logic also changes: organisations must not exceed 2 of the 3 criteria in two consecutive financial years.

Companies that were classified as SMEs in 2025 may no longer qualify in 2026, which would make external verification mandatory. Recalculate your SME status before planning your 2026 registration.

Additional updates

Interoperability with regional registers Under Article 5.2 of the RD: if you have already registered with a regional (autonomous community) register, you can notify that register to forward the application to MITECO, avoiding duplicate processing.

New types of absorption projects From 2025, blue carbon projects (marine and coastal ecosystems) are accepted, alongside the existing categories of forest restoration and post-fire projects.

Carbon footprint of events (coming soon) The register will expand its scope to include events. Not yet operational, but included in MITECO’s roadmap.

How Dcycle can help

If you use Dcycle to calculate your carbon footprint, you are already a step ahead: your data is structured, traceable, and ready to be used in the registration process.

The Customer Success team can help you:

• Review whether your reduction plan meets the new 5-year minimum horizon
• Recalculate your SME status under the new criteria
• Identify which electronic office procedure applies to your specific case

If you have questions about how these changes affect you, or want to review your situation before 11 May, contact your Customer Success manager.