Article
How to comply with CSRD in Spain: a strategic guide for 2026
The European Sustainability Reporting Standards (ESRS) are the technical framework of the Corporate Sustainability Reporting Directive. The directive establishes what and who; ESRS establish how. The European Commission approved the first package in July 2023 with a total of 1,144 datapoints. The Omnibus package of February 2025 opened a review and simplification process aimed at significantly reducing that figure. This guide explains the current requirements, what changes with simplification and how to organise the work in a mid-market company without falling into either over-reporting or improvisation.
Key takeaways ESRS comprise two cross-cutting standards (ESRS 1 and ESRS 2), five environmental standards, four social standards and one governance standard. Double materiality is the central filter: it determines which standards apply fully, partially or not at all. The Omnibus package aims to reduce mandatory datapoints from 1,144 to a target figure close to 450 and strengthen the primacy of the materiality filter. ESRS 2 always applies, without a filter: governance, strategy, management of impacts, risks and opportunities, metrics and targets. Limited assurance is mandatory from the first reported financial year. Reasonable assurance is under consideration for later phases. Reporting is published within the management report, in ESEF format, with XBRL tagging following the ESRS taxonomy.
Table of contents
- What ESRS are and how they are organised
- The architecture of the twelve standards
- The double materiality assessment
- What changes with Omnibus in 2025-2026
- Preparing for limited assurance
- How Voombu automates ESRS reporting
- Leading the transition rather than suffering through it
- Frequently asked questions
1. What ESRS are and how they are organised
ESRS are the set of technical standards developing the CSRD's information requirements. They were developed by EFRAG (European Financial Reporting Advisory Group) and approved by the European Commission through a delegated act. They are legally binding on every company within the CSRD reporting boundary.
The set is divided into three blocks: Cross-cutting: ESRS 1 (general principles) and ESRS 2 (general disclosures). Both apply to every obligated company, without a materiality filter. Environmental topical standards: five standards, E1 to E5, covering climate change, pollution, water resources, biodiversity and circular economy. Social and governance topical standards: four social standards (S1 to S4) and one governance standard (G1). Application of the topical standards depends on the outcome of the double materiality assessment. A company may have five fully applicable standards, three partially applicable ones and four excluded as non-material. Every decision is documented and audited.
2. The architecture of the twelve standards
ESRS 1 — General principles Defines the common methodological framework: how to apply materiality, establish the consolidation boundary, connect ESG reporting with financial statements, and address estimates and uncertainties. It does not set datapoints; it sets the rules of the game. It is the most underestimated standard and the one that generates the most errors when ignored.
ESRS 2 — General disclosures Mandatory block covering four areas: governance (composition of governing bodies, sustainability oversight, links with remuneration), strategy (business model, transition plan, resilience), management of impacts, risks and opportunities, and metrics and targets. ESRS 2 is what an investor reads first to judge the seriousness of the report.
E1 — Climate change The most demanding standard in the package. Covers GHG emissions in Scopes 1, 2 and 3, a transition plan aligned with limiting warming to 1.5 °C, reduction targets, physical risks (flooding, heatwaves, water scarcity) and transition risks (carbon prices, regulatory changes, market developments). For most companies, it is material and accounts for a substantial share of the reporting effort.
E2 — Pollution Air, water, soil, substances of concern, microplastics. Material for chemicals, heavy manufacturing and agri-food. Often overlaps with ESRS E3 and E4.
E3 — Water and marine resources Consumption, discharges, exposure to water-stressed areas. Material for textiles, food, beverages, mining and data centres in dry regions.
E4 — Biodiversity and ecosystems Impacts on species, habitats, protected areas and ecosystem services. Material for sectors with agricultural, forestry or fisheries value chains, or intensive land use.
E5 — Circular economy Resource inflows and outflows, waste, products designed for reuse or recycling. Material for packaging, electronics, automotive and textiles.
S1 — Own workforce Employment conditions, gender equality and diversity, health and safety, training, collective bargaining, adequate wages. Material for almost any company with employees.
S2 — Workers in the value chain Working conditions among suppliers and subcontractors. Material for companies with long supply chains or a presence in countries with higher labour-related risks.
S3 — Affected communities Impacts on local communities where the company or its suppliers operate. Material for extractive industries, infrastructure and energy.
S4 — Consumers and end-users Product safety, accessibility, data protection, responsible commercial practices. Material for banking, insurance, telecommunications, retail and healthcare.
G1 — Business conduct Corporate culture, corruption prevention, lobbying, supplier relationships, whistleblower protection. Material for practically every company, although to varying degrees.
3. The double materiality assessment
Double materiality is the methodological element that most clearly distinguishes CSRD from previous voluntary reporting. It requires each ESG matter to be assessed from two perspectives:
Impact materiality. The positive or negative effect that the company's activity has on people, communities and the environment. The magnitude, scope and reversibility of the impact are assessed.
Financial materiality. The current or expected effect that an ESG matter may have on the company's financial position or operating performance. Probability and financial magnitude are assessed.
A matter is material if it exceeds the relevance threshold in either dimension. The assessment must:
Identify potentially material matters based on the business model, value chain and stakeholders. Consult internal stakeholders (board, management, workforce, works council) and external stakeholders (customers, suppliers, lenders, communities) in a structured way. Apply documented scoring criteria, not opinions. Produce a matrix or equivalent showing prioritised matters, the threshold applied and the justification for what is included and excluded. Be reviewed periodically. Materiality is not a static asset. The common mistake is to outsource the matrix to an external consultancy, receive it as a PDF, approve it at board level and file it away. When the auditor arrives, they request traceability of stakeholder consultations and the criteria applied. If that traceability does not exist, the rest of the report rests on weak foundations.
4. What changes with Omnibus in 2025-2026
The Omnibus package published by the Commission in February 2025 and the "stop-the-clock" directive approved in April of the same year modify three dimensions of the CSRD-ESRS framework:
Scope The obligation threshold is raised. The cut-off moves towards 1,000 employees combined with turnover (>€450 million) or balance sheet (>€25 million) criteria. Consequently, the second reporting wave shrinks significantly and the third wave (listed SMEs) is greatly reduced.
Timeline A two-year postponement for the second and third waves. Companies that were due to publish their first report in 2026 will do so in 2028. The first wave, already subject to NFRD, continues reporting as normal.
Content The Commission has asked EFRAG to simplify ESRS. The public objectives are to reduce mandatory datapoints from the original 1,144 to a figure close to 450, eliminate redundant disclosures, strengthen the materiality filter and postpone the introduction of sector-specific standards in their initial form. Consultation and approval of the revised version take place throughout 2025 and 2026.
Three interpretations need to be challenged.
The first: that Omnibus removes the obligation. It does not. Companies within scope remain required to report under ESRS, with limited assurance and ESEF format. Only the content is simplified and the timeline postponed.
The second: that simplification reduces the technical demands on large companies. It does not do that either. The disclosures that remain are the most relevant, and the primacy of materiality requires better documentation of why something is excluded.
The third: that non-obligated SMEs can ignore the framework. This is the most expensive interpretation. Large companies and banks will continue requesting ESG data from their value chains, and the simplified voluntary standard for SMEs (VSME) is designed precisely for that scenario.
5. Preparing for limited assurance
Limited assurance is a less demanding level of verification than reasonable assurance, but it is not optional. It applies from the first financial year reported under CSRD. The independent auditor issues a report published alongside the sustainability report.
What the auditor requests A board-approved sustainability policy with clear governance arrangements. A documented double materiality assessment, with an explicit methodology and traceable stakeholder consultation. Traceability for every data point: origin, calculation formula, factor applied, owner, date. Without traceability, verification is impossible. Internal controls over ESG information. Ideally, these should be integrated into the COSO ERM risk management framework rather than built separately. Reconciliation between ESG figures and financial statements, particularly regarding the consolidation boundary. Documentary evidence for qualitative statements. The text in ESRS 2 is audited too. Common mistakes Treating reporting as a writing exercise rather than an information system. Consolidating data in Excel without version control. Changing calculation methodology between financial years without documenting the transition. Underestimating the time required for the audit dossier: typically an additional four to six weeks after the calculations are closed. The difference between a company passing the audit cleanly and one passing with observations is usually governance, not data. Correct figures without a documented process produce a qualified report.
6. How Voombu automates ESRS reporting
Voombu is an artificial intelligence-powered ESG management system. The platform is built specifically to produce auditable ESRS reports, integrating the four pillars required by the regulation:
Automated reporting. Imports data from ERP, HR and procurement systems. Calculates the mandatory datapoints for each applicable ESRS. Generates a draft report aligned with the XBRL taxonomy and ESEF format.
ESG risk management under COSO ERM. Identifies and monitors material risks using a 5×3 matrix integrated with the rest of the internal control system. Connects each risk with the operational data that generates it.
Dynamic ESG Score. An internal weighted indicator (Environmental 40 %, Social 35 %, Governance 25 %) that evolves with the data and allows links to incentives, KPIs or sustainable financing conditions.
Executive dashboard. A single view for management and the board, with drill-down to the original data and audit-ready exports.
The double materiality module guides the sustainability team through identifying matters, consulting stakeholders and scoring, while keeping an auditable record of every decision. Companies arriving with an existing assessment upload it directly; those without one build it within the system itself.
For specialised ESG consultancies, a multi-licence (MLC) option allows several clients to be managed from a single infrastructure while maintaining data separation and client-specific visual customisation.
7. Leading the transition rather than suffering through it
The ESRS conversation is polarised between two caricatures. One says it is a pointless regulatory cost that destroys competitiveness. The other says it is a strategic opportunity that transforms the business. Both are false in their simplified form.
The reasonable truth is more prosaic. ESRS require companies to measure things most previously did not measure rigorously: emissions across the value chain, disaggregated social data, physical climate risks, effective governance. Measurement has a cost. Using the data, if that happens, generates value. If it does not, the cost remains just a cost.
Three less obvious uses of reporting we see in companies making the most of it: Industrial investment decisions. The ESRS E1 transition plan requires capex and opex projections under different climate scenarios. The company ends up with investment analyses it did not previously have. Discussions with lenders. Sustainability-linked loans (SLLs) with margin improvements or penalties of around 5 to 15 basis points depending on KPI achievement. Banks request structured ESG data; companies that have it can negotiate. Supply chain screening. Corporate customers are choosing suppliers with verifiable ESG data. An SME able to answer a questionnaire within fifteen days wins tenders that an SME improvising its response loses. ESG is not compliance. ESG is strategy. The report is only the photograph. What counts is what you do with what the photograph reveals.
8. Frequently asked questions
How many datapoints do I actually have to report? That depends on the outcome of double materiality. A typical mid-market industrial company ends up reporting between 200 and 400 datapoints, not the full catalogue of 1,144. The Omnibus review will reduce the catalogue and, with it, the subset applicable to each company.
Do I have to apply every topical ESRS? No. Only those found material through the assessment. Non-material standards are excluded with documented justification. ESRS 1 and ESRS 2 always apply.
Is the value chain also reported? Yes. ESRS E1 covers Scope 3 if climate change is material. S2 covers workers in the value chain. The value chain enters the reporting boundary whenever the materiality assessment justifies it.
What happens if I cannot measure a material matter? Report what is known, explain what is missing and what is being done to address the gap. ESRS 1 accepts estimates and approximations when precise data is unavailable, provided the methodology is documented and uncertainty is explicit. Omitting the matter without justification is unacceptable.
Can I use a voluntary standard alongside ESRS? Yes, and many companies do. CDP, SBTi, GRI, TCFD, ISSB. The platform should be able to feed all of them from the same underlying data. Reporting the same thing twice in different formats is a symptom of a poorly organised system.
What about non-obligated SMEs? They have access to the simplified voluntary standard (VSME), designed to answer customers and lenders without the complexity of the full package. It is the sensible option for a Spanish SME regularly receiving ESG questionnaires.
Does ESG information replace the traditional management report? No. It is integrated into the management report in a dedicated sustainability section, alongside the audited annual accounts. Publication is joint and in the same ESEF package.
Next steps ESRS are not understood by reading the text of the standards. They are understood by building the system that produces them. Voombu supports mid-market companies and specialised consultancies in that construction. A 30-minute demo is usually enough to establish the starting point, identify the most costly gaps and outline a six-to-twelve-month plan at a realistic scale.