Environmental Law · RD 214/2025
Carbon Footprint: Obligations under RD 214/2025
Royal Decree 214/2025 requires companies to calculate, register with MITECO and publish their carbon footprint. The obligations are phased in between 2025 and 2028. Do you know whether your company is already obliged?
Applicability checklist: is your company obliged?
Answer these 10 questions in order to determine whether your company is subject to RD 214/2025 and from which financial year the obligation applies.
Does the company have its registered office or a permanent establishment in Spain?
Yes: Continue the analysis
No: Not subject to RD 214/2025
Has the company exceeded 500 employees on average headcount in the last financial year?
Yes: Obliged from financial year 2025
No: Go to question 3
Does the company exceed €150M net turnover or €150M total assets in two consecutive financial years?
Yes: Obliged from financial year 2025
No: Go to question 4
Does the company exceed two of these three thresholds: 250 employees · €50M turnover · €43M assets?
Yes: Obliged from financial year 2026
No: Go to question 5
Does the company exceed 50 employees or €10M turnover in two of the last three financial years?
Yes: Obliged from financial year 2027
No: Go to question 6
Is the company included in any of the high carbon-intensity sectors listed in the Annex to RD 214/2025?
Yes: May be obliged regardless of size — check the sector Annex
No: Go to question 7
Does the company take part in the EU ETS (European Emissions Trading System)?
Yes: Already calculates scope 1. RD 214/2025 adds scope 2 and, progressively, scope 3
No: Go to question 8
Is the company subject to the CSRD (EU 2022/2464) and required to report under ESRS E1?
Yes: Carbon footprint calculation (scopes 1, 2 and 3) is mandatory under ESRS E1 — compatible with RD 214/2025
No: Go to question 9
Is the company a public sector contractor for more than €5M per year?
Yes: ESG clauses in public contracts may require a registered carbon footprint as a solvency criterion
No: Go to question 10
Have you checked whether your region has adopted additional carbon footprint regulation?
Yes: Check regional regulations: they may set obligations for companies that do not meet the national thresholds
No: If you answered No to all the previous questions, the company is not currently obliged — review each financial year
ISO 14064-1 · GHG Protocol
Scopes 1, 2 and 3 of the carbon footprint
RD 214/2025 requires the calculation of scopes 1 and 2 from the first year of application. Scope 3 is phased in progressively according to the company's size and sector.
Scope 1
Direct emissions
Emissions from sources directly controlled by the company: combustion of own fuels (boilers, fleets), industrial processes and fugitive emissions (refrigerant leaks, methane).
Examples
Natural gas boilers · Company vehicles · Industrial combustion processes · Fluorinated gas leaks
Scope 2
Indirect energy emissions
Emissions from the generation of electricity, heat, steam or cold that the company purchases and consumes. Although the emission occurs at the supplier's plant or facility, RD 214/2025 attributes it to the consumer.
Examples
Grid electricity · Purchased heat or steam · Centralised air conditioning purchased from third parties
Scope 3
Other indirect value chain emissions
Emissions occurring in the company's value chain, both upstream and downstream: purchased raw materials, contracted transport, waste generated, use of the sold product, and end of life.
Examples
Purchased raw materials · Subcontracted transport and distribution · Waste generated · Product use by the customer
What RD 214/2025 requires
The four main obligations
Carbon footprint calculation
Methodology in line with ISO 14064-1 or the GHG Protocol. Scopes 1 and 2 mandatory from the first year of application. Scope 3 phased in progressively according to the RD 214/2025 calendar.
Registration with the MITECO National Registry
The calculated footprint must be registered with MITECO's National Registry of Carbon Footprint, Offsetting and Absorption Projects before 31 December of the year following the calculated financial year.
Multi-year reduction plan
Together with the registration, the company must submit an emissions reduction plan with quantified targets and a time horizon. The plan must be updated annually.
Verification by an ENAC-accredited body
The carbon footprint calculation must be verified by a verification body accredited by ENAC (Spain's National Accreditation Body) under ISO 14064-3 or an equivalent standard.
RD 214/2025 · Transitional provisions
2025-2028 obligation calendar
RD 214/2025 obligations are phased in according to company size. Identify the financial year in which your first calculation and registration are due.
| Financial year | MITECO registration | Companies affected | Mandatory scopes |
|---|---|---|---|
| 2025 | 31 Dec 2026 | Large companies exceeding 500 employees or €150M net turnover or €150M total assets in two consecutive financial years. | Scopes 1 and 2 mandatory · Scope 3 voluntary |
| 2026 | 31 Dec 2027 | Companies exceeding two of the three thresholds: 250 employees · €50M turnover · €43M total assets in two consecutive financial years. | Scopes 1 and 2 mandatory · Scope 3 voluntary with incentives |
| 2027 | 31 Dec 2028 | Medium-sized companies exceeding 50 employees or €10M turnover in two of the last three financial years. | Scopes 1 and 2 mandatory · Scope 3 mandatory for Annex sectors |
| 2028 | 31 Dec 2029 | Companies in the high carbon-intensity sectors of the RD 214/2025 Annex that have not met the previous thresholds, and all companies from previous tiers with a scope 3 obligation. | Scopes 1, 2 and 3 mandatory for all tiers |
Frequently asked questions about RD 214/2025
What is RD 214/2025 and which companies does it apply to?
Royal Decree 214/2025 establishes the obligation to calculate, register and publish organisations' carbon footprint. It applies to companies with a registered office or permanent establishment in Spain that exceed the size thresholds or belong to high carbon-intensity sectors. The obligation is phased in between 2025 and 2028 according to company size.
What is the difference between scope 1, scope 2 and scope 3 of the carbon footprint?
Scope 1 covers the company's direct emissions (own combustion, industrial processes, fugitive emissions). Scope 2 covers indirect emissions from purchased energy (electricity, heat, steam). Scope 3 covers the rest of the value chain's indirect emissions: raw materials, contracted transport, waste, product use and end of life. RD 214/2025 makes scopes 1 and 2 mandatory and phases in scope 3 progressively.
How and when do you register with MITECO's National Carbon Footprint Registry?
Registration must be completed before 31 December of the following year after the calculated financial year. Companies in the first tier must register their 2025 footprint before 31 December 2026. Registration requires submitting the calculation verified by an ENAC-accredited body along with the multi-year reduction plan.
What penalties does RD 214/2025 set out for non-compliance?
RD 214/2025 refers to the sanctioning regime under Law 34/2007 on Air Quality and applicable sector regulations. Fines can range from €300 to €500,000 depending on the classification of the infringement (minor, serious or very serious). Non-compliance also negatively affects the company's ESG rating and its access to labelled sustainable finance.