CSRD Reporting Spain: Guide for Spanish SMEs
Introduction
Spain’s business landscape is shifting towards greater sustainability and transparency. Under the Corporate Sustainability Reporting Directive (CSRD), large companies and certain listed SMEs must disclose environmental, social, and governance (ESG) information. For small and growing businesses (SMEs), understanding what applies and how to prepare—especially if they operate within supply chains of larger companies—is essential.
This guide explains what the CSRD means for Spanish small and growing businesses (SMEs), how it interacts with Spain’s national regulations, and how the Voluntary Sustainability Reporting Standard for SMEs (VSME) can make reporting simpler and proportionate.
CSRD in Spain: Who Must Report?
From 2025 onward, large Spanish companies—defined as having more than 250 employees, €50 million turnover, or €25 million in total assets—are required to report sustainability data in line with the European Sustainability Reporting Standards (ESRS). This aligns with Directive (EU) 2022/2464, which replaces the previous Non-Financial Reporting Directive.
For SMEs, mandatory CSRD reporting applies only to those listed on EU-regulated markets (excluding microenterprises). These listed SMEs will begin reporting from 2027, with an optional deferral until 2029. Learn more about CSRD deadlines for SMEs. However, many non-listed SMEs in Spain will still need to provide sustainability data indirectly to their larger clients or banks.
Voluntary Sustainability Reporting: The VSME Standard
For SMEs not directly in scope, Spain’s businesses can use the EFRAG Voluntary Sustainability Reporting Standard for SMEs (VSME). This standard helps small companies prepare credible sustainability reports without the heavy administrative burden of ESRS.
The VSME has two modules:
| Module | Purpose | Ideal For |
|---|---|---|
| Basic Module | Simple environmental, social, and governance metrics (energy, emissions, workforce, anti-corruption) | Micro and small companies |
| Comprehensive Module | Adds strategy, climate targets, human rights, and diversity data | Medium-sized companies or those with ESG-conscious clients |
The Basic Module covers key disclosures such as:
- Energy use and greenhouse gas (GHG) emissions (Scopes 1 and 2)
- Workforce health, safety, and diversity
- Anti-corruption practices
- Waste and circular economy activities
Spanish SMEs can report annually, aligned with their financial reporting cycle, and publish sustainability data in their management report or as a standalone document.
How CSRD Affects Spanish SMEs
While only some SMEs are legally required to report, market pressure is growing. Large companies in Spain—especially those in manufacturing, construction, and food production—are asking their suppliers for ESG data to complete their own CSRD disclosures. This is where the VSME comes in: it ensures SMEs can provide relevant, standardised information without overburdening small teams.
Example:
A medium-sized textile producer in Valencia may not be legally obliged to report under CSRD but will likely need to disclose:
- Energy use (from electricity bills)
- Waste management practices
- Employee training hours and safety incidents
- Any diversity or inclusion initiatives
Using VSME templates helps such SMEs respond quickly to client data requests and demonstrate sustainability commitment when applying for finance or public tenders.
Spain-Specific Considerations
- National Support: Spain’s Ministerio para la Transición Ecológica y el Reto Demográfico (MITECO) and Instituto de Contabilidad y Auditoría de Cuentas (ICAC) are coordinating CSRD implementation and guidance in Spain.
- Language: Reports can be prepared in Spanish for local use, but English summaries are recommended for international stakeholders.
- Local Incentives: Some autonomous communities (e.g., Catalonia and Basque Country) offer grants for digital sustainability tools and energy audits.
For SMEs, integrating CSRD-aligned data into existing processes—like invoicing systems, HR records, or energy monitoring—is often the most practical path.
Tools & Resources
- Official CSRD Directive (EU) 2022/2464
- EFRAG VSME Exposure Draft 2024
- Spanish Ministry for Ecological Transition – MITECO
- VSME Basic vs Comprehensive Module
Frequently Asked Questions
When does CSRD apply in Spain?
Large companies must report for financial years starting in 2024 (reports published in 2025). Listed SMEs will start in 2027, with an optional delay until 2029. Non-listed SMEs can voluntarily adopt VSME to align early with client expectations. Read more on CSRD timelines →
Can Spanish SMEs report in Spanish?
Yes. Reports can be prepared in Spanish, but English summaries help attract investors and partners from other EU markets. For cross-border supply chains, bilingual reporting is best practice.
What’s the easiest way for SMEs to start?
Start with the VSME Basic Module, which requires simple data already available (energy bills, payroll, and invoices). Many SMEs automate data collection using tools like CSRD Pro to save time and avoid manual errors. Compare manual vs automated reporting →
Are there Spanish grants or tools available?
Yes. Spain’s regional governments and chambers of commerce offer funding for digital sustainability management tools, especially for SMEs transitioning to greener operations. MITECO regularly updates available programmes.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive, EU law requiring sustainability disclosures from large and listed companies.
- VSME – Voluntary Sustainability Reporting Standard for SMEs developed by EFRAG.
- Basic Module – The simpler VSME option focusing on key environmental and social metrics.
- Comprehensive Module – The extended VSME option covering strategy and governance details.
- ESRS – European Sustainability Reporting Standards, mandatory for large undertakings.
- SME – Small and medium-sized enterprise, as defined by EU thresholds.
- Scope 1 and 2 emissions – Direct (Scope 1) and purchased energy (Scope 2) greenhouse gas emissions.
- Turnover – Total annual revenue, used to determine company size thresholds.
Conclusion
Spanish SMEs face growing expectations for sustainability transparency, whether through regulation or market demand. By adopting the VSME Standard, businesses can begin reporting in a structured, credible way—without excessive complexity. Starting now helps SMEs strengthen their supply chain position, build investor trust, and prepare for future CSRD requirements.