The Spanish Securities Commission (CNMV) and the Institute of Accounting and Auditing (ICAC) issued a third joint statement recommending that Spanish entities subject to Law 11/2018 with more than 1,000 employees prepare their 2026 sustainability reports using the European Sustainability Reporting Standards (ESRS). The recommendation addresses the possibility that Spanish legislation will remain unaligned with European Union rules at Dec. 31, 2026, and aims to make reporting comparable with that of most other EU issuers. Entities following the recommendation should use one of the alternatives provided in the delegated regulation introducing the simplified ESRS, known as Set 2. Although the Corporate Sustainability Reporting Directive (CSRD) and ESRS impose more demanding requirements than Law 11/2018, the CNMV will accept ESRS reports only if they also comply with that law. Other entities subject to Law 11/2018 should assess whether to apply ESRS or the voluntary standard. Independent assurance providers should consider recent national and international developments, including ICAC’s unapproved draft technical assurance standard, guidelines from the Committee of European Auditing Oversight Bodies and International Standard on Sustainability Assurance 5000. The CSRD remains pending transposition in Spain, following similar joint statements addressing reporting for 2024 and 2025. EU amendments published in February 2026 narrowed the directive’s scope to companies with more than 1,000 employees and net turnover exceeding EUR 450 million. Delegated acts published July 3 introduced the voluntary standard for exempt companies and the simplified Set 2 standards.
Spanish Securities Commission and Institute of Accounting and Auditing recommend ESRS reporting for 2026 by entities with more than 1,000 employees
The Spanish Securities Commission and the Institute of Accounting and Auditing recommend that Spanish entities subject to Law 11/2018 with more than 1,000 employees use European Sustainability Reporting Standards for their 2026 reports while Spain’s transposition of the Corporate Sustainability Reporting Directive remains pending. The commission will accept those reports provided they also meet Law 11/2018, while other entities covered by the law should assess using ESRS or the voluntary standard. Assurance providers should take account of recent national and international standards and guidance.