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    cómo afecta la CSRD a las pymes proveedoras en España

    CSRD and sustainability: how it will affect SMEs and self-employed suppliers in Spain from 2026

    For years, “sustainability” was something that sounded like big multinationals, reports full of photos of forests and lots of nice words.

    That is over now.

    With the new European Sustainability Reporting Directive (CSRD) and its future transposition in Spain through the Corporate Sustainability Reporting Act, sustainability is no longer just marketing talk; it has become a legal and accounting obligation for tens of thousands of companies.

    And even if you are an SME or a self-employed person, even if no one is going to directly ask you for a ‘sustainability report’, you are going to feel the impact… especially if you work for large companies, banks or public administrations.

    In this article, we are going to explain, in practical terms:

    • What the CSRD is and what Spain intends to achieve with the new Corporate Sustainability Reporting Act.
    • Why it affects you even if you are not on the IBEX.
    • What your customers may start asking you for from 2026 onwards.
    • How to prepare yourself with common sense and without driving your business crazy.

    What is the CSRD and the future Business Information Law on Sustainability

    From ‘non-financial reports’ to CSRD sustainability reports

    Until now, only a limited number of large companies were required to publish ‘non-financial’ information: environmental, social, personnel issues, etc.

    The CSRD (Corporate Sustainability Reporting Directive) goes one step further: it requires detailed sustainability reports, based on European standards (ESRS) and reviewed by an independent verifier, similar to an audit of accounts. In summary:

    • Sustainability is no longer just a nice brochure.
    • It becomes regulated information, comparable between companies and with real consequences for financing, reputation and compliance.

    Who will have a direct obligation and from when

    The simplified timetable is as follows:

    • Large public interest companies: they are already starting to report for the first financial years.
    • Other large companies (more than 250 employees): they will start reporting for financial years beginning in 2025 (reports published in 2026).
    • Listed SMEs: they will join somewhat later, around 2026–2027, with some flexibility or temporary exemption.

    Spain is adapting all this through a Draft Law on Corporate Sustainability Information, which specifies:

    • Who is subject to the requirements.
    • How the reports are prepared.
    • How they are verified (new figure of sustainability verifier under the supervision of the ICAC).

    What about SMEs and self-employed persons who are not listed?

    The vast majority of SMEs and self-employed persons will not be directly required to produce a full CSRD report.

    So why should you be interested in this issue?

    Because your clients will be. And those clients will need data from their entire value chain: suppliers, subcontractors, distributors, etc.

    Why does it affect you even if you are "small"

    Even if the law does not mention you by name, there are three ways in which sustainability will affect you:

    1. Banks and financing

    Financial institutions are incorporating ESG criteria into:

    • risk analysis,
    • loan approval,
    • financing conditions.

    It is increasingly common for lenders to require information on:

    • business emissions and energy consumption,
    • employment situation (workforce, turnover, equality),
    • potential environmental or compliance risks.

    It is not just a matter of ‘approving a loan’, but of the conditions under which it is granted.

    What does ESG criteria mean?

    ‘ESG criteria’ are a set of factors used to assess how a company performs beyond purely financial figures.

    In English, it stands for:

    • E – Environmental
    • S – Social
    • G – Governance

    In Spanish, people often refer to ASG criteria (Environmental, Social and Governance), but it is the same thing.

    Why are they ‘throwing it’ at you everywhere now?

    Because:

    • The EU, banks and large companies are using ESG/ASG criteria to assess risks, grant financing and select suppliers.
    • With regulations such as the CSRD, large companies will have to publicly report their ESG data and, to do so, they will request information from their SME and self-employed suppliers.

    In summary:

    ESG/ASG = how “healthy and responsible” the company is in environmental, social and governance terms.

    2. Major clients and value chain

    If you work for:

    • large construction companies,
    • industrial groups,
    • retail chains,
    • multinational companies,

    it is very likely that, from 2026 onwards, you will start to receive:

    • sustainability questionnaires for suppliers,
    • contractual clauses linked to ESG,
    • requests for data on working conditions, energy consumption, etc.

    Essentially, your clients are passing on part of their transparency obligations.

    3. Subsidies and public contracts

    Many lines of aid and public tenders already include:

    • additional points for having certain ESG policies in place,
    • minimum requirements (equality plans, salary register, LGTBI protocol, etc.),
    • commitments to reduce emissions, circular economy, etc.

    If your business depends in part on subsidies or working with the government, ignoring this issue could mean being left out without really knowing why.

    What they may start asking you for from 2026 onwards if you are a supplier

    Here comes the practical part. What might a large company or bank ask of you?

    Don’t expect them to ask for a complete CSRD report right away, but it is reasonable for them to start with basic blocks of information:

    Simple environmental data

    Typical examples:

    There is no need to set up a NASA; it is about being able to answer with data and not with impressions.

    Social and labour data

    This includes issues that you are already required to comply with, but which you may not have systematised:

    • Do you have an up-to-date and reliable workday record?
    • Do you have a salary record and, if applicable, an equality plan?
    • How do you manage occupational risk prevention, training, etc.?
    • What is the staff turnover rate, the percentage of permanent contracts, etc.?

    All of this may appear in supplier questionnaires or as an annex to contracts.

    Compliance and corporate governance

    Large companies also look at:

    Again, not because you are perfect, but because the company that hires you wants to be able to say:

    ‘We know our suppliers, we have procedures in place and we avoid serious risks in the value chain.’

    Practical guide for SMEs and freelancers: how to prepare yourself step by step

    The good news: you don’t need to become an ESG consultant.

    But it is a good idea to do a minimum amount of homework so that when the questions come, you’re not caught off guard.

    Step 1. Identify which of your clients are ‘big’

    Make a very simple list:

    • Clients that are publicly traded.
    • Clients that are medium/large business groups.
    • Clients who already publish sustainability reports.

    These are the ones who will be the first to start placing demands on suppliers.

    Step 2. Quick inventory of what you ALREADY have

    You probably already comply with many obligations without calling them ‘sustainability’:

    • Occupational risk prevention.
    • Workday records (perhaps already in electronic format).
    • Employment contracts, payroll, etc.
    • Certificates of being up to date with the tax authorities and social security.
    • Some informal procedure for complaints or claims.

    The first step is to collect and organise it.

    Step 3. Define 3–4 key indicators that you can measure

    For most SMEs and self-employed people, a ‘basic pack’ is sufficient:

    • kWh of electricity consumed per year (you can find this on your bills).
    • Number of employees and type of contracts (permanent/temporary).
    • Percentage of women in the workforce.
    • Number of workplace accidents or sick leave due to accidents in the year.

    If you can measure anything else (litres of fuel consumed, tonnes of waste, etc.), all the better, but it is not essential to start with.

    Step 4. Write down 2–3 simple policies

    We’re not talking about an 80-page manual.

    We’re talking about short, clear documents that you can provide if requested:

    • A basic code of conduct (respect for the law, anti-corruption, confidentiality).
    • An equality and non-discrimination policy tailored to your size.
    • A very simple protocol on harassment prevention and a reporting channel (even if it is through your consultancy).

    This is also in line with other labour and compliance obligations that are already becoming more stringent.

    Step 5. Use all this to sell more, not just to “comply”

    The big mistake is to see sustainability only as a cost.

    If you manage it even minimally well, you can:

    • Include a small ESG section in your commercial proposals.
    • Highlight that you comply with salary registration, working hours, occupational risk prevention, etc.
    • Respond quickly and well to your customers’ questionnaires, while your competitors still don’t even understand what they’re talking about.

    In many sectors (industrial, construction, B2B services), this will make the difference between staying on the list of suppliers… or being left out.

    Will there be simplified aid and standards for SMEs?

    The EU and various administrations are taking steps to ensure that this does not become a bureaucratic nightmare for small businesses:

    • A simplified voluntary sustainability standard for SMEs (VSME) has been designed, with a reduced set of indicators.
    • Some calls for aid already finance:
      • carbon footprint calculation,
      • preparation of basic sustainability reports,
      • related energy or technology investments.

    And, of course, it is always possible to outsource part of the work:

    • ESG consultancies,
    • specific software,
    • or a consultancy that integrates tax, labour and sustainability in a practical way (ahem).

    Conclusion: from an inconvenient obligation to a competitive advantage

    The CSRD and the future Corporate Sustainability Information Law are not designed to target a self-employed person with a diesel van or an SME with eight employees.

    But they will change the environment in which you operate:

    • Your major clients will have to report in much greater detail.
    • Your banks will look beyond purely financial figures.
    • Government agencies will make aid and tenders conditional on ESG criteria.

    You can react in two ways:

    1. Wait for the first 20-page questionnaire to arrive and improvise.
    2. Get ahead of the game, put your house in order and use it as an argument to attract and retain customers.

    If you choose the second option, this is an area where very few SMEs are prepared yet. Those who take action in 2025–2026 will have a clear advantage over the rest.

    And that is where a consultancy that understands taxation, labour and new sustainability obligations can make the difference between:

    • ‘Another headache from Europe’ and
    • ‘An opportunity for my company to look bigger, more serious and more financeable than the competition’.

    Frequently asked questions about CSRD

    • Will I be required to produce a sustainability report if I am an SME or self-employed supplier?In most cases, you will not be directly required to produce a full sustainability report under the CSRD. However, your large customers will have to report and, to do so, they will ask you for information on environmental, social and governance aspects of your company. You will not have to produce ‘full CSRD reports’, but you will have to provide basic data and certain internal documentation.
    • What kind of information can my clients ask me for from 2026 onwards under the CSRD?Most commonly, they will ask you for simple data on energy consumption, waste management, working conditions (working hours, contracts, equality, occupational risk prevention), and some internal documents such as a code of ethics or an equality policy. They are not looking for you to be perfect, but rather to demonstrate that you are managing these issues to a minimum standard.
    • If I don’t work with large companies, does the CSRD also affect me?The impact will be less, but not zero. Banks, insurance companies and public administrations are also incorporating sustainability criteria into financing, grants and contracts. Even if you don’t have a large listed client, it will become increasingly common for you to be asked for ESG information in order to be granted a loan or to participate in a grant or tender.
    • What is the difference between the CSRD and the future Corporate Sustainability Information Law in Spain?The CSRD is a European directive that sets out the general framework and defines the standards. The future Corporate Sustainability Information Law is the Spanish regulation that adapts this directive and specifies which Spanish companies will be required to comply, how they must report and who will verify this information. For SMEs and self-employed suppliers, the important thing is that both regulations reinforce transparency requirements throughout the value chain.
    • What can I do in 2025–2026 to avoid being left out as a supplier?Identify your ‘big’ customers, compile the labour and prevention documentation that you already comply with, define 3–4 easy-to-measure sustainability indicators (energy, workforce, accidents, etc.) and write down a short code of ethics and an equality or non-discrimination policy. This will ensure you are better prepared than most of your competitors when the sustainability questionnaires start arriving.