Spain: MITERD clarifies the scope of the obligations to calculate the carbon footprint and to draw up and publish reduction plans
In a recent note, it specifies its application for business groups based on the location of the ultimate parent company and its subsidiaries.
The Ministry for Ecological Transition and Demographic Challenge (MITERD) has published, in a note released last December, some clarifications and details on Royal Decree 214/2025, of March 18, 2025, creating the carbon footprint, offsetting and carbon dioxide absorption projects register and imposing the obligation to calculate the carbon footprint and draw up and publish plans for the reduction of greenhouse gas emissions.
These clarifications and precisions refer, in particular, to Chapter IV, and more specifically to Article 11, concerning the obligation to calculate the carbon footprint and to draw up and publish a reduction plan.
The note addresses issues such as the obligated parties, the scope of the obligation, its entry into force, the deadlines for submitting the annual calculation of the carbon footprint and the reduction plan, its publicity, as well as how it applies to corporate groups depending on the location of the ultimate parent company and its subsidiaries, distinguishing in relation to the latter among the following cases:
- Group with ultimate parent company in Spain and subsidiaries in Spain.
- Group with ultimate parent company in Spain and subsidiaries outside Spain.
- Group with ultimate parent company in another EU country (e.g., Sweden) and subsidiaries in Spain.
- Group with ultimate parent company outside the EU (e.g., U.S., Switzerland, United Kingdom) and subsidiaries in Spain.
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