Spain: The CNMV and the ICAC publish a second statement on sustainability reports pending the transposition of the CSRD Directive into the Spanish legal system
Spain -
The Spanish National Securities Market Commission (CNMV) and the Institute of Accounting and Auditing (ICAC) have issued a new statement updating their previous statement dated 27 November 2024, given the possibility that the CSRD and other related rules will not be transposed into the Spanish legal system before 31 December 2025.
In this statement, both bodies recommend that, without prejudice to compliance with the Spanish legislation currently in force:
- Spanish entities included in phase 1 (“wave 1”) of CSRD reporting, required to report sustainability information for the 2025 financial year, should, to the extent possible, publish the Non-Financial Information Statement (EINF) taking into account the European Sustainability Reporting Standards (ESRS), availing themselves of the new EU transitional framework under the “quick fix” Delegated Regulation adopted on 11 July 2025.
- Entities included in phase 2 of the CSRD should assess the advisability of using the ESRS or, where appropriate, the voluntary sustainability reporting standard for small and medium-sized enterprises, in preparing their EINF, taking into account Directive 2025/794 of the European Parliament and of the Council of 14 April 2025 (“stop the clock”) and other ongoing European legislation.
Finally, it notes that the recommendations included in their initial statement regarding the independent assurance of the content of the EINF or Sustainability Report remain in force.
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