Royal Decree 214/2025: the obligation to calculate and reduce the carbon footprint

Royal Decree 214/2025 of 18 March (published in Spain's Official State Gazette on 12 April 2025 and in force since 12 June 2025) marks a fundamental shift in Spanish climate policy: for the first time it requires large companies and the state public sector to calculate their carbon footprint, publish it and prepare an emissions reduction plan. It also renews the state carbon footprint registry run by MITECO, Spain's ministry for the ecological transition.

This article explains exactly what the rule says, who it binds, what must be done and from when, separating what is mandatory from what remains voluntary.

What does Royal Decree 214/2025 establish?

Royal Decree 214/2025 does two things. First, it repeals and replaces the earlier Royal Decree 163/2014, which in 2014 created the carbon footprint registry on a purely voluntary basis. Second, it develops the Climate Change and Energy Transition Law 7/2021 and introduces, for the first time, a legal obligation to calculate the carbon footprint for certain organisations.

The renewed registry, officially called the Registry of carbon footprint, offsetting and carbon dioxide absorption projects, broadens its scope to take in new types of absorption project and the carbon footprint of events. It is organised into three sections: carbon footprint and reduction commitments (section a), CO₂ absorption projects in national territory (section b) and emissions offsetting (section c).

According to MITECO's press release of March 2025, when the rule was adopted the registry held around 14,250 registered carbon footprints, 23,348 hectares of reforested land and recognised offsets equivalent to 154,406 tCO₂, a snapshot of the activity accumulated since 2014.

What is the carbon footprint and why must it be calculated?

The carbon footprint measures the total greenhouse gas (GHG) emissions associated with an organisation's activity, expressed in tonnes of CO₂ equivalent. Calculating it is the starting point of any decarbonisation strategy: you cannot reduce what you do not measure.

The calculation distinguishes between Scope 1, Scope 2 and Scope 3: direct emissions, indirect emissions from purchased energy and the rest of the indirect emissions in the value chain. Identifying them rigorously helps detect inefficiencies, save costs and get ahead of regulation.

Who is required to calculate their carbon footprint?

The calculation obligation is not based on a single workforce threshold but is tied to companies that already have to file a non-financial statement (EINF) under the Commercial Code and the Capital Companies Act. In practice, it covers:

• Companies that prepare consolidated accounts and capital companies with an average workforce of more than 500 employees that are public-interest entities or qualify as large companies.
• Ministerial departments of the General State Administration, their autonomous agencies, the managing bodies and common services of Social Security and other entities of the state administrative public sector.

It is estimated that around 4,000 public and private entities fall within the scope of the rule. Other companies may calculate and register their footprint voluntarily.

Calculate and publish, not necessarily register

One point that often causes confusion is worth clarifying. Companies in scope are not required to register with the MITECO registry: they must calculate their footprint annually, prepare an emissions reduction plan and publish both, free of charge and accessibly, on their website, usually through the sustainability report. Registration remains voluntary for them.

By contrast, the state public sector must register its footprint and reduction plan with the registry each year. Its first footprint, for 2025, is registered in 2026.

Deadlines and scopes: what changes and when

The first carbon footprint subject to the new obligation is that of the 2025 financial year, calculated and published in 2026. As a minimum, Scope 1 and Scope 2 must be included. Including Scope 3 becomes mandatory from the 2028 calculation onwards.

The reduction plan must include at least a quantified reduction target over a minimum horizon of five years, together with the measures to achieve it.

Is external verification needed?

Scope 1 and 2 footprints must be verified by an accredited body (for example, by ENAC), except where the significant emissions use emission factors published by the Spanish Climate Change Office and the footprint belongs to an SME, association, foundation, cooperative or public administration. To register sources without an official factor, such as Scope 3, external verification is required.

How to prepare step by step

1. Define the boundaries of the organisation and the scopes to calculate.
2. Collect activity data: energy use, fuels, travel, waste and other sources.
3. Calculate the emissions with a recognised methodology (ISO 14064 or the GHG Protocol) and up-to-date emission factors.
4. Prepare the reduction plan with five-year targets, measures and owners.
5. Verify the inventory where applicable and publish the footprint and plan on your website; if you decide to register, submit the application on the MITECO platform.

To understand the detail of the registry and the official seals, you can read our guide to obtaining the Calculate, Reduce and Offset seals and the summary of the latest changes to the carbon footprint registry.

If you are not sure whether your company falls within the scope of Royal Decree 214/2025, our MITECO registry solution and the free environmental obligations checker help you find out and prepare the calculation with confidence.