EINF reporting requirements are set by Spain’s Law 11/2018, which asks companies in scope to disclose structured information across five pillars: environmental matters, social and employee matters, human rights, anti-corruption and bribery, and diversity. Each pillar combines quantitative data (metrics and KPIs) with qualitative descriptions (policies, risks and due diligence), and an independent verifier checks both.
This guide lists what to report under each pillar, which team usually owns it, and where companies most often fall short. If you are not yet sure your company is in scope, start with who needs to file an EINF.
How to read each pillar
For every pillar, the EINF expects three layers:
- Policies: what the company has committed to and how it manages the topic.
- Risks: the main risks linked to the topic and how they are mitigated.
- Results: metrics and outcomes, ideally with a year-over-year comparison.
A common weakness is to describe policies without numbers. “We have a diversity policy” is not enough; the verifier will look for the figures that show what the policy achieved.
1. Environmental matters
This is usually the most data-intensive pillar.
- Greenhouse gas emissions: Scope 1 (direct), Scope 2 (indirect from purchased energy) and, where material, Scope 3 (value chain).
- Energy consumption: total consumption in MWh or GJ, breakdown by source (electricity, gas, diesel, renewables) and energy efficiency measures.
- Water consumption: total use, sources and wastewater discharge.
- Pollution: measures to prevent and mitigate air, water and soil pollution.
- Circular economy: waste by type (hazardous and non-hazardous), recycling rates and waste prevention initiatives.
- Biodiversity: impact on protected areas and conservation measures.
- Climate change: risks, adaptation measures and carbon reduction targets.
You should also state the methodology behind each calculation, for example the GHG Protocol for emissions. Owners: operations, facilities and procurement, with the sustainability team consolidating. Evidence: energy and fuel invoices, meter readings, waste manager certificates and water bills. Our EINF environmental reporting guide goes deeper into this pillar.
2. Social and employee matters
- Employment: headcount by gender, age and country; contract types (permanent, temporary, part-time); turnover and new hires.
- Work organisation: working hours, flexible work arrangements, disconnection policies and work-life balance measures.
- Health and safety: occupational accident frequency and severity rates, work-related illness and prevention measures.
- Social dialogue: collective bargaining coverage, employee representation and consultation procedures.
- Training: total training hours, average hours per employee and professional development programmes.
- Accessibility: measures for persons with disabilities and universal accessibility initiatives.
- Equal pay: remuneration by gender and professional category, and pay gap analysis.
Owners: HR, payroll and the health and safety function. Evidence: HR system exports, payroll data, accident registers and training records. The key risk here is consistency: headcount in the EINF should be explainable against the figures in the annual accounts.
3. Human rights
- Due diligence: human rights risk assessment, both internally and across the value chain.
- Risk prevention: measures to prevent and mitigate human rights violations.
- Complaints mechanisms: grievance and whistleblowing channels, with cases reported and resolved.
- Supply chain oversight: human rights criteria in supplier selection and monitoring.
Owners: compliance, procurement and HR. Evidence: risk assessments, supplier questionnaires or codes of conduct, and the case log of the complaints channel.
4. Anti-corruption and bribery
- Policies: anti-corruption and anti-bribery policies and the code of conduct.
- Compliance programmes: training, risk assessments and internal controls.
- Whistleblowing: channels for reporting irregularities and protections for whistleblowers.
- Outcomes: confirmed incidents, legal proceedings and sanctions imposed.
- Political contributions: donations and lobbying activities, where applicable.
Owners: compliance and legal. Evidence: approved policies, training attendance, the incident log and board minutes. See our guide to EINF governance and anti-corruption for detail on what to disclose.
5. Diversity
- Board composition: gender, age range, professional background and nationality of board members.
- Diversity policy: objectives, implementation measures and progress.
- Pay gap: remuneration differences by gender and job category.
- Inclusion measures: policies promoting diversity beyond the board.
Owners: company secretary, HR and the board itself. Evidence: board composition records, the diversity policy and pay data.
What verifiers look for
The EINF must be verified by an independent assurance provider, currently at a limited assurance level. That is less rigorous than a financial audit, but it still requires substantial evidence. Verifiers focus on:
- Completeness: are all five pillars and the mandatory data points covered?
- Accuracy: do reported figures match source documents, and are methodologies applied correctly?
- Consistency: do numbers align across sections and with the financial statements?
- Compliance: does the report meet the requirements of Law 11/2018?
In practice, every data point should be traceable to a source document such as an invoice, meter reading or HR record. Our EINF audit preparation guide explains how to build that evidence pack.
Common mistakes
- Policies without results. The EINF needs outcomes and metrics, not only descriptions.
- Inconsistent scope. Every entity in the reporting boundary should be covered across all five pillars.
- Missing evidence. Gathering source documents after the fact is slow and error-prone.
- No methodology. State how each figure was calculated, especially emissions.
- No comparison. Verifiers expect trend data. In your first year, say so and plan comparisons from year two.
- Ignoring Scope 3. It is not always mandatory, but value chain emissions are increasingly expected.
Disclosure checklist
- Reporting boundary defined and applied to all five pillars
- An owner named for every pillar and data point
- Environmental data with stated methodology and source documents
- Social data reconciled with HR and payroll records
- Human rights and anti-corruption policies, risks and outcomes documented
- Board composition and pay gap data ready
- Year-over-year comparison included, or first-year status stated
- Evidence linked to every figure before the verifier starts
How Dcycle helps
Dcycle pre-maps every EINF requirement across the five pillars, so you can see which data points are complete, which are pending and who is responsible. Automated data collection reads invoices, ERP exports and spreadsheets and maps them to the right requirement, and evidence traceability keeps each figure linked to its source document, calculation and approval. Data collected for the EINF can also feed carbon footprint, CSRD or GRI-based projects. Request a demo to see it with your own data.
Frequently asked questions (FAQs)
What are the five pillars of the EINF?
Environmental matters, social and employee matters, human rights, anti-corruption and bribery, and diversity. Each pillar requires policies, risks and results, combining qualitative descriptions with quantitative metrics.
Is Scope 3 mandatory in the EINF?
Scope 1 and Scope 2 emissions are expected. Scope 3 is reported where material. It is not always mandatory, but verifiers and stakeholders increasingly expect value chain emissions such as business travel, commuting and purchased goods.
Does the EINF require a specific reporting standard?
Law 11/2018 does not impose a single mandatory standard, but you must state the methodology behind each figure. Many companies use GRI as a reference framework and the GHG Protocol for emissions.
What level of assurance applies to the EINF?
The EINF is verified by an independent assurance provider at a limited assurance level. It is less rigorous than a financial audit, but every figure still needs a source document and a clear methodology.
