EINF environmental reporting is where most companies spend the bulk of their effort. Law 11/2018 asks for information on the current and foreseeable effects of your activities on the environment, and the evidence behind it comes from invoices, meter readings, waste records and supplier data scattered across the business. Knowing exactly what is required, who holds the data and how the verifier will test it helps you avoid a last-minute scramble during audit preparation.
This guide walks through each environmental topic, then covers ownership, common mistakes and a checklist you can reuse every year.
What the law asks for in the environmental pillar
The environmental section of the EINF is not just a list of KPIs. It combines figures with a description of how you manage environmental risk. Expect to cover:
- Management approach: environmental policies, certification procedures (for example ISO 14001), resources dedicated to preventing environmental risks, and the application of the precautionary principle
- Pollution: measures to prevent, reduce or repair emissions to air, water and soil, including noise and light pollution where relevant to your activity
- Circular economy and waste: prevention, recycling, reuse and other forms of recovery, plus actions against food waste
- Sustainable use of resources: water, raw materials and energy, with the measures taken to use them more efficiently
- Climate change: greenhouse gas emissions, adaptation measures and the reduction targets you have set
- Biodiversity: protection measures and the impact of your activities on protected areas
Every topic needs a policy or approach, the results of that policy, and the related risks. A table of figures without that narrative is one of the gaps verifiers flag most often.
Greenhouse gas emissions
Report your carbon footprint using a recognised methodology. The GHG Protocol is the most common choice:
- Scope 1: direct emissions from owned or controlled sources (fleet, boilers, refrigerant leaks)
- Scope 2: indirect emissions from purchased electricity, heat or steam
- Scope 3: other indirect emissions (business travel, commuting, purchased goods, transport) where material
State the methodology, the sources of your emission factors and the reporting boundary. Include a year-over-year comparison and intensity ratios (for example tCO2e per employee or per million euros of revenue), so readers can judge your trajectory regardless of growth. If you have set reduction targets, report progress against them; if you have not, say so plainly.
Energy consumption
- Total energy consumption in MWh or GJ
- Breakdown by source: electricity, natural gas, diesel, other fuels, renewables
- Share of renewable energy, and how you evidence it (for example guarantees of origin)
- Energy efficiency measures implemented and their results
Energy is usually the most straightforward data to collect because it comes from utility invoices. The difficulty is consistency: companies with many sites must apply the same boundary everywhere, convert units correctly and avoid double-counting shared supplies, such as a warehouse whose electricity is billed to the landlord.
Water, raw materials and pollution
- Water consumption by source, taking local constraints into account where you operate in water-stressed areas
- Wastewater discharge volumes and treatment
- Consumption of the main raw materials and measures to use them more efficiently
- Air pollutant emissions (NOx, SOx, particulate matter) where your activity generates them
- Soil contamination incidents and remediation
For office-based companies, several of these topics are not material. You may conclude that, but explain the reasoning rather than leaving the section blank.
Circular economy and waste
- Total waste generated by type (hazardous and non-hazardous)
- Treatment route: recycling, recovery, landfill
- Measures to prevent waste and promote circularity
- Actions against food waste (essential for food, retail and hospitality companies)
Waste data is where gaps appear most often. Records sit with external waste managers, are expressed in different units or cover only some sites. Ask your waste managers for annual summaries early, and reconcile them with your own records.
Biodiversity
- Operations in or adjacent to protected areas
- Impact assessment and mitigation measures
- Commitments to biodiversity conservation
Who owns the environmental data
The environmental pillar touches more departments than any other. A typical ownership map looks like this:
| Data | Usual owner | Source documents |
|---|---|---|
| Electricity, gas, fuels | Facilities or finance | Utility invoices, meter readings |
| Fleet fuel and travel | Fleet manager, procurement | Fuel cards, travel agency reports |
| Refrigerant leaks | Maintenance | Maintenance contractor logs |
| Waste | Operations or HSE | Waste manager certificates |
| Water | Facilities | Water bills, meter readings |
| Policies and certifications | Sustainability or quality | ISO certificates, policy documents |
Name one owner per data point and agree deadlines before the reporting year closes. The EINF data collection guide explains how to organise this across all five pillars.
How verifiers test the environmental pillar
The EINF must be verified by an independent assurance provider, and the environmental figures are where verifiers spend the most time. They typically:
- Pick a sample of data points and trace each one back to its source document
- Recalculate emissions using your stated emission factors
- Check that the reporting boundary matches the entities covered elsewhere in the EINF
- Compare this year with last year and ask you to explain significant variations
If you cannot show where a number comes from, it will be questioned. Keeping the invoice, the calculation and the approval together for every figure is the most effective way to shorten verification.
Common mistakes
- Reporting figures without the policy and risk narrative that the law requires
- Inconsistent boundaries, with some subsidiaries included in energy but not in waste
- Undocumented emission factors, so the verifier cannot reproduce your footprint
- Missing refrigerant leaks in Scope 1, a frequent omission
- No explanation of year-over-year changes, such as a new site or a change of methodology
Environmental pillar checklist
- Reporting boundary defined and consistent with the rest of the EINF
- Owner and deadline assigned for each data point
- Scope 1 and 2 calculated, Scope 3 assessed for materiality
- Methodology and emission factors documented
- Energy, water, waste and raw materials data reconciled with source documents
- Policy, results and risks described for each topic
- Year-over-year comparison, with variations explained
- Evidence filed for every figure, ready for the verifier
Preparing for CSRD
Companies moving towards CSRD reporting should note that the ESRS environmental standards (E1 to E5, covering climate change, pollution, water and marine resources, biodiversity and ecosystems, and resource use and circular economy) go much further than the EINF. Data you structure well today is the foundation for that transition.
How Dcycle helps
Dcycle covers the environmental pillar end to end. Connect your energy providers or upload invoices, and the platform calculates emissions with documented emission factors. With automated data collection, your data stays current throughout the year instead of being compiled in a rush at reporting time, and evidence traceability links every figure to its source document, so you can answer the verifier’s sample requests quickly. The results feed directly into your EINF project, mapped to the related GRI indicators. Request a demo to see how it works.
Frequently asked questions (FAQs)
Is Scope 3 mandatory in the EINF?
Law 11/2018 asks for greenhouse gas emissions without detailing scopes. Scope 1 and 2 are standard practice; Scope 3 is expected where it is material, and verifiers increasingly ask how you assessed it.
Can we leave out environmental topics that do not apply to us?
Yes, if a topic is not material for your activity, but you must explain why. An unexplained blank section reads as an omission.
Which methodology should we use for the carbon footprint?
The GHG Protocol is the most widely used. Whatever you choose, state it in the report and document the emission factors so the verifier can reproduce the calculation.
What evidence will the verifier ask for?
Source documents for a sample of figures: utility invoices, meter readings, waste manager certificates and fuel records, plus your calculation files and emission factor sources.
