Spain’s Law 11/2018 introduced the EINF (Estado de Información No Financiera), but not every company has to file one. The thresholds are clear on paper, but group structures and the two-year rule are where companies get the answer wrong.
This guide explains who needs to file an EINF report, how to run the test and how verifiers look at it.
Mandatory reporting thresholds
Your company must file an EINF if it meets at least two of the following conditions for two consecutive financial years:
| Criterion | Threshold |
|---|---|
| Average employees | More than 250 |
| Total assets | More than €20 million |
| Net annual revenue | More than €40 million |
The obligation applies to both individual companies and consolidated groups. The employee criterion uses the average number of employees over the year, not a headcount on a single date, so companies with seasonal staff should calculate the average rather than look at the year-end payroll.
How to run the test with your own figures
- Take total assets and net revenue from the approved annual accounts of the last two financial years.
- Ask HR for the average number of employees for each of those years, calculated on the same basis both years.
- Mark each criterion as met or not met per year. You are in scope if at least two criteria are met in both years.
- Repeat the test at group level if your company is a parent, using consolidated figures.
- Write down the result, the figures used and their source. This short memo becomes part of your evidence file.
Public-interest entities
Companies classified as public-interest entities (listed companies, credit institutions and insurance companies) with more than 500 employees must report regardless of the asset and revenue thresholds above.
Group vs individual reporting
If your company belongs to a group, the parent company can file a consolidated EINF covering all subsidiaries. In this case, individual subsidiaries are exempt from filing separately, but only if the consolidated report explicitly covers their operations and data.
This is where many companies slip: a subsidiary assumes it is exempt, yet the group EINF does not include its figures. If your data is not in the consolidated report, you may still need to file individually.
When the parent company is based outside Spain, check carefully whether the group’s non-financial report actually covers the Spanish entity and meets the requirements of Law 11/2018. Organisations with complex structures should get a documented opinion on which entity bears the obligation before data collection starts.
When does the obligation start and end?
The obligation applies for the financial year in which the thresholds are met for the second consecutive year. If your company met two of the three criteria in both 2024 and 2025, you must file an EINF for fiscal year 2025.
The reverse also applies: if you fall below the thresholds for two consecutive years, the obligation ceases, although many companies keep reporting voluntarily.
Who should own the scope decision
The scope assessment touches several departments:
- Finance: total assets, net revenue and the consolidation perimeter.
- HR: the average number of employees per entity and per year.
- Legal or company secretary: public-interest entity status, group structure and the board approval process.
- Sustainability lead: turns the result into a reporting boundary and a data collection plan.
The board of directors approves the EINF, and it is filed alongside the annual financial statements as part of the management report. The scope decision should therefore reach the board early.
Common mistakes when assessing scope
- Looking at one year only. The two-year rule matters both for entering and for leaving the obligation.
- Counting employees on 31 December. Use the annual average.
- Assuming the group report covers you. Check that your entity’s data is actually included.
- Leaving the boundary undocumented. If you cannot explain which entities, facilities and operations are in scope, the verifier will ask.
- Deciding too late. Preparing an EINF typically takes two to four months.
How verifiers look at scope
The EINF must be verified by an independent assurance provider. Verifiers check completeness, accuracy, consistency with the financial statements and compliance with Law 11/2018. Scope sits at the root of all four: if the reporting boundary differs from the consolidation perimeter in the annual accounts, or if an entity is covered in the environmental pillar but missing from the social one, expect questions.
In the EINF projects we support, the smoothest verifications start with a one-page boundary note: entities included, the reason for any exclusion, and the figures behind the threshold test. Our EINF audit preparation guide covers the rest of the evidence pack.
Voluntary reporting
Companies below the thresholds can file an EINF voluntarily, increasingly because clients, public tenders and investors ask for ESG data.
It also builds the processes you will need if you grow into the mandatory thresholds.
Relationship with the CSRD
The CSRD is progressively replacing national non-financial reporting requirements across the EU. Spanish companies meeting CSRD thresholds will move from the EINF to reporting under the European Sustainability Reporting Standards (ESRS). Most of the data you collect for the EINF today feeds directly into CSRD reporting.
Scope checklist
- Assets, revenue and average employees for the last two financial years, from approved accounts
- Public-interest entity status confirmed
- Group structure mapped and consolidated test run
- Confirmation that any group EINF explicitly covers your entity
- Reporting boundary documented and aligned with the consolidation perimeter
- Owners named in Finance, HR, Legal and Sustainability
- Timeline agreed so the EINF is ready for board approval with the annual accounts
How Dcycle helps
Dcycle’s sustainability experts help you scope your obligation, define the reporting boundary and plan data collection per entity. Once you know you need to report, the platform collects data from ERPs, invoices and spreadsheets across your facilities, and every figure keeps a link to its source document for the verifier. For the full picture of what goes into the report, see what the EINF is and our step-by-step preparation guide. Request a demo to get started.
Frequently asked questions (FAQs)
Which entities must report non-financial information under the EINF thresholds?
Under Spain's Law 11/2018, companies and groups must report when they meet at least two of the three size criteria (more than 250 average employees, more than €20 million in total assets, more than €40 million in net revenue) for two consecutive financial years. Public-interest entities with more than 500 employees must report regardless of the size criteria.
Is a subsidiary exempt if its parent files a group EINF?
Only if the consolidated EINF explicitly covers the subsidiary's operations and data. If the subsidiary's figures are not included in the group report, it may still need to file individually.
Can a company stop filing the EINF?
Yes. If the company falls below the thresholds for two consecutive financial years, the obligation ceases. Many companies keep reporting voluntarily because clients and investors still ask for the information.
Does a voluntary EINF need the same structure as a mandatory one?
There is no shortcut format. A voluntary report earns credibility when it covers the same five pillars, uses the same methodologies and keeps the same evidence trail as a mandatory EINF, which also makes the move to mandatory reporting much easier.
