The Royal Decree 214/2025 reinforces the climate commitment in Spain by requiring large companies and public entities to calculate their carbon footprint annually (scopes 1 and 2) and to draw up reduction plans with five-year targets.
In this article we provide guidance on the steps to follow to develop an emission reduction plan that complies with the requirements of RD 214/2025.
Main points of the RD in relation to companies
Companies affected
The provisions of RD 214/2025 apply to organisations subject to the scope of Law 11/2018, which obliges certain companies to report non-financial information. This framework now extends its requirements in relation to the quantification and reduction of greenhouse gases (GHG).
Main obligations
Annual calculation of the carbon footprint:
Companies shall calculate, on an annual basis, their emissions of scopes 1 and 2. The calculation of the SCOPE 3 is considered voluntary.
Use of OECC emission factors:
For operations and activities carried out in Spanish territory, it shall be compulsory to use the emission factors of the Spanish Office for Climate Change (OECC).
Carbon footprint registration at MITERD:
Although the registration in the official register of the Ministry for Ecological Transition and the Demographic Challenge (MITERD) is voluntary, its use is encouraged as a tool for transparency.
Publication of results:
Organisations should publish its carbon footprint annually on its corporate websiteThe Commission's proposal for a European Parliament and Council Regulation (EC) No.
Development of a decarbonisation plan:
Each company will have to design and implement a decarbonisation plan that meets the following criteria:
Minimum coverage of scopes 1 and 2emissions, consistent with the calculated footprint inventory.
Minimum time horizon of five yearswith defined milestones and reduction paths.
Inclusion of quantifiable and measurable objectivesThe Commission has also developed a set of guidelines, which allow for regular assessment of progress.
Alignment with the commitments of the Paris AgreementThe aim is to achieve the climate neutrality by 2050.
Mandatory publication of the plan in 2026emissions, based on footprint data for 2025.
The Paris Agreement
The Paris Agreement, adopted in 2015 under the United Nations Framework Convention on Climate Change, sets out the global commitment to limiting the global average temperature increase to well below 2°C above pre-industrial levels, striving to limit it to 1.5°C.
To achieve this, countries must submit and periodically update their Nationally Determined Contributions (NDCs), which include emission reduction and adaptation plans, with increasing ambition in each five-year cycle.
It also promotes climate resilience, financing for developing countries, technology and capacity cooperation, and transparency in monitoring and reporting progress, aiming to achieve a balance between greenhouse gas emissions and removals in the second half of the century.
Decarbonisation plan:
setting reduction targets (using SBTi methodology)
As mentioned above, the reduction plans should be in line with the objective of the Paris Agreement to limit global warming to 2°C, while efforts are being made to limit the increase to no more than 1.5°C.
The methodology developed by the Science Based Target Initiative (SBTi)provides calculation methods that can be used by any company to set reduction targets in line with the Paris Agreement.
Here are some key concepts to consider when setting reduction targets:
Base year.
This is the year in relation to which reduction targets will be set. The SBTi methodology accepts base years of 2015 onwards. In case a base year higher than 2020 is used, the methodology applies a correction factor to increase the intensity of reductions.
Target year.
This is the year in which the company must have achieved its emission reduction commitment. In the case of short-term objectives, this should cover a period of 5 to 10 years.emissions, relative to the base year. For a company developing the reduction plan with a base year of 2025, the minimum target year is 2030.
Scope of emissions.
The reduction target should include at least 95% of range 1 and 2 emissions. Likewise, if the company includes Scope 3 in the reduction target, it shall account for at least 67% of emissions in the case of short-term targets and 90% of Scope 3 for long-term targets.
Scenarios.
These are the global or sectoral emissions trajectories which describe how energy use, fuels and greenhouse gas emissions should be reduced over time to stay within the 1.5°C or 2°C thresholds. Each scenario shows a annual emission reduction curve compatible with a warming level (1.5 °C or 2 °C).
Level of ambition.
Companies have a choice between the 1.5°C reduction scenario or the well below 2°C reduction scenario. It is best to set a high ambition, aligned with the 1.5°C scenario.
Absolute reduction of emissions.
The application of the SBTi methodology implies that companies with short-term objectives (between 5 and 10 years) will have to reduce by at least 4,2% linear annually, its scopes 1 and 2. The indicator used are absolute tonnes of CO2eq.
Decarbonisation plan:
develop the reduction plan
A reasonable approach to defining a decarbonisation plan should take into account the following aspects:
Understanding the organisation's carbon footprint:
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- Identification of hotspots.
- Understanding of energy consumption and typologies of energy sources (generally in scopes 1 and 2).
- Understanding the contributions of the value chain, both upstream and downstream (generally in scope 3).
This exercise will make it possible to identify the areas with the highest contribution and to make a first assessment of the reduction potentials in each activity.
Definition of decarbonisation scenarios:
This is about working with evolution projections, both of internal factors to the company, such as the forecast of sales in the coming years, as well as of external factors, such as the decarbonisation of the national electricity mix or the evolution of certain technologies within a specific industrial sector.
The idea is to take into account the external economic and technological factors that will have an impact on the organisation's climate performance, beyond the specific actions to be implemented.
Identification and evaluation of concrete reduction actions:
In this phase, the explore different technical options and their reduction potential emissions. The appraisal of decarbonisation measures should include economic analysis to determine the costs and the cost/reduction potential ratio of each initiative.
At this stage, it is key to precisely identify the potential reductions of each specific measure and to quantify the economic costs and necessary investments related to each action.

