The EINF requires structured disclosure across five pillars defined in Spain’s Law 11/2018. Each pillar has specific data points that auditors verify. Here’s exactly what you need to report.
1. Environmental matters
- Carbon footprint , Scope 1, 2, and (where material) Scope 3 greenhouse gas emissions
- Energy consumption , Total energy use, renewable vs non-renewable breakdown, energy intensity ratios
- Pollution , Air, water, and soil pollution measures and prevention
- Circular economy , Waste generation, recycling rates, resource efficiency measures
- Biodiversity , Impact on protected areas, mitigation measures
2. Social and employee matters
- Employment , Total headcount, contract types, turnover, absenteeism
- Work organisation , Working hours, work-life balance, disconnection policies
- Health and safety , Occupational accidents, frequency and severity indices
- Social dialogue , Collective bargaining coverage, consultation procedures
- Training , Hours of training per employee, professional development programs
- Accessibility , Measures for persons with disabilities, universal accessibility
3. Human rights
- Due diligence , Human rights risk assessment procedures
- Risk prevention , Measures to prevent human rights violations in the value chain
- Complaints and grievances , Mechanisms for reporting violations, cases resolved
4. Anti-corruption and bribery
- Policies , Anti-corruption policies and their scope
- Procedures , Whistleblowing channels, compliance programs
- Outcomes , Confirmed incidents, actions taken
5. Board diversity
- Composition , Gender, age, professional background of board members
- Diversity policy , Objectives, implementation measures, results
- Pay gap , Remuneration by gender and category
What auditors look for
The EINF must be verified by an independent assurance provider. Auditors focus on:
- Traceability , Can every data point be traced to a source document?
- Consistency , Do numbers align across sections and with financial reporting?
- Completeness , Are all required disclosure areas covered?
How Dcycle helps
Dcycle maps every EINF requirement to specific data points and tracks completion across all five pillars. Evidence is attached to each data point automatically, giving auditors the traceability they need.
