Legislation and regulation
Carolina Skarupa
Product Carbon Footprint Analyst

To obtain an auditable carbon footprint report in Spain you need three things: calculate emissions in line with ISO 14064-1:2018 or the GHG Protocol, have them verified by a body accredited by ENAC under UNE-EN ISO/IEC 17029 and UNE-EN ISO 14065, and keep every figure traceable back to its source document.
That verified report is what public contracting authorities, customers reporting Scope 3 and financial institutions accept. Registration in the MITECO carbon footprint registry is voluntary for private companies, but it is what adds the official Calculo, Reduzco or Compenso seal.
The two words are used interchangeably, but they are not the same. Verification is the process by which an independent body reviews an emissions inventory that has already been calculated and issues a statement on whether the information is complete, accurate and consistent with the declared criteria. Certification is the commercial term normally used for the outcome: the document you can show to a third party.
Greenhouse gas verification follows ISO 14064-3, which defines two levels of assurance, limited and reasonable, and requires a materiality threshold to be set. A reasonable assurance report is more demanding and more expensive, and it is the one usually requested by customers consolidating your figure into their own Scope 3.
Before verifying, you have to calculate properly. To review the method, the formula and the official factor sources, see our guide on what a carbon footprint is and how to calculate it.
The Spanish National Accreditation Entity (ENAC) does not verify carbon footprints. What it does is accredit the bodies that do, periodically checking their technical competence, impartiality and the consistency of their procedures. It is the same organisation that accredits laboratories and inspection bodies in Spain.
For environmental validation and verification, ENAC works with two reference standards:
Within that framework, ENAC covers schemes such as organisational carbon footprints, the EU Emissions Trading System, the Carbon Border Adjustment Mechanism (CBAM, Regulation (EU) 2023/956), which explicitly requires verifiers accredited by a national accreditation body, and sustainable aviation fuels under Regulation (EU) 2023/2405.
An ENAC accreditation is what turns a verifier's statement into a document recognised outside your own company. ENAC publishes the list of accredited bodies and their scope at enac.es, and it is worth checking before you sign: accreditation is granted per scheme, not generically.
Article 202 of Spain's Public Sector Contracts Act (Ley 9/2017) requires every tender document to include at least one special performance condition, and it explicitly lists reducing greenhouse gas emissions among the environmental options. Article 145 also allows environmental characteristics to be used as an award criterion.
In practice: more and more tenders ask you to evidence your footprint or its reduction, each with slightly different wording. What usually covers almost all of them:
A common mistake is submitting a management system certificate, such as ISO 14001, assuming it will do. It will not: it certifies the system, not the emissions figure. There are more cases like this in our list of common mistakes when certifying a carbon footprint with MITECO.
| Stakeholder | What they usually ask for | Document that solves it |
|---|---|---|
| Public contracting authority | Evidence of emissions or their reduction as a special performance condition (art. 202 LCSP) or award criterion (art. 145 LCSP) | Verified report for the last financial year and, if the tender cites it, registration with the Calculo or Reduzco seal |
| Corporate customer reporting Scope 3 | Emissions attached to the product or service they buy, with method, year and declared factors | Verified ISO 14064-1 inventory plus a breakdown per unit of product or service |
| Bank or financial institution | Data for their financed emissions and their own sustainability reporting | Verified Scope 1 and 2 footprint plus a reduction plan with a quantified target |
| Sustainability or financial auditor | Data traceability and evidence behind the calculation | Working papers, source documents and a factor log with source, version and year |
| MITECO registry | Scopes 1 and 2 as a minimum, using the registry's own factors | Verified report, except for the cases in article 6.6 of RD 214/2025 |
Not exactly, and this is the most widespread confusion. Royal Decree 214/2025 requires companies to calculate their Scope 1 and 2 footprint, publish it free of charge and accessibly on their corporate website, and draw up a reduction plan with a quantified target over a minimum five-year horizon. It applies to companies that already prepare the non-financial information statement: more than 250 employees plus either public-interest entity status or exceeding, over two consecutive financial years, 20 million euros in assets or 40 million euros in turnover. MITECO has clarified that publication must happen within six months of the financial year end, in line with the non-financial statement timetable.
What the royal decree does not do is force every company to register or to verify:
Article 6.6 also recognises, alongside bodies accredited to verify GHG under ISO 14064 or the GHG Protocol, Kyoto Protocol designated operational entities and reports issued under ISAE 3410.
| Seal | What it evidences | What you have to provide |
|---|---|---|
| Calculo | That the organisation has calculated its Scope 1 and 2 footprint | The year's footprint using registry factors, a reduction plan and a verification report except in the listed cases |
| Reduzco | That it has reduced its footprint over time | Four consecutive years of data to compare two overlapping three-year periods, with the recent period's average ratio below the earlier one |
| Compenso | That it has offset part or all of its emissions | Quantified tonnes and removals purchased from projects registered in section b) of the registry, located in Spain |
The full requirements and deadlines for each are in our guide to the Calculo, Reduzco and Compenso seals, and the concrete return of being registered is covered in the benefits of registering your carbon footprint with MITECO.
Not for private companies: registration is voluntary. It is mandatory for state public sector entities from 2026. What is mandatory for companies within the scope of RD 214/2025 is calculating the footprint, publishing it and having a reduction plan.
Yes, if all its significant Scope 1 and 2 emissions have a factor published by the Spanish Climate Change Office. If it includes Scope 3 or sources without a published factor, verification is required.
It covers a specific period, normally one financial year. It does not expire, but it stops being useful as soon as the other party asks for the following year, so in practice the cycle is annual.
They do not replace it. They certify an environmental management system, not the emissions figure. RD 214/2025 does accept supplementary information from schemes such as EMAS or ISO 50001, but the document that evidences the footprint is the verification statement.
Limited assurance concludes that nothing has been found to suggest material error; reasonable assurance positively states that the information is correct within the materiality set. Reasonable assurance requires more sampling and more evidence.
The report may be technically sound, but a tender or a registry that requires accreditation will reject it. Always check the verifier's accreditation scope before engaging them.
At Manglai we calculate footprints under the GHG Protocol and ISO 14064, with every figure traceable back to its source invoice, which is exactly what a verifier asks for. If your goal is registering with the national registry, see Manglai's solution for the MITECO registry; if you need a certifiable inventory, see the ISO 14064 solution.
Carolina Skarupa
Product Carbon Footprint Analyst
About the author
Graduated in Industrial Engineering and Management from the Karlsruhe Institute of Technology, with a master’s degree in Environmental Management and Conservation from the University of Cádiz. I'm a Product Carbon Footprint Analyst at Manglai, advising clients on measuring their carbon footprint. I specialize in developing programs aimed at the Sustainable Development Goals for companies. My commitment to environmental preservation is key to the implementation of action plans within the corporate sector.
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