Is calculating a carbon footprint mandatory in Spain?

For some organizations, yes. Since Royal Decree 214/2025, companies required to publish a non-financial information statement must calculate their scope 1 and 2 footprint every year and publish a reduction plan. Ministries and state public-sector entities are also required.

Is registering with MITECO mandatory?

Not for companies. Article 12 keeps registration voluntary. State public-sector entities must register their footprint every year. Registration is free.

Which scopes have to be calculated?

At least scopes 1 and 2, with exclusions of no more than 5% of that total. Scope 3 is voluntary for companies. For the state public sector it is mandatory from the 2028 calculation.

When does the first footprint have to be published?

According to the ministry's clarifying note, the footprint adapted to the decree must be included in the information the company publishes in 2026 about fiscal year 2025. From that calculation on, the reduction plan must have a base year and a target at least five years out.

What do the Calculo, Reduzco and Compenso seals mean?

Calculo recognizes that the organization calculated its footprint and submitted a reduction plan. Reduzco, that it also reduced it, which requires at least four years registered. Compenso, that it offset all or part of its footprint with absorption projects from the registry or reduction projects recognized by the ministry.

Royal Decree 214/2025 and the MITECO registry

Q: Does the footprint need verification?

Only to register it. Registration requires accredited verification, with exceptions: an SME, association, foundation, cooperative or public administration does not need to verify its scope 1 and 2 footprint if all its significant emissions are calculated with factors the ministry publishes. A large company that registers always submits the verification.

On June 12, 2025, Royal Decree 214/2025 came into force. With it, calculating a carbon footprint stopped being purely voluntary for large Spanish companies: those that publish a non-financial information statement must calculate their footprint every year and publish a plan to reduce it.

The first time is now. According to the ministry's clarifying note, the footprint adapted to the decree must be included in the information published in 2026 about fiscal year 2025. This guide explains what the decree requires, how the MITECO registry works and what changes with the Omnibus directive.

One registry, two regimes

The registry of carbon footprint, offsetting and absorption projects has existed since 2014. Royal Decree 163/2014 created it, and for eleven years it was entirely voluntary: an organization calculated its footprint, registered it and received a seal.

Royal Decree 214/2025, of March 18, published in the BOE on April 12, repeals that decree and recreates the registry. It keeps the voluntary part and adds a calculation duty for a specific group of organizations. Earlier registrations remain valid unless they need updating.

	Voluntary	Mandatory
Who	Any company or self-employed worker active in Spain	Companies required to publish non-financial information, and the state public sector
What	Calculate, register and get the seal	Calculate the footprint and publish a reduction plan every year
Registration	Voluntary and free	Voluntary for companies, annual for the state public sector

Who is required

Article 11 names two groups.

The first is companies required to include a non-financial information statement, under article 49.5 of the Commercial Code and article 262.5 of the Capital Companies Act. That is the Law 11/2018 regime: broadly, large companies and consolidated groups that already publish sustainability information. The decree sets no thresholds of its own, so the group changes when those rules change.

The second is ministries, autonomous bodies, social security entities and other entities of the state administrative public sector. Regional government departments and provincial councils can join voluntarily.

What has to be done

Three things, every year.

Calculate the scope 1 and 2 footprint. Non-significant sources can be excluded as long as they stay at or below 5% of the total. Scope 3 is voluntary for companies; the state public sector includes it from the 2028 calculation.
Prepare a reduction plan with a quantified target, a base year and a horizon of at least five years, compatible with the Paris Agreement and climate neutrality by 2050.
Publish the footprint and the plan on the organization's website. Companies comply by including them in the sustainability report they already have to file.

The emission factors are those published by the Spanish Climate Change Office, as long as they are compatible with the non-financial reporting rules. If the year's factors are not yet published, the last available year's are used.

The MITECO registry

The registry has three sections: carbon footprint and reduction commitments, CO2 absorption projects, and footprint offsetting. A company normally uses only the first and, if it offsets, the third.

Registration is free and is filed through the ministry's electronic office. According to the annual report of February 2026, there are 6,788 organizations registered and 17,645 footprints on record. In 2025, 1,382 organizations registered for the first time, the highest figure since the registry began.

Since January 2026 only emissions attributable to Spanish territory can be registered.

The three seals

Whoever registers a footprint can use the ministry's seal, which applies to a specific calculation year. It has three variants:

Seal	What it recognizes	Share in February 2026
Calculo	A calculated footprint and a submitted reduction plan	78%
Calculo and Reduzco	Also, a demonstrated reduction	15%
Calculo and Compenso, or all three	Also, offsetting of all or part of the footprint with projects from the registry or recognized by the ministry	7%

Reduzco has a rule worth knowing before you start. The registry compares the average emission intensity of the last three years with that of the three before, so at least four years registered are needed to qualify. Intensity is measured with an activity indicator: tonnes per unit produced, per employee or per revenue, depending on the sector.

The 3,157 footprints that achieved a reduction cut emissions by 17% on average.

Verification

Verification is required to register, not to meet the calculation duty. Article 9 requires accredited verification with the application, with two exceptions. An SME, association, foundation, cooperative or public administration does not need to verify its scope 1 and 2 footprint if all its significant emissions are calculated with factors published by the Office. And small companies, micro-enterprises and administrations do not need to verify their scope 3 if the Office has published the factors needed.

A large company that registers, then, always submits a verification from a body accredited under ISO 14064, the GHG Protocol or equivalent standards.

How it is calculated

The ministry publishes a scope 1 and 2 calculator and an emission factors document. The May 2026 version covers factors from 2007 to 2025. Electricity is calculated with the retailer's factor, which depends on CNMC data.

If you already calculate under the GHG Protocol or ISO 14064-1, you can reuse the same activity data. The GHG Protocol and ISO 14064 guide explains how scopes map to the ISO categories.

Public procurement

Article 10 allows contracting authorities to include carbon footprint considerations in their tenders, under Law 9/2017. They are proven with registration in the registry or equivalent certificates. It is an option, not a general requirement: the decree does not require the seal to bid.

What changes with Omnibus

The article 11 duty follows the non-financial reporting regime. That regime is moving on two fronts.

Spain is still passing the law transposing the EU Corporate Sustainability Reporting Directive, the CSRD. And the Omnibus directive, adopted in February 2026, narrows the CSRD to companies with more than 1,000 employees and 450 million euros of revenue, for fiscal years starting from 2027.

Until the transposition is passed, Law 11/2018 applies. When it is, the group required to calculate a footprint will change with it, because the decree refers to those rules and to whatever amends them.

Penalties

Royal Decree 214/2025 has no penalty regime of its own. That does not change the fact that the footprint and the plan are part of the company's sustainability report, which is published with its accounts.

What we would do in your place

If you publish non-financial information, calculate all of 2025 with scopes 1 and 2, and choose the base year and the intensity indicator now. They are the two decisions that are hardest to change later.

Register even if you are not required to. It is free, and Reduzco requires four years in a row: every year you skip delays the seal.

Keep the invoice behind every figure. If you are a large company and you register, you need accredited verification, and the verifier will ask for the document, the factor and the calculation.

Grumbic calculates the footprint from your fuel and electricity invoices, under the GHG Protocol and ISO 14064-1, and keeps every figure linked to the document it came from. That backing is what the verifier reviews.

See the platform or talk to us.

Sources

Information reviewed on October 19, 2026 in the BOE and in documents from the Ministry for the Ecological Transition. This guide is informative and does not replace legal advice.