ESG Compliance in Spain: Sustainability Obligations

We design and implement your ESG compliance program: sustainability reporting (CSRD), value chain due diligence (CSDDD), the EU Taxonomy, ESG governance and training. Comply with the rules without slowing down your business.

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SFDR product classification
Arts. 6, 8 and 9
GHG emission scopes
Scope 1, 2 and 3
Implementation steps
10 steps
Key regulation
CSRD

ESG compliance by your type of company

Listed companies, SMEs in the value chain, the financial sector or industry: each profile has different ESG obligations and different deadlines.

Listed companies

Mandatory CSRD reporting and Taxonomy

"Large listed companies are the first in scope: a sustainability report under the ESRS standards, double materiality, Taxonomy and assurance by an independent auditor."

Financial sector

SFDR, Taxonomy and ESG risk

"Banks, asset managers and insurers must integrate ESG factors into investment decisions (SFDR), classify financial products and report sustainability risks."

SMEs in value chains

Indirect impact and due diligence

"Even if you are not directly in scope, if you supply a company subject to the CSDDD or the CSRD, you will be asked for ESG data, questionnaires and evidence of compliance."

Industry

Carbon footprint and circular economy

"Industrial ESG compliance means measuring and reducing emissions (Scope 1, 2 and 3), managing waste, complying with environmental law and demonstrating traceability in the supply chain."

What happens if you fall short on ESG?

Failing to comply with ESG rules leads to penalties, exclusion from financing, lost contracts and severe reputational damage.

Regulatory penalties: the CSRD and the CSDDD provide for penalty regimes with fines proportionate to the company's turnover.

Exclusion from financing: banks and investment funds apply ESG screens. Without proper reporting, your company may be left out of credit lines and funding rounds.

Lost contracts and value chain exclusion: large companies require ESG compliance from their suppliers. Failing to comply can mean being dropped from the supply chain.

Greenwashing Reputational risk

Unsupported sustainability claims lead to lawsuits, consumer protection penalties and reputational crises, with a direct impact on sales and valuation.

CSDDD Civil liability

The CSDDD introduces civil liability for damage resulting from a failure to carry out human rights and environmental due diligence.

CSRD From 2024–2026

CSRD reporting is being phased in: large listed companies (2024), large unlisted companies (2025) and listed SMEs (2026).

Does your company need ESG compliance?

We assess your situation, identify your obligations and design a workable ESG compliance program: CSRD reporting, due diligence, Taxonomy, governance and training.

ESG compliance: common questions

What is ESG compliance?

ESG compliance is the set of policies, procedures and controls a company puts in place to comply with the rules on the environment (E), social responsibility (S) and corporate governance (G).

It covers sustainability reporting, value chain due diligence, integrating ESG risks into business management and preventing greenwashing.

What is the CSRD and who does it affect?

The CSRD (Corporate Sustainability Reporting Directive) is the EU directive that requires companies to publish a detailed sustainability report under the ESRS standards.

It is being phased in for large listed companies (from 2024), large unlisted companies (from 2025) and listed SMEs (from 2026). The report must be verified by an independent auditor.

What is the CSDDD (due diligence)?

The CSDDD (Corporate Sustainability Due Diligence Directive) requires large companies to identify, prevent, mitigate and account for adverse impacts on human rights and the environment in their value chain.

It includes the obligation to set up complaints mechanisms, climate transition plans and civil liability for damage resulting from a failure to carry out due diligence.

What is double materiality?

Double materiality is the approach the CSRD requires for ESG reporting. It requires sustainability matters to be assessed from two perspectives:

  • Impact materiality: how the company's activities affect the environment, people and society.
  • Financial materiality: how ESG factors affect the company's financial position, performance and cash flows.

A matter is material (and must be reported) if it is relevant from either perspective.

What is the EU Taxonomy?

The Taxonomy Regulation sets up a classification system for sustainable economic activities. Companies subject to the CSRD must report what percentage of their turnover, capex and opex is Taxonomy-aligned.

  • Eligibility: whether the activity is covered by the Taxonomy.
  • Alignment: whether it meets the technical criteria for substantial contribution and DNSH (Do No Significant Harm).
  • Minimum social safeguards.
What is greenwashing and how can you avoid it?

Greenwashing is the practice of making misleading or unsubstantiated sustainability claims. The EU is regulating this practice through the Green Claims Directive and the Empowering Consumers Directive.

  • Every environmental claim must be backed by verifiable evidence.
  • Generic labels ("eco-friendly", "green") are banned without recognized certification.
  • Penalties can include fines, product withdrawals and consumer collective actions.
How does ESG affect SMEs?

SMEs can be affected directly (listed SMEs, from 2026 under the CSRD) or indirectly (as suppliers to companies subject to the CSDDD or the CSRD). In practice, more and more large companies require their suppliers to provide ESG data, sustainability questionnaires and evidence of compliance.

Getting ahead with a basic ESG compliance program is a competitive advantage and a requirement for keeping business relationships with large customers.

How does ESG relate to sustainable finance?

ESG compliance ties directly into the EU sustainable finance framework:

  • SFDR: financial market participants must classify their products by their degree of sustainability (Arts. 6, 8 and 9).
  • Taxonomy: funds and financial products must report their degree of alignment with sustainable activities.
  • Green bonds (EU GBS): the European standard for green bonds, with Taxonomy alignment requirements.

A practical guide to ESG compliance

An effective ESG compliance program is not an annual report: it is a management system built into operations, with governance, metrics, evidence and continuous improvement.

Environmental

E: environment and climate

Carbon footprint (Scope 1, 2 and 3), climate transition plan, circular economy, waste management, biodiversity and EU Taxonomy alignment.

Social

S: people and the value chain

Labor rights, equality, diversity and inclusion, health and safety, impact on communities and human rights due diligence across the value chain.

Governance

G: governance and ethics

Board structure, independence, remuneration, anti-corruption, whistleblowing channel, conflict of interest management and board-level ESG oversight.

Checklist: 10 steps to implement ESG compliance

  1. Initial assessment: evaluate the company's ESG maturity and the applicable regulatory obligations.
  2. Double materiality analysis: identify the relevant ESG matters from the impact and financial perspectives.
  3. ESG governance: set up a sustainability committee, assign responsibilities and define reporting lines to the board.
  4. ESG policies: develop environmental, social and governance policies built into the corporate strategy.
  5. Due diligence: implement processes to identify, prevent and mitigate impacts in the value chain (CSDDD).
  6. Metrics and KPIs: define quantitative and qualitative indicators under the ESRS for each material matter.
  7. EU Taxonomy: assess the eligibility and alignment of economic activities and calculate the reporting ratios.
  8. CSRD reporting: prepare the sustainability report under the ESRS, with double materiality and integrated Taxonomy disclosures.
  9. Assurance: obtain limited (or reasonable) assurance from an independent auditor on the sustainability report.
  10. Training and continuous improvement: train the team by role, review the program regularly and close gaps.

If you need help with your ESG compliance program, see our corporate compliance services or request a free consultation.

ESG in practice

ESG compliance: from policy to management system

An effective ESG compliance program translates into repeatable decisions, traceable metrics and auditable evidence. These are the operational building blocks we design and oversee.

ESG compliance: double materiality1) Materiality

Double materiality: the starting point

Identify which ESG matters are relevant from the impact and financial perspectives. This defines the scope of reporting and the program's priorities.

  • Impact materiality
  • Financial materiality
  • Stakeholder engagement
ESG compliance: metrics and KPIs2) Metrics

ESG KPIs and data collection

Define quantitative indicators (emissions, consumption, ratios) and qualitative ones (policies, processes, governance) under the ESRS. Set up reliable data collection systems.

  • Indicators by ESRS topic
  • Data collection systems
  • Data quality and traceability
ESG compliance: value chain3) Value chain

Due diligence and supplier management

Identify, assess and mitigate ESG risks in the supply chain. Questionnaires, assessments, action plans and follow-up backed by evidence.

  • Value chain mapping
  • ESG risk assessment
  • Mitigation plans
ESG compliance: level of obligationBy type of company

Your level of ESG obligation by profile

Large listed company

CSRD + Taxonomy + CSDDD + SFDR (if a financial entity). Mandatory reporting since 2024.

Large company

CSRD from 2025. CSDDD if above the thresholds. Taxonomy in reporting.

SME

Voluntary CSRD (or from 2026 if listed). Indirect impact through the value chain.

ESG playbook

ESG compliance: what each regulation requires

Regulation
What it requires
Typical evidence

CSRD

Sustainability report with double materiality, ESRS metrics, integrated Taxonomy disclosures and external assurance.

Published report, materiality analysis, ESRS data, auditor's report.

CSDDD

Human rights and environmental due diligence in the value chain: identify, prevent, mitigate, report.

Due diligence policy, value chain mapping, risk assessments, action plans, complaints mechanism.

EU Taxonomy

Classify activities as eligible/aligned. Report the aligned turnover, capex and opex ratios.

Eligibility analysis, assessment of technical criteria (DNSH), ratio calculation, supporting documentation.

SFDR

Classify financial products (Art. 6/8/9), report PAI indicators and sustainability risk policies.

Pre-contractual documents, website disclosures, periodic reports, ESG risk integration policies.

Green Claims

Every environmental claim must be substantiated, verified and not misleading. Generic labels are banned.

Scientific evidence for the claim, recognized certification, review of communications and advertising.

ESG compliance red flags

If you spot any of these situations, it is worth reviewing your ESG compliance program.

  • You do not have a documented, up-to-date double materiality analysis.
  • Your ESG data has no traceability and no structured collection system.
  • You have not mapped the ESG risks in your supply chain.
  • Your sustainability communications are not backed by verifiable evidence.
  • The board has no visibility or active oversight of material ESG matters.
Glossary

Key ESG compliance concepts

If you are implementing an ESG compliance program, these terms come up in the legislation, in audits and in day-to-day operations.

ESGBasics

Environmental, Social & Governance

A framework for assessing corporate sustainability that integrates environmental, social and governance factors into management and corporate reporting.

The basis of ESG compliance and sustainable finance.
CSRDReporting

Corporate Sustainability Reporting Directive

EU directive requiring companies to publish a detailed sustainability report using the ESRS standards, double materiality and external assurance.

Replaces the NFRD. Phased application 2024–2026.
ESRSStandards

European Sustainability Reporting Standards

Technical reporting standards developed by EFRAG that set the content, metrics and structure of the sustainability report under the CSRD.

12 topical standards: E1–E5, S1–S4, G1.
CSDDDDue Diligence

Corporate Sustainability Due Diligence Directive

Directive requiring large companies to carry out human rights and environmental due diligence in their value chain.

Includes civil liability and a transition plan.
TaxonomyClassification

EU Taxonomy Regulation

A classification system for sustainable economic activities. Criteria for substantial contribution to climate/environmental objectives and DNSH.

Mandatory reporting for companies subject to the CSRD.
SFDRFinance

Sustainable Finance Disclosure Regulation

Regulation requiring financial market participants to classify products and report sustainability risks and indicators (PAI).

Article 6, 8 and 9 products. Applies to asset managers, banks and insurers.
Double materialityCore

A two-perspective approach

Assessing ESG matters from the impact perspective (inside-out) and the financial perspective (outside-in). The basis of the materiality analysis under the CSRD.

A matter is material if it is relevant from either perspective.
GreenwashingRisk

Misleading sustainability communication

Unsubstantiated, exaggerated or misleading environmental or social claims. The EU regulates this practice through the Green Claims Directive.

Risk: penalties, lawsuits and reputational crises.
Scope 1/2/3Emissions

GHG emission scopes

Scope 1: direct emissions. Scope 2: indirect emissions from purchased energy. Scope 3: the rest of the value chain (upstream and downstream). Scope 3 is usually the hardest to measure.

Mandatory reporting under ESRS E1 (climate).

ESG COMPLIANCE CONSOLE

ESG compliance dashboard: maturity and obligations by profile

How demanding ESG compliance is depends on the company's size, listing status and sector. This dashboard summarizes the main obligations and their level of impact.

ESG obligations matrix by type of company

Prioritize according to your profile and get ahead of the obligations that are coming.

Regulation
Large listed company
Large company
SME
CSRD
MandatoryFrom 2024
MandatoryFrom 2025
ListedFrom 2026
CSDDD
MandatoryAbove thresholds
By sizePhased in
IndirectValue chain
Taxonomy
ReportingRatios required
ReportingIf under CSRD
VoluntaryRecommended

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Tell us about your situation and we will explain how to put ESG compliance into practice in your company.

ESG compliance: the EU sustainability regulatory framework

ESG compliance (Environmental, Social & Governance) has become a legal obligation for a growing number of European companies. The European Union has rolled out an ambitious package of sustainability legislation that is changing how companies measure, manage and report their environmental, social and governance impacts.

CSRD: the new sustainability reporting

The CSRD (Corporate Sustainability Reporting Directive) replaces the former NFRD and dramatically expands the number of companies required to publish a detailed sustainability report. The report must be prepared under the ESRS standards (European Sustainability Reporting Standards), apply the principle of double materiality and be included in the management report. Assurance by an independent auditor is mandatory.

CSDDD: due diligence in the value chain

The CSDDD (Corporate Sustainability Due Diligence Directive) requires large companies to put in place due diligence processes to identify, prevent and mitigate adverse impacts on human rights and the environment throughout their value chain. It introduces civil liability for damage and requires a climate transition plan aligned with the Paris Agreement.

The EU Taxonomy and sustainable finance

The Taxonomy Regulation sets up a classification system for sustainable economic activities that serves as a reference for corporate reporting, investment and financial products. Companies subject to the CSRD must report what percentage of their turnover, capex and opex is aligned with the Taxonomy. The sustainable finance framework is completed by the SFDR (for asset managers and financial institutions) and the European Green Bond Standard (EU GBS).

Greenwashing prevention

The Green Claims Directive and the Empowering Consumers Directive regulate sustainability claims in marketing communications. Every environmental claim must be substantiated, verified and not misleading. Companies must review their advertising, labeling and ESG communications to avoid penalties and reputational damage.

ESG CSRD ESRS CSDDD EU Taxonomy SFDR Green Claims Greenwashing