Carbon footprint registry: what changes under Royal Decree 214/2025

Royal Decree 214/2025 of 18 March completely renews MITECO's Registry of carbon footprint, offsetting and carbon dioxide absorption projects. It repeals and replaces the earlier Royal Decree 163/2014 and, in addition, introduces the obligation to calculate the carbon footprint and publish a reduction plan for large companies and the state public sector.

It was published in Spain's Official State Gazette on 12 April 2025 and entered into force on 12 June 2025. Below we review the key changes and how they affect organisations.

Mandatory carbon footprint calculation and reduction plan

The main change is the obligation to calculate the carbon footprint and to prepare an emissions reduction plan with a minimum horizon of five years and quantified targets. This obligation falls on organisations that already have to file a non-financial statement, that is:

• Companies with more than 250 employees that are public-interest entities, or that exceed, for two consecutive financial years, €20 million in total assets or €40 million in net turnover.
• Ministerial departments, autonomous agencies and other entities of the state administrative public sector.

Both groups must publish the footprint and the plan free of charge and accessibly on their website. Companies meet this obligation through their sustainability report and are not required to enter the registry, which remains voluntary for the private sector; the state public sector does have to register its footprint annually.

According to the clarifying note published by MITECO in December 2025, the footprint and the reduction plan must be published within six months of the end of the financial year, and the calculation may cover any twelve consecutive months, not necessarily the calendar year.

Carbon footprint of events: a new category

The text introduces the carbon footprint of events, covering the direct and indirect emissions of activities such as trade fairs, conferences or festivals. A major event is defined as one exceeding 1,500 in-person attendees, for which footprint calculation, verification and, where applicable, registration take on particular importance.

Integrating blue carbon and new absorption projects

The concept of sink is broadened to include blue carbon, that is, the carbon stored in marine and coastal ecosystems such as mangroves, salt marshes and seagrass meadows. This opens the door to more diverse absorption projects aligned with biodiversity conservation.

A more interoperable registry

The rule strengthens the interoperability of the state registry with the regional carbon footprint registries. Communities with their own registry will be able to integrate their data, provided their requirements are compatible, through a system coordinated by the Spanish Climate Change Office, reducing the administrative burden for companies operating in several regions.

The three sections of the registry

The registry is divided into three sections:

• Section a): carbon footprints of organisations and events, together with reduction commitments.
• Section b): CO₂ absorption projects in national territory.
• Section c): carbon footprint offsetting through verified absorptions.

Scopes 1, 2 and 3: what goes into the calculation

The calculation must include Scope 1 (direct) and Scope 2 (indirect from energy use) emissions. Scope 3 (other indirect emissions in the value chain) is voluntary under the Royal Decree, although strongly recommended where it is significant: in most sectors it concentrates the bulk of the total and it is what clients, banks and public tenders ask for.

Verification and control of absorption projects

Scope 1 and 2 footprints must be verified by an accredited body, except where official emission factors from the Spanish Climate Change Office are used and the footprint belongs to an SME, association, foundation, cooperative or public administration. Registered absorption projects must meet monitoring, traceability and permanence requirements, and any significant change (such as a fire) must be reported.

Timeline: what to do and when

The obligation applies from the footprint of the 2025 financial year, calculated and published in 2026. The state public sector registers its first footprint (that of 2025) in 2026. It is therefore worth starting to collect data and design the reduction plan as soon as possible.

How to register

Registration, voluntary for companies, has three phases:

1. Emissions calculation: an inventory of direct GHG (Scope 1) and indirect GHG (Scope 2 and, if you choose to include it, Scope 3), using a recognised methodology such as ISO 14064 or the GHG Protocol.
2. Verification: where applicable, an accredited body verifies the inventory.
3. Registration on the official MITECO platform, attaching the footprint and, where relevant, the reduction plan.

If you want to obtain official recognition, see our guide to the Calculate, Reduce and Offset seals and, for the full context of the rule, the article on the obligation to calculate and reduce the carbon footprint.

To check whether your organisation is in scope and prepare the registration with confidence, you can rely on Manglai's MITECO registry solution.