Royal Decree 214/2025: the December update on mandatory carbon footprints

Spain’s Ministry for Ecological Transition (MITECO) has published an updated clarifying note on Royal Decree 214/2025 regarding mandatory carbon footprints. This may sound like more bureaucracy, but these clarifications are genuinely good news: they remove ambiguities and give organisations more flexibility. Here is what they mean for you.

Five key updates you need to know

1. Concrete deadlines — finally

The deadline for submitting your carbon footprint and reduction plan is the same as for the EINF (non-financial information statement): 6 months after the close of the financial year. No loose dates, no interpretation needed. If your year ends in December, you have until June. Simple.

2. Choose the calendar that works for you

You can calculate your carbon footprint using the calendar year or your fiscal year — your choice. What matters is that it covers 12 consecutive months and makes sense for your internal processes.

3. Scopes 1 and 2 mandatory, Scope 3 voluntary

You must calculate Scope 1 and Scope 2 emissions. Scope 3 remains voluntary — though we recommend considering it, as more and more stakeholders are requesting it. You must also use the official emission factors from the MITECO register, provided this is compatible with your other reporting obligations.

4. The reduction target applies to the total footprint

Your reduction plan must include a quantified target of at least 5 years, based on the total footprint. You cannot set a target for just one scope and ignore the rest, though you may break down the target by scope if you wish.

If you already have a 5-year reduction plan in place that meets the requirements, you do not need to start from scratch.

5. International groups — this is the critical one

This has the greatest impact, particularly for subsidiaries of international groups:

Group structure	Implication
Parent company in Spain	Consolidated EINF that includes footprint and plan covers the whole group
Parent in the EU (Germany, France, etc.)	If the parent complies in its home country including footprint and plan, Spanish subsidiaries are exempt
Parent outside the EU (US, UK, Switzerland…)	The consolidated group report does not automatically exempt the Spanish subsidiary

That last point matters: if your non-EU parent’s consolidated report does not include a carbon footprint calculation and reduction plan meeting Spanish requirements, the Spanish subsidiary must comply independently. Many subsidiaries of non-EU multinationals believed they were covered — and are not.

Who is affected?

This applies to companies with more than 250 employees that are public interest entities or that meet at least one of the following criteria for two consecutive financial years:

• Total assets exceeding €20 million
• Annual turnover exceeding €40 million

If you do not meet these thresholds, you are not obligated. If you do, read on.

Key dates

The obligation has been in force since 2021, but this update clarifies that:

• If you need to adapt your footprint or plan to the new specifications, this must be done in the 2026 report (covering the 2025 financial year)
• If your financial year follows the calendar year, the first deadline is June 2026

Registration in the official MITECO register

For registration in the Carbon Footprint Register, only emissions in Spanish territory are registered, along with a plan that includes specific targets to reduce those emissions in Spain.

Beyond compliance: carbon management is already strategic

Even without this regulation, carbon footprint management has become essential. Your banks, insurers, B2B customers, and supply chain partners are already asking for it — or will be soon.

The work you do to comply with RD 214/2025 also serves to:

• Access green financing on better terms
• Pass supply chain audits without friction
• Compete for tenders with ESG criteria
• Identify operational inefficiencies that are costing you money

The regulation may evolve, but sustainability as a lever for risk reduction, efficiency improvement, and business development is already a market reality.

What to do now

If you are within the mandatory thresholds (or close to them), these are the next steps:

1. Confirm whether you are a mandatory subject based on your structure and figures
2. Define the scope of calculation that best fits your situation
3. Set a realistic reduction plan you can actually deliver (and that creates value)
4. Prepare all documentation to meet the deadline without last-minute pressure

The deadline is approaching: if your financial year follows the calendar year, you must submit information for the 2025 financial year before 30 June 2026.