EINF: who must report, what it includes and how to automate it with AI

Your company's EINF must be approved before 30 June and filed with the Commercial Registry before 30 July. If you are not sure whether you have to submit one, or how to do it without losing weeks, here are the essentials.

What is the EINF and who must file it?

The non-financial statement (Estado de Información No Financiera, or EINF) sets out a company's environmental, social and governance impact within its management report. It is the Spanish piece of sustainability reporting and is governed by Law 11/2018, which remains in force in Spain while its successor is being processed: the future Business Sustainability Information Law that will transpose the CSRD.

Your company must file one if it meets any of these conditions:

• Public-interest entity (bank, insurer, listed company, and so on): more than 500 employees on average.
• Other companies: more than 250 employees and, in addition, exceeding at least two of these three thresholds for two consecutive years: total assets, turnover and average number of employees.

For the financial thresholds you will see, depending on the source, 20M euros in assets / 40M euros in turnover, or the updated figures of 25M euros / 50M euros, because they were revised in 2024 to correct for inflation. It is worth confirming with your advisers which applies to your specific case.

EINF vs CSRD: why the threshold matters more than ever

On 18 March 2026, Directive (EU) 2026/470, known as the Omnibus I Package, entered into force, cutting the scope of the CSRD to companies with more than 1,000 employees and more than 450M euros in turnover, both criteria at once. That new threshold will apply to financial years starting on or after 1 January 2027, and it reduces the universe of companies obliged by the CSRD from around 50,000 to roughly 5,000 across the EU. We cover this in detail in our analysis of the Omnibus Package.

That does not let anyone off the hook on reporting. The EINF, with its 250-employee threshold under Law 11/2018, is still in force and is right now the regime that actually applies to most mid-sized companies in Spain. If your company relaxed thinking "the CSRD no longer applies to me", you are probably still bound by the EINF. To place the differences correctly, this guide to the CSRD and the ESRS helps avoid confusing the two regimes.

EINF timeline: the dates that matter

For a financial year ending on 31 December, these are the deadlines that recur each year:

• Drawing up (the EINF within the management report): by 31 March.
• Approval at the general meeting: by 30 June.
• Filing with the Commercial Registry: by 30 July.

If your company has a different year-end, the three deadlines are counted the same way from your closing date: 3, 6 and 7 months respectively.

What must the EINF include?

The minimum content requires verifiable data, not statements of intent:

• Business model and policies applied
• Environmental indicators: Scope 1, 2 and 3 emissions, energy use, water and waste
• Social indicators: workforce, equality, working conditions
• Governance: anti-corruption and human rights
• Risks associated with each matter and how they are managed

Each KPI must be traceable back to the source data, because the EINF requires verification by an independent auditor.

Mind Royal Decree 214/2025: mandatory carbon footprint

If your company files an EINF, since 2025 you are also affected by Royal Decree 214/2025, published in the BOE on 12 April 2025 and in force since 12 June 2025. It requires large companies within the EINF perimeter to calculate their Scope 1 and 2 carbon footprint each year and publish an emissions reduction plan with a minimum horizon of five years and quantified targets. Scope 3 is voluntary. Under the Spanish environment ministry's clarifying note of December 2025, the footprint and the plan must be published within six months of the financial year end.

Two things are often mixed up and should not be: calculating the footprint and having a reduction plan is mandatory, but registration in MITECO's carbon footprint registry remains voluntary for private companies; only obliged state public sector entities must file their data there. Companies that already comply with the CSRD are deemed to comply with the decree too. We have summarised what it means in the article on the royal decree that requires calculating the carbon footprint.

How Manglai's AI turns weeks into hours

Gathering and verifying this data by hand is what takes the most time. Manglai's AI automates exactly that part:

• Reading invoices for electricity, water, fuel and waste: it reads, classifies and assigns them to the right site, in any language or currency.
• Building the company tree site by site: it interprets the org chart in PDF or image form and structures it on its own.
• Importing data from Excel or CSV: a conversational agent automatically transforms it into the report's format.
• Drafting the environmental sections: Manglai's EINF module generates them with the data already loaded into the platform.

The result: traceable, audit-ready data, and weeks of manual work turned into hours.

This is especially useful for sustainability teams managing several sites or countries at once.