The National Securities Market Commission (CNMV), and the Institute of Accounting and Auditing (ICAC), publish the third joint statement pending the transposition of the Corporate Sustainability Reporting Directive, CSRD, and its amendments into Spanish law.
The statement indicates that, as it is possible that Spanish legislation may not yet be aligned with European legislation by 31 December 2026, CNMV and ICAC recommend that Spanish entities subject to Law 11/2018 with more than 1,000 employees publish the sustainability report for the 2026 financial year in accordance with the ESRS, adhering to one of the alternatives proposed in the delegated regulation that publishes Set 2 of ESRS. The aim is for the information to be comparable to that which will be provided by the majority of other issuers in the European Union.
Regarding the rest of the entities subject to Law 11/2018, it is recommended to assess the suitability of applying the ESRS or the voluntary standard.
In relation to the verification of this information by an independent expert, the joint statement recommends that verifiers consider and take into account the latest national and international developments, specifically the text of the verification technical standard (not approved) from ICAC, the guidelines published by COESA, and ISSA 5000.
From 2024, sustainability information in the European Union must be prepared under this Directive, the European standards of EFRAG (known as ESRS) and the respective national legislation.
On 27 November 2024 and 19 November 2025, CNMV and ICAC issued joint statements regarding the possibility that the transposition into Spanish law of the Directive would not be completed by 31 December 2024 and 2025. As of today, the CSRD remains pending transposition in Spain.
Furthermore, as a result of the package of “omnibus” simplification proposals adopted in February 2025 by the European Commission, the CSRD was amended by Directive 2026/470, published in February 2026. This reduced the scope to companies with more than 1,000 employees and €450 million in net turnover. Additionally, on 3 July, two delegated acts were published adopting a voluntary standard for exempt companies and new simplified ESRS standards, known as Set 2.