
Developments on national sustainability reporting legislation
This is to flag that there have been two important developments on national sustainability reporting legislation:
1) Spain's Royal Decree 214/2025 (entry into applicability June 2025)
- Carbon footprint calculation - mandatory Scope 1 and 2 emissions disclosures.
Carbon Footprint Registry - expanding to include products and events.
An Emission Reduction Plans - targets must be specific and measurable.
Public Disclosure Requirements - carbon footprints and emission reduction plans must be registered and on company websites.
2) Draft amendment to the LkSG by Germany's Ministry of Labour and Social Affairs (published on 29 August), marking the start of a longer legislative process.
The proposal reflects the April coalition agreement and, as anticipated, adjusts the existing LkSG in advance of the transposition of the EU CSDDD into German law. The amendments are intended to ensure a “low-bureaucracy” and “enforcement-friendly” implementation. The reporting obligation under the LkSG will no longer apply.
Companies are still required to document their due diligence activities.
All other due diligence requirements under the LkSG remain in place.
If the omnibus proposal is accepted, the CSDDD will still include a reporting obligation.
Therefore, even if reporting under the amended German Act is no longer required, companies must continue tracking and documenting due diligence activities.
Please note that FESI does not directly cover national sustainability reporting legislation; this update is shared for information purposes only.
