EINF: verification and materiality analysis of the non-financial statement

The non-financial statement (EINF, by its Spanish acronym) is the report that certain Spanish companies must publish on environmental, social, personnel, human-rights and anti-corruption matters. It was introduced by Law 11/2018, which amended the Commercial Code, the Capital Companies Act and the Auditing Act to transpose the former Non-Financial Reporting Directive (NFRD), now repealed by the CSRD.

Two features define the EINF: first, its content must undergo mandatory verification by an independent verification services provider; second, the company must report what is material, that is, relevant to understanding the development, results and impacts of its activity.

What the EINF is and who is in scope

The EINF is part of the management report (or issued as a separate report) and describes the business model, the policies applied, the risks and the results on sustainability, with key indicators. In practice it is a legally binding form of sustainability report, very close to the traditional voluntary version, but compulsory.

After the initial transitional period, the obligation reaches companies with more than 250 employees that are also public-interest entities or exceed certain balance-sheet and turnover thresholds (around 20 million euros in assets or 40 million euros in annual turnover). Consolidated groups follow equivalent criteria at group level.

We cover the full list of obligated companies, contents and indicators in our guide on who is required to file the EINF and what it must include.

Mandatory verification by an independent provider

Law 11/2018 requires the EINF information to be reviewed by an independent verification services provider. This verification is not optional: without it, the statement does not meet the legal requirements for publication and filing at the Commercial Registry.

The aim is to give the data credibility and to prevent greenwashing. Among other things, the verifier checks that the materiality analysis has been carried out, that indicators are traceable back to their source, and that the statement covers the contents the law requires.

Who can verify and with what scope

Spain's accounting and audit institute (ICAC) has clarified that the rule does not set specific conditions on who performs the verification, so it can be carried out by the entity's statutory auditor or another professional with adequate knowledge. As for the assurance level, common EINF practice has been limited assurance (concluding that nothing has come to light), a less demanding degree than the reasonable assurance of financial audit. One widespread misunderstanding is worth clearing up here: Directive (EU) 2026/470 removed the planned move to reasonable assurance, so under the CSRD the required level also stays at limited assurance, with the corresponding standard due before 1 July 2027.

How to run the materiality analysis for the EINF

The materiality analysis is the process by which a company identifies which environmental, social and governance issues are relevant enough to report on. Within the EINF framework, materiality focuses mainly on relevance to the business and its stakeholders; with the CSRD that approach broadens to double materiality.

An orderly process usually follows these steps:

1. Identify candidate topics from the sector, the value chain, reference frameworks and applicable regulation.
2. Consult stakeholders (customers, employees, investors, suppliers, community) to understand their expectations.
3. Prioritise each topic by its importance and impact, typically in a matrix.
4. Validate the results with management and document the process, because the verifier will review it.
5. Report the material topics with their associated indicators and policies.

Materiality is not a one-off exercise: it must be reviewed each year, since the regulatory and business context changes.

Materiality of climate issues

For almost every company, climate change is material. That is why the EINF usually includes the carbon footprint by scopes, together with reduction policies and targets. Having a reliable emissions inventory is also the basis for the calculation and reduction-plan obligations that Spain's RD 214/2025 imposes.

How to automate the EINF and its materiality

Much of the EINF effort lies in gathering and consolidating scattered data: energy and water bills, fuel consumption, personnel data, waste, or supplier information. Specialised software automates that collection, applies up-to-date emission factors, keeps the traceability the verifier requires and generates the documentation reproducibly.

• Centralises data from all sites and departments into a single source.
• Reduces errors compared with manual entry in spreadsheets.
• Speeds up verification, because each indicator is linked to its evidence.
• Eases the transition to the ESRS, by reusing the same data with more granularity.

From Law 11/2018 to the CSRD and ESRS: what changes with the Omnibus

The CSRD replaces the EINF regime. In Spain it is transposed through the Business Sustainability Information Act (LIES), which as of mid-2026 is still going through parliament. Until that transposition is completed, affected companies remain subject to Law 11/2018 and the obligation to publish the EINF; many already prepare it in line with the CSRD framework and the ESRS, following the recommendation of the CNMV and the ICAC.

The Omnibus package, published in the EU Official Journal in February 2026 and in force since 18 March 2026, reshaped the CSRD's timeline and scope. Its main effects:

The underlying shift is twofold: fewer companies are legally required, but the technical demand rises for those that do report, with common standards and double materiality. Preparing the transition early is key; we develop it in the guide on how to implement the ESRS step by step.

Frequently asked questions

Is the EINF still mandatory in 2026?

Yes. Until the CSRD transposition in Spain is completed through the LIES, companies already required under Law 11/2018 must continue publishing their verified EINF.

Who can verify the EINF?

An independent verification services provider. According to the ICAC, this can be the entity's statutory auditor or another professional with adequate knowledge, since the rule sets no specific conditions.

How does EINF materiality differ from the CSRD's double materiality?

The EINF has focused mainly on relevance to the business and stakeholders. The CSRD requires double materiality: analysing both the company's impact on its surroundings and the effect of sustainability issues on the company.

Automate your EINF and get ready for the ESRS with Manglai

With Manglai you can calculate your carbon footprint by scopes, keep the traceability the verifier expects and reuse that data for CSRD and ESRS reporting. See how to start with our carbon footprint solution.