Practical guides
Paula Otero
Environmental and Sustainability Consultant

A carbon footprint audit is, in technical language, a verification: an independent accredited body checks that your company's greenhouse gas inventory is complete, consistent and traceable back to source documents. It follows ISO 14064-3:2019, is carried out at either a limited or a reasonable level of assurance, and ends in a verification statement you can present to Spain's MITECO registry, to a customer or to a contracting authority.
In the greenhouse gas world, “audit” is everyday shorthand. The ISO 14060 family uses two separate terms:
The standard that sets requirements for both exercises is ISO 14064-3:2019, second edition. For background on the rest of the family, see our explainer on what ISO 14064 is and what it is used for.
Not any consultancy. Verifiers must be accredited, and in Spain accreditation is granted by ENAC, which assesses validation and verification bodies under UNE-EN ISO/IEC 17029 complemented by UNE-EN ISO 14065.
Article 6.6 of Royal Decree 214/2025 sets out which verifications the MITECO carbon footprint registry recognises. The registry's support document, version 19 of April 2026, lists them:
One date worth keeping in the calendar: the IAASB approved ISSA 5000 in September 2024 as the general standard for sustainability assurance engagements, and it is set to become the sector reference. In the meantime, the MITECO registry's April 2026 support document still accepts ISAE 3410 assurance reports issued by auditors on the ROAC register.
If your installation falls under the EU Emissions Trading System, annual verification of the emissions report is governed by Implementing Regulation (EU) 2018/2067 on the verification of data and the accreditation of verifiers under Directive 2003/87/EC. That is a separate track from the voluntary MITECO registry.
The assurance level is agreed before work starts and drives cost, timing and sampling depth. It also defines what the verifier is allowed to say at the end.
| Criterion | Limited assurance | Reasonable assurance |
|---|---|---|
| Form of conclusion | Negative: nothing has come to our attention indicating material misstatement | Positive: the statement is free from material misstatement |
| Depth of work | Inquiry and analytical procedures, limited sampling | Substantive testing, wider sampling, assessment of internal control |
| Cost and duration | Lower | Considerably higher |
| Typical use | CSRD sustainability statement, MITECO registry, customer requirements | Investor reporting, financing transactions, strict contractual demands |
In the EU, the CSRD sustainability statement is subject to limited assurance. Directive (EU) 2026/470, published in the Official Journal of the European Union on 26 February 2026 and in force since 18 March 2026, removed the planned move to reasonable assurance and raised CSRD thresholds to more than 1,000 employees and more than 450 million euros in net turnover. If your company sits inside that perimeter, look at our CSRD compliance solution and at the breakdown of the 2026 Omnibus package.
Royal Decree 214/2025 requires certain companies to calculate their carbon footprint annually and to publish a reduction plan. It does not, by itself, require external verification. That obligation comes from elsewhere.
| Situation | External verification? | Basis |
|---|---|---|
| Annual calculation and reduction plan under RD 214/2025 | Not required by the decree | Article 11, RD 214/2025 |
| MITECO registration as an SME, medium sized group, association, foundation, cooperative or public entity, scopes 1 and 2, registry emission factors | Not required | Registry support document, April 2026 |
| MITECO registration when the organisation is neither an SME nor a medium sized group | Yes | Registry support document, April 2026 |
| Registration including scope 3, process emissions, or significant sources with no factor published by the registry | Yes | Registry support document, April 2026 |
| CSRD sustainability statement | Yes, limited assurance | Directive (EU) 2026/470 |
| Installation covered by the EU Emissions Trading System | Yes, annually | Implementing Regulation (EU) 2018/2067 |
The SME and medium sized group thresholds used by the registry come from Directive 2013/34/EU: not exceeding two of the three limits of 25 million euros in balance sheet total, 50 million euros in net turnover and 250 average employees. There is a practical exemption: organisations registering only scopes 1 and 2 that participate in EMAS or hold ISO 50001 can skip the GHG specific verification if they supply the certificate or audit report, the calculations, a description of boundaries, activity data, emission factors with their source and the reduction plan. The registration process itself is covered in our MITECO registry guide and in the review of the obligations introduced by RD 214/2025.
Verification is not won with a good looking report. It is won with traceability from every figure to an external document.
| Emission source | Activity data | Evidence usually requested |
|---|---|---|
| Stationary combustion in boilers and furnaces | Cubic metres of gas, litres of diesel, kg of propane | Supplier invoices, delivery notes, meter readings |
| Owned fleet | Litres refuelled or kilometres by vehicle and fuel | Fleet card statements, fuel invoices, mileage records |
| Fugitive refrigerant emissions | Kg recharged per gas and unit | Maintenance reports, fluorinated gas logs, equipment records |
| Purchased electricity | kWh per supply point and period | Electricity invoices, guarantees of origin where a market based figure is reported |
| Purchased goods and services | Spend by category or physical quantity | ERP extract with a documented cut off rule, contracts, primary supplier data |
| Transport and distribution | Tonne kilometres by mode and vehicle type | Delivery notes, logistics operator reports, carrier data |
| Business travel and commuting | Kilometres by transport mode | Travel agency reports, expense claims, documented commuting surveys |
| Waste managed | Tonnes by waste code and treatment | Transfer documents, certificates from the authorised waste manager |
Alongside the data, the verifier will review the calculation memo, the emission factor sheet with source and year, the description of organisational and operational boundaries, the list of sites included and excluded with their weight, and evidence of internal control over how data is collected and approved.
ISO 14064-3 does not set timings, because they depend on size and complexity, but it does order the stages:
Registration with MITECO is a separate administrative step afterwards. The verification statement is part of the supporting documentation, not a substitute for the application.
What makes a report auditable is the data infrastructure underneath it, not the layout. These are the capabilities that make the difference when the verifier arrives:
With those pieces in place, verification stops being an annual document rescue project. If you also need high refresh frequency, the bottleneck is the latency of the source data rather than the dashboard, as we explain in our article on real time carbon footprint data.
Not as a general rule. RD 214/2025 requires companies in scope to calculate their footprint and hold a reduction plan, not to verify it. External verification becomes mandatory to register with MITECO when the organisation is not an SME, medium sized group, association, foundation, cooperative or public entity, when scope 3 is registered, or when there are process emissions or significant sources with no factor published by the registry, and separately under the CSRD and the EU Emissions Trading System.
ISO 14064-3:2019 for verification and validation of GHG statements, applied to inventories built with ISO 14064-1:2018 or the GHG Protocol. Verification bodies are accredited under ISO/IEC 17029 and ISO 14065. In the audit profession ISAE 3410 is used; the IAASB approved ISSA 5000 in 2024 as the general standard for sustainability assurance.
No. Verification requires independence from whoever prepared the statement. If a consultancy builds your inventory, a different accredited body must verify it.
A findings process opens. If errors are correctable and are fixed within the agreed window, verification continues normally. If errors above the materiality threshold remain uncorrected, the verifier issues a modified or adverse conclusion, or none at all.
Not directly. ISO 14001 certifies an environmental management system, not the emissions figure. The MITECO registry does accept EMAS or ISO 50001 documentation instead of a GHG specific verification for scopes 1 and 2, provided additional information on boundaries, activity data, factors and the reduction plan is supplied.
Each reporting year is a separate statement. In the MITECO registry every year is processed as an independent registration with its own documentation, so where verification applies, it repeats annually.
Getting ready for verification is fundamentally a data management problem: who captures each figure, where it comes from, which factor converts it and where the evidence sits. You can see how that work is structured in Manglai's carbon footprint platform and in the ISO 14064 compliance solution, and compare the two main accounting frameworks in our analysis of the GHG Protocol versus ISO 14064-1.
Paula Otero
Environmental and Sustainability Consultant
About the author
Biologist from the University of Santiago de Compostela with a Master’s degree in Natural Environment Management and Conservation from the University of Cádiz. After collaborating in university studies and working as an environmental consultant, I now apply my expertise at Manglai. I specialize in leading sustainability projects focused on the Sustainable Development Goals for companies. I advise clients on carbon footprint measurement and reduction, contribute to the development of our platform, and conduct internal training. My experience combines scientific rigor with practical applicability in the business sector.
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