CLARIFYING NOTE ON ROYAL DECREE 214/2025:
In December 2025, the Ministry for the Ecological Transition and the Demographic Challenge published a clarifying note on Royal Decree 214/2025, legislation that represents a decisive step in the fight against climate change. This decree regulates the registry of the “huella de carbono, compensación y proyectos de absorción de CO₂” (carbon footprint, offsetting and CO₂ absorption projects) and introduces specific sustainability obligations for companies.
The note aims to resolve doubts and to specify key aspects for the correct application of the decree: who is required to comply with it, what actions have to be carried out, what the deadlines are and how the information must be published. It also strengthens the link with European and international commitments, such as the Paris Agreement and the objective of climate neutrality by 2050.
In a context where transparency and environmental responsibility are increasingly valued by customers, investors and society, this legislation is not only a legal requirement, but also a strategic opportunity for companies that want to position themselves as benchmarks in sustainability.
Why is this note relevant?
Royal Decree 214/2025, approved in March and published in April, establishes that certain companies must calculate their carbon footprint and draw up an emissions reduction plan. The clarifying note specifies essential aspects: who is required to comply, what the scope of the calculation is, deadlines, publication and application within corporate groups. This provides legal certainty and helps organisations prepare to comply with the legislation.
Who has to comply with the legislation?
Under article 11 of the decree, the obliged parties are those companies that already have to submit non-financial information (EINF), that is:
- Companies with more than 250 employees.
- Companies with assets above 20 million euros or annual turnover above 40 million euros.
This criterion ensures that large corporations, with the greatest environmental impact, are the first to take on climate responsibilities.
What are the main obligations?
The legislation establishes two fundamental requirements:
Annual calculation of the carbon footprint
- It covers Scope 1 and 2 (direct and indirect energy emissions).
- Scope 3 is voluntary.
- The calculation must follow the Ministry’s official emission factors.
- The reference period is 12 consecutive months.
Emissions reduction plan
- It must set a quantified target over 5 years.
- Compatible with the Paris Agreement and 2050 climate neutrality.
- Include concrete measures to achieve the reduction.
- If the company already has a plan in force that meets the requirements, it can continue to apply it.
Timetable and deadlines
- Companies will have to adapt from 2026, with information relating to the 2025 financial year.
- The deadline for submitting the calculation and the plan coincides with that of the EINF: six months after the close of the financial year.
Publication and transparency
The information on the carbon footprint and the reduction plan must be published free of charge and in an accessible manner on the corporate website for five years. This measure strengthens transparency and allows consumers and investors to assess companies’ climate commitment.
Benefits for companies
Complying with this legislation is not only a legal obligation: it is an opportunity to improve energy efficiency, reduce operating costs and access green finance. It also strengthens corporate reputation and positions the company as a leader in sustainability, a factor increasingly valued by customers and investors.
Alignment with Europe
This decree falls within EU Directive 2022/2464 on sustainability reporting and Regulation (EU) 2021/1119, which sets the objective of climate neutrality by 2050. Spain is thus moving towards a low-carbon economy, in tune with European policies.