The environmental statement is what sets EMAS apart from an environmental management system certified only to ISO 14001: it's a public document that describes the organisation's actual environmental performance with verified data, not just its management system. Regulation (EU) 2018/2026 sets its content and updated the key indicators (Annex IV): energy, materials, water, waste, biodiversity and emissions. It's validated by an ENAC-accredited environmental verifier — never the company or its consultancy — and registered by the competent body in the relevant autonomous community. Typical cycle: a full statement every 3 years and a validated update every year (4 and 2 years for small organisations). Summum Calidad supports its preparation and gets the organisation ready for verification; it doesn't verify or register anything.
The document that sets EMAS apart from ISO 14001
Any organisation certified to ISO 14001 has an environmental management system audited by a third party. But ISO 14001 doesn't require that environmental performance to be made public or registered with any authority. EMAS does: as Spain's environment ministry, MITECO, explains, the structural difference between the two schemes is that EMAS adds a verified, publicly accessible environmental statement, on top of official registration with the competent regional body (MITECO, differences between EMAS and ISO 14001). If your company already has ISO 14001 and is weighing up whether it's worth taking the extra step, the full comparison is in our article EMAS vs. ISO 14001.
This transparency requirement partly explains why Spain has such a mature EMAS register: 853 registered organisations and third place in the European Union as of November 2024, within an EU-wide register that had grown to 4,450 organisations by May 2026. Registering for EMAS means accepting that your environmental statement will be public.
What the environmental statement must contain
The minimum content of the environmental statement is set out in Regulation (EC) No 1221/2009 and was updated by Regulation (EU) 2018/2026, which replaced Annex IV in full to update the key indicators and the statement's content, and also allows it to be reused for the organisation's other reporting obligations (Regulation (EU) 2018/2026). In short, an EMAS environmental statement must include:
| Content block | What it must explain |
|---|---|
| Organisation description | Activity, products, services, sites and structure, with the organisation's name and EMAS registration number |
| Environmental policy and management system | Management's commitments and how they're deployed within the environmental management system |
| Significant environmental aspects | Direct and indirect impacts identified and how they relate to the activity |
| Objectives and targets | Environmental objectives set, and how they relate to the significant aspects |
| Key indicators (Annex IV) | Comparable environmental performance data in the areas set out by Regulation 2018/2026 |
| Applicable legal framework | Reference to the environmental obligations that apply and the degree of compliance |
| Verifier's name and accreditation number | Identification of the verifier who validated the statement and the validation date |
This structure captures the essentials of Annex IV in its current wording. The organisation must adapt it to its actual activity: a generic statement, copied from a sector template, is one of the most common reasons verifiers reject a draft (see below).
The key environmental performance indicators (Annex IV)
Regulation (EU) 2018/2026 strengthened the key indicators so that environmental statements from different organisations can be compared with one another. The broad areas of key indicators set out in Annex IV are:
| Area | What it measures, broadly |
|---|---|
| Energy efficiency | Total energy consumption and the share from renewables |
| Material efficiency | Annual mass flow of raw materials used in the activity |
| Water | Total annual water consumption |
| Waste | Annual waste generation, broken down by type, including hazardous waste |
| Biodiversity | Land use in relation to built-up and sealed surface area |
| Emissions | Annual greenhouse gas emissions and other relevant air pollutants |
The Regulation requires each indicator to be presented with both an absolute figure and an efficiency figure per unit of output or activity, so that environmental performance is comparable regardless of the organisation's size. An indicator expressed only in absolute terms can improve simply because activity has shrunk, without any real gain in efficiency; that's why the verifier checks both readings.
Decision (EU) 2023/2463, which approved the current User's Guide, updated the benchmarking criteria for the indicators and simplified sampling for organisations with multiple sites, while keeping the eight-step process for joining EMAS (Decision (EU) 2023/2463).
How the environmental statement is validated
The environmental statement isn't validated by whoever drafts it, nor by the consultancy that supported its preparation: it's validated by an environmental verifier accredited by ENAC, Spain's national accreditation body designated under Regulation (EC) No 765/2008 (ENAC, environmental verifiers). MITECO describes the verification and validation process as follows:
- The verifier examines the environmental management system documentation, the internal audit procedure and the draft environmental statement.
- It visits the facilities and interviews staff to confirm that what's documented matches actual practice.
- It certifies the reliability, credibility and correctness of the data that ultimately appears in the environmental statement.
- It signs the verifier's statement under Annex VII of Regulation 1221/2009, which accompanies the registration application to the competent body.
Source: MITECO, EMAS verification. Verifiers accredited in Spain include AENOR, Bureau Veritas, DNV, Applus (LGAI), Lloyd's Register and SGS; none of them is Summum Calidad, and that's exactly how it should be: the Regulation requires the verifier to be independent of the consultant who helped implement the system.
How often it's updated and renewed
The frequency for updating the environmental statement is set by Regulation 1221/2009 and developed further by Real Decreto 239/2013 (Spain's national decree implementing the EMAS Regulation):
- Every year, an update to the environmental statement is validated (it doesn't need to be rewritten in full, but the year's data and indicators do need to be reviewed and validated).
- Every 3 years, a full environmental statement is validated, coinciding with the renewal of the registration.
- Small organisations meeting the requirements of Article 7 of Regulation 1221/2009 get an extended timetable: an update every 2 years and a full validated statement every 4 years.
- The verifier must cover the entire environmental management system within a maximum of 36 months.
Source: Real Decreto 239/2013 (BOE-A-2013-3906). In Castilla y León, for example, renewal requires the full record and a validated statement every 3 years; in the years in between, a validated update filed with the Junta's Environmental Assessment Service is enough.
Who does what: consultancy, verifier and competent body
The three roles are often confused, so it's worth spelling them out:
| Who | What they do | What they don't do |
|---|---|---|
| Consultancy (Summum Calidad) | Supports the initial environmental review, system implementation and drafting of the environmental statement; prepares the organisation for verification | Doesn't validate or certify the statement; isn't accredited as a verifier |
| Environmental verifier (ENAC-accredited) | Examines the system and the statement, visits the facilities, validates the data and signs the Annex VII statement | Doesn't implement the management system of the organisation it verifies; must be independent |
| Competent body (regional government) | Receives the application, checks the documentation and decides on registration or renewal in the EMAS register | Doesn't verify the statement's technical content: it relies on the verifier's validation |
This division of roles is required by Regulation 1221/2009 itself: the public register only makes sense if whoever validates the data is independent of whoever produces it.
Common mistakes that delay validation or registration
- Copying a generic sector template instead of describing the organisation's actual environmental aspects and sites.
- Reporting only absolute indicators, without the efficiency-per-unit-of-activity figure that verifiers usually ask to have completed.
- Failing to update the applicable legal framework: repealed regulations or expired permits that no longer match current activity.
- Presenting data with no traceability back to internal records or invoices.
- Forgetting the non-technical summary that the Regulation expects for a non-specialist audience.
- Confusing the annual update with the full statement in the renewal year, when a complete, validated statement is required instead.
- Failing to coordinate deadlines: filing the renewal outside the three months before the registration expires.
Most of these mistakes don't show up while the system is being implemented, but when moving from "having the data" to "writing a public, verifiable document". That's where dedicated support — distinct from the verifier's work — helps most.
Frequently asked questions
Does the EMAS environmental statement have to be public?
Yes. Unlike a system certified only to ISO 14001, a validated EMAS environmental statement is publicly accessible: it's the element MITECO identifies as the structural difference between the two schemes.
Who validates the environmental statement, the consultancy or the verifier?
Always an ENAC-accredited environmental verifier, an independent third party. Summum Calidad supports its preparation and gets the organisation ready for verification, but can't validate it or stand in for the verifier.
How often must the environmental statement be updated?
As a general rule, an update is validated every year and a full statement every 3 years, alongside the registration's renewal. Small organisations (Article 7 of Regulation 1221/2009) get extended timeframes: 2 and 4 years.
What happens if the competent body doesn't decide in time?
Real Decreto 239/2013 (Spain's national EMAS implementing decree) sets a maximum deadline of 3 months; if it passes with no express decision, positive administrative silence applies and the registration is deemed approved.
Are the key indicators the same for every sector?
The Annex IV areas (energy, materials, water, waste, biodiversity and emissions) are common to all, but each organisation must decide which aspects are significant for it and how it measures them; copying indicators from another company in the sector is one of the most common mistakes.
Can I use the EMAS environmental statement for other reporting obligations?
Yes: Regulation (EU) 2018/2026 expressly allows its content to be reused for other environmental reporting obligations, provided the minimum requirements of Annex IV are still met.
Official sources
- Regulation (EU) 2018/2026 — new Annex IV and key indicators (EUR-Lex)
- Regulation (EC) No 1221/2009 EMAS, consolidated text (EUR-Lex)
- Decision (EU) 2023/2463 — EMAS User's Guide (EUR-Lex)
- Real Decreto 239/2013 (BOE-A-2013-3906)
- MITECO — EMAS verification process
- ENAC — accredited environmental verifiers
Summum Calidad supports the implementation of EMAS and the preparation of the environmental statement, including getting ready for verification. Validation depends on an ENAC-accredited verifier, and registration depends on the competent body in your autonomous community. If you're weighing up the two schemes, see EMAS vs. ISO 14001; if you already know you want EMAS, check certification costs and timelines, and if you tender for public contracts, see EMAS for public tenders.