If you are a managing director or quality manager of an industrial, services or construction SME in Spain, you have probably heard about the carbon footprint with increasing frequency over recent months. It is no coincidence: European regulation has taken a turn that, although it does not directly oblige most SMEs, is dragging them in indirectly through their large clients. The question we receive most often at Summum Calidad is clear: «Do I need to calculate my carbon footprint or not?». The honest answer is: it depends on several factors, but if your company sells to large listed groups or to the Public Administration, the answer is probably yes, and sooner than you think.
What is the carbon footprint and why does it matter now?
The carbon footprint measures the total quantity of greenhouse gases (GHG) —expressed in tonnes of CO₂ equivalent (tCO₂e)— that an organisation, product or service generates directly or indirectly. It is not a new concept: the 1997 Kyoto Protocol already established it, and the GHG Corporate Standard (World Resources Institute / WBCSD, 2001) has been the international methodological reference for decades.
What is new is the progressive legal obligation. Europe has moved from voluntary to mandatory requirements in less than five years, and 2026 is an inflection point that cannot be ignored.
The regulatory framework: CSRD, ESRS and the value chain
The Corporate Sustainability Reporting Directive (CSRD) —Directive 2022/2464/EU, published in the Official Journal of the EU on 16 December 2022— requires affected companies to publish detailed information on their GHG emissions according to ESRS (European Sustainability Reporting Standards). ESRS E1, dedicated to climate change, requires the breakdown of emissions into Scope 1 (direct), Scope 2 (purchased energy) and Scope 3 (value chain), following a methodology compatible with the GHG Protocol or ISO 14064.
The implementation calendar is phased:
| Group | Criterion | First mandatory report | Data for |
|---|---|---|---|
| Large companies already subject to NFRD | Listed companies with more than 500 employees | 2025 (financial year 2024) | 2024 |
| Large companies (without NFRD) | At least two of three: more than 250 employees / more than €40 M net turnover / assets >€20 M | 2026 (financial year 2025) | 2025 |
| Listed SMEs (regulated markets) | Listed on EU regulated markets | 2028 (financial year 2027), deferral confirmed by Directive 2025/794 | 2027 |
| Non-listed SMEs | Voluntary criterion + value-chain pressure | Not mandatory under CSRD (yet) | — |
The key for the non-listed SME lies in the Scope 3 of its clients. When a large company subject to CSRD declares its Scope 3 emissions, it must include those of its suppliers. That means your large client will ask you for emissions data —verified or at least estimated using a robust methodology— to compile its own report. If you do not provide them, you risk losing the contract or being replaced by a supplier who does.
ISO 14064: the reference technical standard for calculation
The ISO 14064 standard is a three-part family published by the International Organization for Standardization:
- ISO 14064-1:2018 — Specification and guidance for organisations that quantify and report GHG emissions and removals.
- ISO 14064-2:2019 — Specification for GHG reduction or removal enhancement projects.
- ISO 14064-3:2019 — Specification for the validation and verification of GHG statements.
Part 1 is the one that directly applies to the calculation of the organisational carbon footprint. It defines how to establish inventory boundaries (operational and financial), how to classify emission sources into Scope 1, 2 and 3, and which emission factors to use. In Spain, the Ministry for Ecological Transition and Demographic Challenge (MITECO) annually publishes national emission factors through its Carbon Footprint Calculator, which is compatible with ISO 14064-1.
Certification under ISO 14064-3 means that an accredited third party verifies the inventory statement. As a consultancy, at Summum Calidad we support the organisation throughout the entire process: from data collection and selection of emission factors to preparing the inventory for verification by an accredited body (AENOR, Bureau Veritas, SGS or others accredited by ENAC). The certification is issued by that third party; we build the system that underpins it.
When is the carbon footprint mandatory for a Spanish SME?
This is the key question, and it deserves a structured answer. Currently in Spain, the calculation and reporting of carbon footprint is mandatory in the following situations:
1. You are a supplier to a company subject to CSRD
If you regularly sell to companies that are obliged to report their Scope 3 under CSRD and ESRS E1, you will receive —if you have not already— sustainability questionnaires or emissions data requests. This is indirect, but it has direct contractual consequences. Industrial and large consumer groups have started including sustainability clauses in their framework contracts since 2024-2025.
2. You take part in public tenders with environmental criteria
Law 9/2017 on Public Sector Contracts allows contracting authorities to include environmental award criteria. Since 2021, the Spanish Government's Green Public Procurement Plan has encouraged calls to include carbon footprint criteria or environmental product declarations (EPD). Although not all tenders require it, the number that do is growing every year, especially in infrastructure, construction, energy supplies and transport services.
3. Your company has more than 250 employees or exceeds the CSRD thresholds
If your SME has grown and meets at least two of the three thresholds that define a "large company" under CSRD (more than 250 employees / more than 40 million euros net turnover / assets above 20 million), you are directly obliged to report under the Directive for the 2025 financial year, with the first report in 2026.
4. You access certain green financing facilities
The European Investment Bank (EIB), the ICO in several of its programmes, and European funds such as ERDF or the Recovery and Resilience Facility, require or value the existence of a verified GHG inventory as an eligibility condition or scoring factor. In practice, many Next Generation EU calls linked to digitalisation and sustainability include this requirement for projects of a certain size.
Voluntary but strategic: the most common case for SMEs
Most Spanish SMEs are not legally obliged to calculate their carbon footprint today. But Summum Calidad's experience —with more than nineteen years supporting management systems— shows that companies that wait for the obligation to be explicit arrive too late. The market moves ahead of the law.
Some indicators that should trigger an internal alert for any SME:
- An important client has sent a sustainability questionnaire in the last twelve months.
- The sector has carbon benchmarks (construction, agri-food, logistics, metal manufacturing).
- The company intends to export to markets where the Carbon Border Adjustment Mechanism (CBAM) affects its products (steel, aluminium, cement, fertilisers, electricity, hydrogen and, from 2026, certain industrial products).
- The aim is to obtain or maintain ISO 14001 certification and improve the coherence of the environmental management system.
In these scenarios, compiling the GHG inventory voluntarily before it is required allows it to be done calmly, with quality data and with the ability to act on the results before there is external scrutiny.
Scope 1, 2 and 3: what is measured and what it costs to ignore Scope 3
A common misconception is to think that the carbon footprint is limited to the emissions from a building and company vehicles. The reality is broader:
| Scope | What it includes | Typical SME examples | Can it be directly controlled? |
|---|---|---|---|
| Scope 1 (direct emissions) | Combustion in own facilities, own fleet vehicles, industrial processes, refrigerant leaks | Gas boiler, delivery van, industrial furnace | Yes |
| Scope 2 (indirect energy) | Emissions associated with electricity, heat or cooling purchased from the grid | Electricity consumption in the warehouse or offices | Yes (by contracting certified renewable energy) |
| Scope 3 (value chain) | Purchases of raw materials and services, subcontracted transport, employee commuting, waste, product use and end of life | Purchased steel, outsourced courier, business flights | Partially (collaboration with suppliers) |
Scope 3 represents, in most industries, between 70% and 90% of an organisation's total emissions (GHG Protocol data, published in its «Corporate Value Chain Accounting and Reporting Standard», available at ghgprotocol.org). Ignoring it not only produces an incomplete inventory: it is precisely the data that large buyers and the CSRD demand most.
Difference between organisational carbon footprint and product carbon footprint
It is worth distinguishing two types of calculation that are often confused:
Organisational carbon footprint (ISO 14064-1): measures all of a company's emissions over a period (normally one year). This is what the CSRD requires and what most large clients' sustainability questionnaires ask for.
Product carbon footprint (ISO 14067 or PAS 2050): measures the emissions associated with the life cycle of a specific product or service. This is what is needed for an Environmental Product Declaration (EPD), required in some sectors (construction, food) to access certain markets or tenders.
Both methodologies are compatible and share emission factors, but they are different projects with different scopes and levels of effort. If your objective is to respond to the CSRD questionnaires of your clients, the organisational footprint is the mandatory starting point.
How it is calculated: the step-by-step process
Calculating an organisational carbon footprint following ISO 14064-1 has a well-defined sequence that, for an SME without organised historical data, typically takes between six and ten weeks of joint work:
- Boundary definition: deciding which legal entities and operations are included (operational or financial control criterion).
- Identification of emission sources: inventorying all relevant categories of Scope 1, 2 and the priority categories of Scope 3.
- Collection of activity data: fuel consumption, electricity, distances, material tonnages, etc. This is the step where most time is lost if the company does not have organised recording systems.
- Selection of emission factors: using those published by MITECO for Spain, or those from the IPCC / DEFRA depending on the geographical scope of the activity.
- Calculation and aggregation: multiplying activity data by emission factors and summing by category and scope.
- Internal review and documentation: preparing the GHG inventory report with estimated uncertainty and justified exclusions.
- External verification (if required): an accredited body (ENAC in Spain accredits GHG verifiers) reviews the inventory and issues a verification statement with reasonable or limited assurance.
If your company already has an ISO 14001 environmental management system in place, the path is considerably shorter: much of the consumption records and environmental aspects already exist; it is a matter of expanding them with the quantitative emissions approach required by ISO 14064.
Carbon footprint registration in Spain: the MITECO programme
The Ministry for Ecological Transition and Demographic Challenge maintains the Registry of Carbon Footprint, Compensation and CO₂ Absorption Projects, currently regulated by Royal Decree 214/2025 of 18 March (which repealed the former Royal Decree 163/2014). Registering is voluntary for most companies, but it has concrete advantages:
- It officially certifies the calculation to clients, public authorities and financial institutions.
- It allows the carbon footprint label to be obtained (calculated, reduced or offset), which some tenders already require as a tiebreaker criterion.
- It facilitates access to the compensation programme with national carbon sinks.
The registry accepts inventories prepared using the MITECO methodology (official Calculator) or with the GHG Protocol / ISO 14064, provided they are properly documented. Registration is free of charge and is managed through the MITECO electronic office.
Frequently asked questions
Does a 30-employee SME need to calculate its carbon footprint?
At present, the CSRD does not directly oblige non-listed SMEs with fewer than 250 employees. However, if that company sells to large industrial groups or listed corporations subject to CSRD, it will very likely receive requests for Scope 3 emissions data from its buyers. In practice, value-chain pressure works as a de facto obligation for any strategic supplier to a large company. We recommend getting ahead with a simple, documented inventory, before urgency makes it impossible to do it rigorously.
Are ISO 14064 and ISO 14001 the same thing?
No. They are complementary standards with different objects. ISO 14001 sets the requirements for an environmental management system (EMS): processes, objectives, operational control, internal audits. ISO 14064 is a standard specifically methodological for quantifying and reporting GHG emissions. Having ISO 14001 implemented makes the ISO 14064 work considerably easier because consumption records and environmental aspects are already identified, but it does not replace the formal GHG inventory. A company can have ISO 14064 without ISO 14001, although both typically go hand in hand in organisations with a mature management system.
How much does it cost to compile a carbon footprint inventory?
The cost depends on the complexity of the company (number of sites, diversity of emission sources, scope of Scope 3 to be covered) and on whether or not external verification is sought. In market terms, inventory projects for industrial SMEs without verification typically fall in a range of €3,000 to €8,000, and projects with external verification at reasonable assurance level can range between €8,000 and €20,000 depending on the certifier chosen. These are indicative market references; each case requires prior analysis. Summum Calidad does not publish fixed fees because every project is different, but we do provide a personalised proposal after a no-cost diagnostic meeting.
Is ISO 14064-3 verification the same as ISO 14001 certification?
They are different processes. ISO 14064-3 verification consists of an accredited third party reviewing the GHG inventory and issuing a verification statement on the accuracy and completeness of the inventory. It does not «certify» the organisation; it certifies the inventory statement. ISO 14001 certification, on the other hand, audits the environmental management system as a whole and issues a certificate of conformity with the standard. A company can have its GHG inventory verified without any formal ISO certification, although the combination of both provides the greatest credibility with clients and public authorities.
What is CBAM and does it affect my SME?
The Carbon Border Adjustment Mechanism (CBAM) is a European Union instrument —Regulation (EU) 2023/956— that was in a transitional phase (without certificate payments) from October 2023 and that, from 1 January 2026, has been in its definitive regime: European importers of certain products (steel, aluminium, cement, fertilisers, electricity, hydrogen and some derived products) must declare the embedded emissions in those imports and purchase CBAM certificates equivalent to the carbon price in the EU ETS market. Coverage will be progressively extended through to 2034, when free ETS allowances for the affected sectors will be eliminated. If your SME imports any of these materials from outside the EU, or if you manufacture products that are exported to markets with carbon regulation (United Kingdom, California), CBAM or its equivalents directly affect you. If you simply use these materials purchased on the European market, the impact is indirect (it may be passed on in the price of the steel or aluminium you buy), but it does not generate direct declaration obligations for you.