New Royal Decree 214/2025 on carbon footprint: implications, methods and tools for businesses

Context and Regulatory Evolution

Spain has been a pioneer in carbon footprint regulation. In 2014, Royal Decree 163/2014 created the Voluntary Carbon Footprint, Offset and CO₂ Absorption Projects Register, a tool that enabled organisations to calculate and report their greenhouse gas (GHG) emissions voluntarily. This registry became a European benchmark, fostering transparency and climate action across the business landscape.

Subsequently, Law 7/2021 on Climate Change and Energy Transition introduced the obligation to move towards a more demanding regulatory framework, anticipating that the calculation and publication of the carbon footprint would become mandatory for certain economic and administrative actors. This law also laid the foundations for integrating sustainability into corporate strategy and public procurement.

Royal Decree 214/2025 puts this requirement into practice and establishes a mandatory system for:

• Large companies (with more than 250 employees and certain financial thresholds).
• Public administrations (ministries, autonomous bodies, and managing entities).
• Events with more than 1,500 attendees.

Among its main new features are:

• Obligation to calculate and publish the carbon footprint (Scopes 1 and 2, with progressive inclusion of Scope 3 starting in 2028).
• Design of a reduction plan with measurable objectives and a minimum five-year horizon, aligned with the Paris Agreement.
• National registry and verification in certain cases, reinforcing traceability and transparency.
• Recognition of international methodologies (GHG Protocol, ISO 14064-1) and the MITERD Guide as a technical reference.
• Interoperability between regional and national registries, avoiding duplication and facilitating data transfer between regional governments and the central administration.

In addition, the Royal Decree is complemented by the CSRD Directive, which strengthens mandatory corporate sustainability reporting, and by regional regulations that already imposed specific requirements (Catalonia, Balearic Islands, Navarre, Valencia, Basque Country). This regulatory framework seeks to harmonize criteria and ensure that emissions data are comparable, verifiable, and accessible.

Who is required to comply and what must they do?

• Large companies: more than 250 employees and financial thresholds (assets > €20M or turnover > €40M).
  • Mandatory: calculate and publish the footprint (Scopes 1 and 2; Scope 3 progressively from 2028), and develop a reduction plan with a minimum 5-year horizon.
  • Registry: optional, unless the official seal is sought or required for public tenders.
• Public administrations: ministries, autonomous bodies, and Social Security management entities.
  • Mandatory: calculation, publication, and registration.
• Events: trade fairs and conferences with more than 1,500 attendees.
  • Mandatory: calculation and verification.
• SMEs: voluntary participation, but strategic for anticipating client, bank, and future regulatory demands. The Recommendation (EU) 2025/1710 provides a voluntary framework for clear and recognized sustainability reporting.

Benefits and Challenges of Carbon Footprint Calculation

Competitive Advantages:

• Access to sustainable financing.
• Better scoring in public tenders.
• Official recognition and enhanced reputation among stakeholders.

Main Challenges:

• Collecting reliable data.
• Integrating Scope 3 (indirect value-chain emissions).
• Developing plans aligned with corporate strategy.

Accepted Methodologies

Royal Decree 214/2025 allows methodological flexibility, provided traceability and transparency are guaranteed:

• GHG Protocol: international standard, practical and flexible (Scope 3 optional).
• ISO 14064-1: more formal, management-system oriented, requires coverage of all categories.
• MITERD Guide: technical and practical approach, defines the minimum report content and registry requirements.

Strategic choice: depends on the goal (regulatory compliance, corporate reporting, public tenders, or internal improvement) and the organization’s maturity level.

Carbon Footprint Calculation Process

Carbon footprint calculation is not just a mathematical operation but a structured process ensuring traceability and consistency. It includes four key stages:

1. Define Boundaries
   • Organizational: determine which entities, sites, or subsidiaries are included (e.g., only Spain HQ or the entire group).
   • Operational: define activities covered (production, transport, offices, events).
   • Reporting period: usually annual, must be clearly defined.
   • Baseline year: serves as a reference to measure future reductions. Choose the first full year with reliable data and keep it unless significant changes occur (mergers, scope expansion).
2. Data Collection
   • Identify sources:
     • Direct (Scope 1): fuel combustion, company vehicles, process emissions, refrigerant leaks.
     • Indirect (Scope 2): purchased electricity, steam, heat, EV charging.
     • Value chain (Scope 3): business travel, commuting, freight, procurement, waste management.
   • Evidence: invoices, consumption logs, internal reports.
   • Emission factors: preference for MITERD-published ones for consistency; if unavailable, use recognized sources (IPCC, sector databases).
   • Uncertainty analysis: not required by MITERD, but recommended by GHG Protocol and ISO 14064 for confidence in results.
3. Calculate and Analyze
   • Apply the chosen methodology (GHG, ISO, MITERD).
   • Document any estimations (e.g., when using averages).
   • Present results by scope and source, indicating totals in tCO₂e.
   • Optionally, establish performance indicators (intensity per production unit, per employee) for monitoring.
4. Plan Improvements
   • Define a reduction plan with clear, measurable goals.
   • Assign responsibilities and establish annual monitoring.
   • Integrate the plan into corporate strategy and communicate progress transparently.

Reduction Plan: Requirements and Examples

The Royal Decree requires plans to meet minimum criteria:

• Quantified objectives: e.g., “Reduce total footprint by 5% compared to baseline within five years.”
• Specific actions: replacing boilers with electric systems, purchasing renewable energy, optimizing logistics.
• Time horizon: at least five years, with a long-term (2050) vision aligned with the Paris Agreement (1.5 °C).
• Public availability: publish on corporate websites or sustainability reports.
• Annual monitoring: report progress and justify deviations; transparency is key for credibility.

Verification and Registry

• Verification: not always mandatory but provides credibility and competitive advantage; required for Scope 3 and major events.
• Registry: mandatory for public administrations; voluntary for private companies (recommended for obtaining seals and funding).
• Accredited entities: ISO 14064/65, ETS, ISO 50001/EMAS, ISAE 3000/3410, DOE.

Our Solution: Carbon Footprint Monitor

At Applus+ Certification, we offer a digital carbon footprint solution integrated into our footprint verification service. It enables:

• Fast, traceable calculation of Scopes 1 and 2.
• Progressive inclusion of Scope 3.
• Reports compatible with MITERD, GHG, and ISO standards.
• Supplier monitoring to strengthen the value chain.
• Real-time results, year-over-year comparisons, and editable draft reports.

Outlook and Next Steps

Royal Decree 214/2025 is not just a legal obligation: it’s an opportunity to position your organization as a sustainability leader.

Those who act now will be better prepared to:

• Comply with future regulations.
• Increase competitiveness in markets and tenders.
• Access green financing and enhance their reputation.

Recommendation: start calculations as soon as possible, progressively integrate Scope 3, train internal teams, and rely on digital tools and expert guidance.

Resources

• Download the presentation by Applus+ Certification (only in Spanish)
• Watch the webinar recording (only in Spanish)