The Spanish Public Audit and Accountancy Institute (Instituto de Contabilidad y Auditoría de Cuentas) recently issued a decision intending to clarify certain issues regarding the new obligation of preparing a consolidated non-financial statement (CNFS).

This obligation applies to groups with more than 500 employees and, in addition, during two consecutive financial years since 2017, meet 2 from the 3 following requirements: Consolidated assets over 20 million euros; turnover over 40 million euros; and average number of employees over 250.

The new decision states the following clarifications:

  • The CNFS to be prepared by the parent company must include all the subsidiaries worldwide.
  • Spanish subsidiaries are exempted from this obligation if the parent company prepares the CNFS, either if such parent company is being domiciled in Spain, in another member state of the EU and in a third country.
  • If the non-resident parent company did not provide with all the information requested by the Spanish law (which is more extended than the EU Directive), the Spanish subsidiary might provide, in its own CNFS, the complementary information requested by the Spanish legislation. This is also applicable if the Spanish subsidiary is in turn the parent company of a subgroup.
  • Separate companies obliged to prepare the CNFS at a single level are also obliged to have verified such CNFS by a third party verifier.

Please find attached this new decision (which is in Spanish).

Should you need further information please do not hesitate to contact us.

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