Preparing an EINF report can feel overwhelming the first time. The obligation comes from Spain’s Law 11/2018, the statement covers five pillars, it must be verified by an independent assurance provider, and the board approves it together with the annual accounts. This guide breaks the process into seven manageable steps so you know what to do, who should do it and what the verifier will ask for at each stage.
As a rule of thumb, a complete EINF cycle takes two to four months, depending on company size and how ready your data is. Start at least three months before your filing deadline: data collection always takes longer than expected.
Step 1: Determine your scope
Before you collect a single number, define your reporting boundary: which legal entities, facilities, activities and time period the statement covers. If you are part of a group, clarify whether you file individually or the parent files a consolidated EINF. A subsidiary is only covered by the group report if that report explicitly includes its operations and data, so check this rather than assume it. The guide on who needs an EINF report explains the thresholds in detail.
Owner: Finance or the sustainability lead, with sign-off from management.
Output: a one-page scope note listing the entities inside and outside the boundary, the reporting period and the consolidation criteria. Keep it: the verifier will ask for it, and every figure you report must match this boundary.
Step 2: Map your data requirements
For each of the five EINF pillars (environmental, social and employee matters, human rights, anti-corruption and bribery, and diversity), list the specific data points you need. Separate them into two types:
- Quantitative indicators: energy consumption, greenhouse gas emissions, water, waste, headcount by gender, age and country, contract types, accident rates, training hours, remuneration by gender and professional category.
- Qualitative disclosures: policies, due diligence procedures, main risks and how you manage them, complaints channels, and the results of those policies.
Many companies use a recognised framework such as the GRI Standards as the reference for each indicator, which makes the statement easier to compare and to verify. Whatever you choose, document it: the methodology is part of what gets reviewed. The article on EINF reporting requirements lists the disclosures pillar by pillar.
Step 3: Assign data owners
No single team holds all EINF data, so name one owner per data point, not just per pillar. Typical ownership looks like this:
- Environmental: Operations, Facilities, Procurement
- Social and employment: HR, Health and Safety
- Human rights: Legal, Compliance, and Procurement for the supply chain
- Anti-corruption: Legal, Compliance, Internal Audit
- Diversity: HR, Board Secretary
Agree a deadline with each owner and a single channel for submitting data and evidence. Attachments scattered across inboxes are one of the most common reasons a verifier cannot trace a figure later.
Step 4: Collect and validate data
Gather the source documents behind every figure: energy and water invoices, meter readings, waste contractor reports, HR and payroll exports, accident records, compliance reports and board minutes. Then validate before you draft:
- Completeness: no months missing, every entity in the boundary covered.
- Consistency: the same units across sites (kWh or MWh, kg or tonnes) and the same definitions across countries.
- Plausibility: compare against last year and flag values that move sharply without an explanation.
- Calculations: record the emission factors, conversion rules and allocation criteria you used.
Our EINF data collection guide explains where to find each data point.
Step 5: Draft the report
Structure the statement around the five pillars. For each one, describe the policies in place, the main risks and the results, backed by indicators. A policy description is not enough on its own: “we have a diversity policy” needs the numbers that show what it achieved. Include year-over-year comparisons wherever data allows; if this is your first year, say so and plan for comparisons from year two.
Keep an evidence index while you write, linking every figure and claim to its source document and calculation. Building it afterwards is slow and error-prone.
Step 6: Independent verification
The EINF must be verified by an independent assurance provider. Engage them early, ideally during data collection, to agree the scope, the timeline and the evidence they expect. Verifiers check four things:
- Completeness: all five pillars and the required content are covered.
- Accuracy: reported figures match the source documentation and methodologies are applied correctly.
- Consistency: numbers agree internally and with the financial statements.
- Compliance: the statement meets the requirements of Law 11/2018.
Send them an organised evidence pack and resolve their findings before board approval. Our guide to EINF audit preparation covers what verifiers look for.
Step 7: Board approval and filing
The board of directors approves the EINF, and it is filed alongside the annual financial statements as part of the management report. Keep a record of who provided, validated and approved each section: the approval chain is part of the evidence.
Common mistakes to avoid
- Starting too late: the verifier needs time, and so do the departments that own the data.
- Inconsistent scope: an entity reported in the environmental pillar but missing from the social one.
- Missing evidence: figures that nobody can trace back to an invoice, an export or a record.
- Policies without results: descriptions of commitments with no indicators behind them.
- No methodology note: emission factors and calculation rules that are not documented.
Quick checklist
- Scope note approved, with entities, period and consolidation criteria
- Data point list per pillar, with an owner and a deadline for each
- Source documents collected and validated
- Calculation methodology documented
- Evidence index linking every figure to its source
- Verifier engaged and findings resolved
- Board approval recorded
How Dcycle helps
Dcycle handles steps 2 to 6 in a single platform. EINF requirements come pre-mapped, so you can see which data points are complete, which are pending and who is responsible for each. Data collection is automated: upload invoices, import spreadsheets or connect your ERP through automated data collection, and the platform classifies the data and flags anomalies before drafting starts. In EINF/GRI projects, each figure stays linked to its source file and its GRI reference, so when the verifier asks for evidence your team finds it in the same workflow instead of searching inboxes. Request a demo to see a complete EINF project.
Frequently asked questions (FAQs)
How long does it take to prepare an EINF report?
A complete cycle usually takes two to four months, depending on company size and how ready the data is. Start at least three months before your filing deadline and engage the verifier early.
Who approves the EINF?
The board of directors approves the EINF, and it is filed together with the annual financial statements as part of the management report.
Do I need to follow a specific reporting standard?
Law 11/2018 does not impose a single standard, but many companies use the GRI Standards as a reference. Whatever framework you choose, document it so the verifier can check how each indicator was prepared.
Can a subsidiary rely on its parent company's EINF?
Only if the group's consolidated EINF explicitly covers the subsidiary's operations and data. If it does not, the subsidiary may still need to file its own statement.
