Legislation and regulation
Jaume Fontal
CPTO & Co-Founder
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As of August 2026, a company operating in Spain lives with four blocks of environmental regulation: climate and reporting (Royal Decree 214/2025, CSRD after Omnibus, CBAM, ETS2), waste and packaging (Law 7/2022, PPWR), product and supply chain (ESPR, EUDR, CSDDD) and mobility (Law 9/2025). On top of that sit environmental taxes and the rules on green claims.
This guide gathers every one of those rules in a single table, with its scope, who it applies to, from when and what it requires, and then develops each block with the dates that belong in your calendar.
| Rule | Scope | Who it applies to | From when | What it requires |
|---|---|---|---|---|
| Law 7/2021 on climate change and energy transition | Spain | Companies and the public sector | 2021 | Sets climate neutrality by 2050 and enables the carbon footprint and reduction plan duties |
| Royal Decree 214/2025 | Spain | Companies with more than 250 employees that are public interest entities or exceed 20 M€ in assets or 40 M€ in turnover for two financial years; the state administrative public sector | Financial year 2025, published in 2026 | Calculate the Scope 1 and 2 footprint and publish a reduction plan with a minimum five-year horizon. Registry entry is voluntary for private companies |
| CSRD, Directive (EU) 2022/2464, amended by Directive (EU) 2026/470 | EU | Companies with more than 1,000 employees and more than 450 M€ in net turnover | First reporting year 2027. Transposition by 19 March 2027 | Sustainability report under the ESRS, with limited assurance |
| Law 11/2018 and the non-financial information statement | Spain | Companies already reporting | 2018 | Still the applicable regime until the Spanish Sustainability Reporting Act is passed |
| CSDDD, Directive (EU) 2024/1760, amended by Directive (EU) 2026/470 | EU | Companies with 5,000 employees and 1.5 bn€ in worldwide turnover | Transposition 26 July 2028, application 26 July 2029 | Human rights and environmental due diligence across the chain of activities. Omnibus removed the duty to adopt and implement a climate transition plan |
| Taxonomy, Regulation (EU) 2020/852 | EU | Companies in CSRD scope and financial institutions | 2022, simplified by Omnibus | Disclose what share of activity is eligible and aligned |
| CBAM, Regulation (EU) 2023/956, amended by Regulation (EU) 2025/2083 | EU | Importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen | Definitive regime since 1 January 2026 | Become an authorised declarant, declare by 30 September and buy certificates from 2027. Exemption below 50 tonnes per year |
| ETS2 | EU | Suppliers of fuels for buildings and road transport | Auctions from 2027, fully operational in 2028 | Surrender allowances for fuel released for consumption, with pass-through to end prices |
| Directive (EU) 2024/825 on empowering consumers | EU | Companies making environmental claims to consumers | Applies from 27 September 2026 | Bans generic and unsubstantiated environmental claims and regulates sustainability labels |
| PPWR, Regulation (EU) 2025/40 | EU | Packaging manufacturers, importers and distributors | Applies from 12 August 2026 | Recyclability, packaging minimisation, recycled content and harmonised labelling |
| Law 7/2022 on waste and contaminated soil | Spain | Waste producers and product producers | 2022 | Extended producer responsibility, the non-reusable plastic packaging tax and the landfill and incineration tax |
| Law 9/2025 on sustainable mobility and Royal Decree-Law 7/2026 | Spain | Companies with more than 200 employees or more than 100 per shift | Plan approved before 5 December 2026 | Workplace sustainable mobility plan negotiated with employee representatives |
| ESPR, Regulation (EU) 2024/1781 | EU | Manufacturers and importers, by product group | Phased. Battery passport from 18 February 2027 | Ecodesign requirements and the digital product passport |
| EUDR, Regulation (EU) 2023/1115, amended by Regulation (EU) 2025/2650 | EU | Operators and traders of seven deforestation-linked commodities | 30 December 2026 for large and medium companies. 30 June 2027 for micro-enterprises and natural persons for remaining products | Deforestation-free due diligence with plot geolocation |
| Directive (EU) 2024/3019 on urban wastewater | EU | Municipalities and, through extended producer responsibility, the pharmaceutical and cosmetics sectors | Transposition by 31 July 2027 | Quaternary treatment funded by micropollutant producers |
| Law 2/2023 on whistleblower protection | Spain | Companies with 50 or more employees | 2023 | Internal reporting channel and documented investigations |
| ISO 14001:2026 | International, voluntary | Any organisation | Published 15 April 2026 | Environmental management system, now weighted towards climate, biodiversity and the value chain |
Directive (EU) 2026/470, known as Omnibus I, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. Its effect is to narrow scope, not content.
The detail is in our analysis of the ESG Omnibus in 2026. If you need to separate what the directive asks for from what the standards ask for, the guide to CSRD and ESRS differences sorts it out.
Even with the CSRD narrowed, Spain keeps a climate obligation that reaches many more companies: Royal Decree 214/2025. It requires companies that report non-financial information to calculate their Scope 1 and 2 footprint and publish a reduction plan with a quantified target and a minimum five-year horizon, within six months of the end of the financial year. The reference year is 2025.
Do not confuse that duty with the registry. Entering the MITECO carbon footprint registry remains voluntary for private companies, and is only mandatory for the General State Administration and its administrative public sector, from 2026.
Spain's CSRD transposition is not finished: the Sustainability Reporting Bill is still going through parliament and, in the meantime, the non-financial information statement regime under Law 11/2018 still applies. There are additional regional duties, covered in our review of environmental legislation at regional level.
On imports, CBAM entered its definitive phase on 1 January 2026. Regulation (EU) 2025/2083 introduced a de minimis threshold of 50 tonnes of net mass per importer per year, which leaves most small importers of cement, iron and steel, aluminium and fertilisers outside the regime. Electricity and hydrogen do not benefit from that threshold: they are always covered.
Regulation (EU) 2025/40 on packaging and packaging waste is this summer's headline: it applies from 12 August 2026 and replaces the old directive with directly applicable requirements on recyclability, empty space minimisation, recycled content and harmonised labelling. We break it down in our guide to what your business needs for the PPWR.
In Spain it overlaps with Law 7/2022 on waste and contaminated soil and with Royal Decree 1055/2022 on packaging, which extended producer responsibility to commercial and industrial packaging. The usual duties are registering as a producer, joining a collective scheme or setting up an individual one, declaring the quantities placed on the market and documenting waste traceability.
Law 9/2025 on sustainable mobility requires companies with more than 200 employees, or more than 100 per shift, to have a workplace sustainable mobility plan negotiated with employee representatives. Royal Decree-Law 7/2026 brought the deadline forward by a year: the plan must be approved before 5 December 2026. Non-compliance is classified as a minor infringement, with fines from 101 to 2,000 euros, and can trigger the return of public aid. It is developed in our article on the workplace mobility plan after Royal Decree-Law 7/2026.
Add to that low emission zones in municipalities above 50,000 inhabitants, the Euro 7 standard for new vehicles and, for transport emissions accounting, ISO 14083:2023, which underpins the GLEC Framework and the CountEmissions EU initiative.
The full map, including available deductions, is in our guide to green taxation in Spain.
The Green Claims Directive is not law: the European Commission withdrew the proposal in June 2025 and it is no longer going through the legislative process. What does apply is Directive (EU) 2024/825 on empowering consumers for the green transition, which had to be transposed by 27 March 2026 and applies from 27 September 2026. It bans generic environmental claims without recognised substantiation, climate neutrality claims based only on offsetting, and sustainability labels that do not come from a certification scheme.
At a minimum, Law 7/2021 on climate change, Law 7/2022 on waste with its associated taxes, the PPWR from 12 August 2026 if you place packaging on the market, and Law 9/2025 on sustainable mobility above 200 employees. If you also report non-financial information, Royal Decree 214/2025 applies. If you import carbon-intensive goods, CBAM does.
Only if it exceeds 1,000 employees and 450 million euros in net turnover. Directive (EU) 2026/470 removed the vast majority of the companies that sat in waves 2 and 3. For those still in scope, the first reporting year is 2027.
Yes for companies that report non-financial information, under Royal Decree 214/2025, which also requires publishing a five-year reduction plan. Registering it with MITECO is a separate matter and remains voluntary for the private sector.
The Commission withdrew the proposal in June 2025, so it never became law and it is no longer in the legislative pipeline. Greenwashing control now rests with Directive (EU) 2024/825, applicable from 27 September 2026.
12 August 2026 for the PPWR, 27 September 2026 for environmental claims, 5 December 2026 for workplace mobility plans, 30 December 2026 for the EUDR, 18 February 2027 for the battery passport and 19 March 2027 for Omnibus transposition.
If you would rather bring emissions calculation, documentation and reporting into a single flow instead of chasing each rule separately, see how Manglai approaches CSRD compliance and the other frameworks.
Jaume Fontal
CPTO & Co-Founder
About the author
Jaume Fontal is a technology professional who currently serves as CPTO (Chief Product and Technology Officer) at Manglai, a company he co-founded in 2023. Before embarking on this project, he gained experience as Director of Technology and Product at Colvin and worked for over a decade at Softonic. At Manglai, he develops artificial intelligence-based solutions to help companies measure and reduce their carbon footprint.
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