Carbon Reporting for Spanish SMEs: CSRD Procurement Guide
Carbon Reporting for Spanish SMEs: What You Need for CSRD Procurement Questionnaires
Spain's large companies — Mercadona, Inditex, BBVA, Telefónica, Iberdrola, Repsol, Ferrovial — are implementing CSRD supply chain requirements that will affect tens of thousands of Spanish SME suppliers. If you have received a cuestionario de sostenibilidad (sustainability questionnaire) from a large buyer, this guide explains what you need to calculate and how.
Spain's Electricity Grid Factor
Spain's electricity mix combines natural gas, nuclear, wind, solar, and hydro. The grid carbon intensity is moderate:
| Country | Grid factor (kgCO2e/kWh) |
|---|---|
| --------- | -------------------------- |
| Spain | 0.195 |
| France | 0.052 |
| Germany | 0.380 |
| Portugal | 0.190 |
| UK | 0.193 |
For a Spanish SME consuming 75,000 kWh/year of electricity, Scope 2 = 75,000 x 0.195 = 14.6 tCO2e. Spain's growing renewable share (wind and solar reached over 50% of generation in 2023) is pushing the grid factor lower each year.
Scope 1: Direct Emissions for Spanish SMEs
| Fuel | DEFRA 2023 factor | Example: 5,000 m³/year |
|---|---|---|
| ------ | ------------------- | ------------------------ |
| Natural gas | 2.04 kgCO2e/m³ | 10.2 tCO2e |
| Diesel | 2.68 kgCO2e/litre | — |
| Petrol (gasolina) | 2.31 kgCO2e/litre | — |
| Autogas (LPG) | 1.51 kgCO2e/litre | — |
Collect annual gas consumption from your Endesa, Naturgy, Repsol, or Iberdrola bill (expressed in kWh or m³) and fuel card records for company vehicles.
Scope 3 Categories Required by Most Spanish Buyers
Spanish procurement questionnaires aligned to CSRD typically request:
- Category 3 (WTT): Well-to-tank upstream emissions from your gas and diesel supply. Calculated automatically from Scope 1 inputs using DEFRA factors.
- Category 5 (waste): Annual office and production waste by disposal route (vertedero/landfill, reciclaje/recycling, incineración/incineration). Your gestión de residuos (waste management) contractor provides annual summaries.
- Category 6 (business travel): Flight km, rail km, and hotel nights for business travel.
- Category 7 (employee commuting): Average daily km commuted by your employees, estimated by mode.
Spanish Regulatory Context
Spain is transposing the CSRD through domestic legislation. Large Spanish companies (over 500 employees, or over 250 with public interest entity status) have been reporting non-financial information under Ley 11/2018 since 2019. CSRD extends and deepens these requirements from 2025 onwards, with supply chain data requests cascading to SME suppliers.
The MITECO (Ministerio para la Transición Ecológica) publishes IPCC-compatible emission factors for Spanish grid electricity and fuels. DEFRA 2023 factors are internationally recognised and are accepted by all major Spanish buyers as a valid methodology basis for SME suppliers.
Responding to Spanish Buyer Questionnaires
Inditex (Zara, Massimo Dutti, Pull and Bear): Active supplier sustainability programme. Carbon data requested through their Join Life supplier portal for Tier 1 suppliers.
Mercadona: Supplier qualification increasingly incorporates environmental KPIs. Carbon data collection piloting with largest suppliers.
Telefónica / Movistar: Scope 3 supplier data collection programme in place. GHG Protocol methodology accepted for SME responses.
AECOC Sustainability (ECR Spain): Industry body coordinating carbon data standards for food and consumer goods suppliers.
Generating Your Carbon Passport
DeCarbonOPS applies Spain's grid factor (0.195 kgCO2e/kWh) and all DEFRA 2023 factors automatically. Enter your annual energy bills, fuel records, and headcount data — the calculation takes under 20 minutes. Your Carbon Passport includes a public verification URL that satisfies the evidentiary requirements of CSRD-driven questionnaires from Spanish and European buyers.
Getting your carbon data in order now positions your company as a preferred supplier as large Spanish corporates accelerate their supply chain sustainability requirements in 2025 and 2026.
Frequently Asked Questions
What is Spain's electricity grid factor for Scope 2 reporting?
Spain's grid carbon intensity is approximately 0.195 kgCO2e/kWh (IEA 2022 data). Spain has a diversified mix of natural gas, nuclear, wind, solar PV, and hydroelectric generation. The renewable share has been growing rapidly — wind and solar together exceeded 50% of annual generation in 2023. As the grid decarbonises further, the Scope 2 factor will decrease. Use the year-appropriate factor (0.195 for data reported in 2024–2025 based on 2022 figures).
Can I use REE (Red Eléctrica de España) data for my Scope 2 factor instead of DEFRA?
Yes — REE publishes annual grid emission intensity data for Spain that is the domestic authoritative source. For international procurement questionnaires from non-Spanish buyers, DEFRA 2023 or IEA factors are preferred as they provide internationally comparable data. Both sources produce similar figures for Spain (approximately 0.19–0.20 kgCO2e/kWh). Either is acceptable; note the source in your methodology statement.
Which large Spanish companies are asking SME suppliers for carbon data?
Active supply chain sustainability programmes include: Inditex (Join Life supplier programme), Mercadona (environmental supplier qualification), Telefónica (Responsible Business Programme), Iberdrola (supplier chain sustainability), Repsol (supplier carbon data), BBVA (sustainable procurement), Ferrovial (supply chain ESG), ACS Group, and El Corte Inglés. Spanish public procurement is also incorporating environmental criteria in tenders above EU threshold values.
Is carbon reporting required under Spanish law for SMEs?
Spain's Ley 11/2018 on Non-Financial Information requires annual non-financial reporting (including GHG emissions) only for large companies (over 500 employees). SMEs are not directly covered. However, CSRD (EU Directive 2022/2464), transposed into Spanish law from 2025, will indirectly require SME suppliers to provide carbon data to their large enterprise customers. The obligation flows from your customers, not directly from Spanish regulation for SMEs.
How do I get my gas consumption in m³ from a Spanish energy bill?
Spanish gas bills from Naturgy, Endesa, Repsol, or Iberdrola typically show consumption in kWh (thermal). To convert to m³, divide by the calorific value of gas (approximately 10.55 kWh/m³ for standard natural gas). For example: 50,000 kWh gas consumption = 50,000 / 10.55 = 4,739 m³ x 2.04 kgCO2e/m³ = 9.67 tCO2e. Some meters show m³ directly — check whether your bill uses kWh or m³ as the consumption unit.
Ready to get your Carbon Passport?
Generate a verified carbon report in 20 minutes — free for your first annual report. Accepted by SAP Ariba, Coupa, and enterprise procurement teams across the EU.
Get started free