2027 is the year the revised CSRD starts to apply to large companies above the new thresholds, with the simplified ESRS mandatory for financial years beginning on or after 1 January 2027. The same year brings the opening of CBAM certificate sales, the first annual CBAM declaration, the EUDR for micro and small enterprises and the first reference year of the new Industrial Emissions Portal. This calendar sets out the dates confirmed as of 29 October 2026 for companies in Spain and the EU, and flags what is still in the pipeline.
Context: a transition year between old and new rules
Much of the 2027 calendar comes from Directive (EU) 2026/470 (Omnibus I), published on 26 February 2026. It limits the CSRD to companies with more than 1,000 employees and more than EUR 450 million in net turnover, and postpones CSDDD due diligence to 2029.
Spain has an additional factor. The bill transposing the CSRD lapsed when Parliament was dissolved (Royal Decree 806/2026 of 5 October), so transposition will have to start again after the general election of 29 November 2026. In the meantime, Law 11/2018 on non-financial information (EINF) remains in force. You can follow the latest in our article on CSRD transposition in Spain.
How to read this calendar: the dates come from regulations and directives published in the Official Journal of the EU, from the Spanish Official State Gazette (BOE) and from statements by supervisors. Where a date depends on a proposal or a Commission forecast, we say so. Dates for financial years assume a calendar year ending on 31 December. You can read the revised ESRS in full on EUR-Lex.
January to March 2027
- 1 January: simplified ESRS become mandatory. Delegated Regulation (EU) 2026/1563 applies to financial years beginning on or after 1 January 2027. According to the Commission, it cuts mandatory datapoints by more than 60%.
- 1 January: new CSRD thresholds. EU companies exceeding both 1,000 employees and EUR 450 million in turnover report on financial year 2027, with the first report due in 2028.
- 1 January: cap on value chain requests. From financial years starting in 2027, in-scope companies cannot ask suppliers with up to 1,000 employees for more information than the voluntary standard provides (Delegated Regulation (EU) 2026/1560).
- 1 January: first reference year of the Industrial Emissions Portal. Regulation (EU) 2024/1244 sets 2027 as the first data year. Installations will report that data in 2028, when the regulation replaces the current E-PRTR.
- 1 February: CBAM certificate sales open. The central platform opens for purchasing certificates covering emissions embedded in 2026 imports. We explain it step by step in our CBAM timeline for 2026 and 2027.
- 12 February: PPWR milestones. Under the timetable of Regulation (EU) 2025/40, Member States must have their penalty regimes in place, and takeaway food businesses must let customers bring their own containers.
- 18 February: battery passport. Regulation (EU) 2023/1542 requires a digital passport for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh. More background in our guide to the digital product passport.
- 19 March: Omnibus I transposition deadline. Member States must bring the CSRD changes into national law. In Spain the deadline coincides with the formation of a new government, so it is worth tracking the process.
April to June 2027
- EINF for financial year 2026. Companies covered by Law 11/2018 file it with their annual accounts. The CNMV and the ICAC recommend that entities with more than 1,000 employees prepare it using the revised ESRS, while still meeting every requirement of Spanish law.
- Emissions calculation and reduction plan (RD 214/2025). Companies required to publish the EINF must calculate their 2026 scope 1 and 2 emissions and publish their reduction plan within six months of the financial year end. We cover it in our article on Royal Decree 214/2025.
- PRTR declaration of 2026 data. Regulation (EC) 166/2006 still applies to 2026 data, reported in 2027. Each autonomous community sets its own deadline; we summarise them in our guide to Spain's PRTR register.
- 30 June: EUDR for micro and small enterprises. Following Regulation (EU) 2025/2650, micro and small enterprises established as such by 31 December 2024 apply the deforestation regulation from this date. Medium and large companies apply it from 30 December 2026. See our article on the EUDR postponement.
July to September 2027
- 1 July: limited assurance standard. The Commission must adopt the EU limited assurance standard for sustainability reports by this date. Until then, Member States may apply national standards. We explain what the assurance provider reviews in our article on limited assurance.
- 26 July: CSDDD guidelines. The Commission must publish the first guidelines on the due diligence process and model contract clauses.
- 18 August: battery due diligence. Regulation (EU) 2025/1561 postponed supply chain due diligence obligations for batteries to this date.
- 30 September: first annual CBAM declaration. Authorised declarants file the declaration for 2026 imports and surrender the corresponding certificates. Regulation (EU) 2025/2083 moved this deadline from 31 May.
October to December 2027
- 11 October: energy management systems. Directive (EU) 2023/1791 requires companies with average annual energy consumption above 85 TJ to have a certified energy management system in place. In Spain, MITECO states that the rule transposing this article is being drafted, so national details may differ.
- EU Taxonomy. The simplified Taxonomy has applied since 2026. According to published planning, the Commission expects to adopt a further revision of the Disclosures Delegated Act in early 2027, with effect expected in the third quarter of 2027. This is a forecast and may change.
- EU ETS review. The Commission's July 2026 proposal for the post-2030 carbon market will be negotiated in Parliament and Council during 2027. Its figures may change.
What moves beyond 2027
- ETS2 (buildings and road transport): starts on 1 January 2028 after the delay agreed alongside the 2040 climate target. See our article on ETS2.
- CSDDD: transposition by 26 July 2028 and application from 26 July 2029.
- Industrial Emissions Portal: Regulation (EU) 2024/1244 applies from 1 January 2028.
- PPWR labelling: harmonised labelling obligations apply from 12 August 2028.
- Non-EU groups under the CSRD: report from financial years starting in 2028.
What to do now
- Check which rules apply to your company. Compare headcount, turnover, CBAM imports, EUDR commodities, packaging and energy use against each threshold.
- Close your 2026 data properly. The EINF, the RD 214/2025 reduction plan, the PRTR declaration and the 2027 CBAM declaration all rely on 2026 data.
- Prepare financial year 2027 from January. If you exceed the CSRD thresholds, decide from day one how you will collect the data the revised ESRS require.
- Organise your source documents. Invoices, certificates and waste manager documents need to be easy to find for assurance.
- Review what you ask your suppliers. Align questionnaires with the value chain cap that applies from 2027. If you are a supplier, expect requests based on the voluntary standard.
- Track the process in Spain. Transposition of the CSRD and of Article 11 of the energy efficiency directive depends on the new government.
Frequently asked questions
Which companies report under the CSRD for the first time in 2027?
EU companies exceeding both 1,000 employees and EUR 450 million in net turnover. They report on financial year 2027 and publish the report in 2028, using the simplified ESRS.
Is the EINF still mandatory in Spain in 2027?
Yes. Until the CSRD is transposed, Law 11/2018 remains in force and in-scope companies file the EINF for financial year 2026 in 2027.
When do CBAM certificates have to be bought?
Sales open on 1 February 2027. The first annual declaration and certificate surrender are due on 30 September 2027.
Does ETS2 start in 2027?
No. Its start was postponed to 1 January 2028.
What happens with the CSDDD in 2027?
The Commission must publish guidelines by 26 July 2027. Due diligence obligations apply from 26 July 2029.
Can these dates change?
Dates in published regulations are firm unless amended again. Dates that depend on proposals, Commission forecasts or national transposition may move, and we flag them as such.
How Manglai helps
Many of these obligations share the same foundation: reliable, traceable environmental data. Manglai brings together on one platform the data from all your sites, suppliers and documents, reads invoices and PDFs automatically with artificial intelligence and calculates scope 1, 2 and 3 emissions with documented emission factors under the GHG Protocol and ISO 14064. For waste, it classifies by LoW (LER) code and digitises waste manager documentation. Reports are audit-ready, with every data point traceable to its source document, and support CSRD/ESRS reporting. See how footprint measurement works in Manglai.
