Spain Issues Interim Guidance to Steer Sustainability Reporting Ahead of CSRD Transposition

Key Takeaways

• ESRS Recommended for 2025: Spain’s regulators advise Phase 1 companies to use the European Sustainability Reporting Standards for their 2025 sustainability reports to ensure comparability across the EU.
• Temporary Simplifications Noted: The guidance highlights the EU’s “quick fix” regulation, which freezes certain ESRS disclosure requirements for two years.
• Options for Phase 2 Entities: Firms in Phase 2 are encouraged to assess whether the ESRS or the voluntary SME sustainability standard is more suitable while EU legislation continues to evolve.
• Assurance Guidance Updated: Independent verifiers are urged to consider the latest national and international materials, including the draft ICAC technical standard, COESA guidance, and ISSA 5000.

Deep Dive

Spain’s financial and audit regulators are trying to bring some stability to the sustainability reporting landscape as the clock ticks toward the 2025 reporting cycle. This week, the Comisión Nacional del Mercado de Valores (CNMV) and the Institute of Accounting and Auditing (ICAC) issued a joint statement outlining how Spanish companies should approach their disclosures while the Corporate Sustainability Reporting Directive (CSRD) is still in the process of being transposed into national law.

The move comes as the CNMV separately begins overhauling its Good Governance Code for Listed Companies, a revision that will run through the second quarter of 2027 and reflects the significant regulatory shifts that have taken place since the Code’s last update in 2020.

Preparing for CSRD Before Spain’s Rulebook Is Final

Because Spain may not have completed its legislative alignment with the EU by 31 December 2025, the CNMV is advising Phase 1 companies to report their 2025 sustainability information using the European Sustainability Reporting Standards (ESRS). The aim is to keep Spanish disclosures comparable with those of other EU issuers.

The communication also points companies to the European Commission’s “quick fix” delegated regulation, which introduces temporary simplifications and freezes certain ESRS disclosure requirements for two years. Regulators note that Spanish companies should factor these eased obligations into their reporting plans.

For Phase 2 companies, the guidance is more open-ended. The CNMV recommends evaluating whether the full ESRS or the voluntary SME sustainability standard (VSME) is the more appropriate route, taking into account ongoing EU legislative work such as the temporary suspension directive.

Assurance Providers Told to Watch Evolving Standards

The statement also speaks directly to independent assurance providers. While sustainability assurance rules continue to develop, the CNMV and ICAC urge verifiers to consider the most recent national and international materials available, including:

• the draft ICAC technical verification standard (not yet approved),
• COESA’s published guidance, and
• ISSA 5000, the international sustainability assurance benchmark.

Regulators underscore that assurance work should reflect the latest thinking across both Spanish and European frameworks as they continue to evolve.

Parallel to the sustainability guidance, the CNMV has begun the formal process of revising Spain’s Good Governance Code, a commitment outlined in its CNMV2030 Plan. To support the work, the regulator will form a Group of Experts in the coming weeks, bringing together representatives from government bodies, financial sector associations, major law firms, and market participants

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