CERSE 2026: what changes in CSR and how it affects your company

Key data

Companies with CSR policies in Spain have a new reference framework as of April 9, 2026. Royal Decree 301/2026 modifies Royal Decree 221/2008, which created the State Council for Corporate Social Responsibility (CERSE), the Government's main advisory body on CSR matters. The reform updates its internal structure, composition and functions to adapt them to the current regulatory context, marked by the entry into force of the CSRD Directive and the European green taxonomy.

This is not a regulation that imposes direct obligations or economic sanctions. But it can condition voluntary reporting frameworks and future public CSR policies in Spain. For companies already working on corporate sustainability, ignoring this change would be a strategic mistake.

What does this regulation establish?

CERSE was created in 2008 through Royal Decree 221/2008 as a collegial body of a consultative nature, attached to the competent Ministry in labor matters. Its mission is to promote and encourage CSR policies in Spain, with representation from business organizations, trade unions and civil society.

Royal Decree 301/2026 introduces a reform of that original framework. The changes focus on three areas:

• Council structure: The internal organization of CERSE is updated to reflect the new institutional context.
• Composition: The representation of different actors is adjusted: business organizations, trade unions and civil society. New actors are likely incorporated or the weight of existing ones is redistributed.
• Functions: The Council's competencies are updated to align them with current corporate sustainability standards, including European regulation on CSRD and green taxonomy.

The Council has no sanctioning power. Its value lies in the recommendations, reports and criteria it issues, which guide both public policies and companies' voluntary reporting frameworks.

Economic and operational impact

The direct economic impact of this regulation is null in the short term: there are no fees, no sanctions, no new reporting obligations directly derived from Royal Decree 301/2026.

However, the indirect impact can be relevant for certain companies:

• The recommendations of the renewed CERSE can become a reference for sustainability audits, CSR reports and certification processes.
• Companies participating in public procurement or seeking access to green financing may be affected if CERSE establishes new reference criteria.
• In the context of CSRD (Corporate Sustainability Reporting Directive), companies required to report on sustainability in Spain may find in CERSE an additional reference framework for their reports.
• Business and trade union organizations with representation in CERSE will need to adapt to the new participation structure.

The operational cost associated with this change is mainly monitoring and strategic adaptation, not direct regulatory compliance.

Who does it affect?

• Companies with active CSR policies that prepare sustainability reports or participate in recognized CSR initiatives.
• Large and listed companies already subject to or in the process of adapting to the CSRD Directive.
• Business organizations with representation in CERSE (such as CEOE or Cepyme) that will need to adapt to the new composition of the Council.
• Trade unions represented in CERSE that will see their participation in the body modified.
• Civil society entities with presence in the Council.
• Sustainability advisors and consultants who guide companies on CSR and non-financial reporting matters.
• CFOs and sustainability directors of companies that report or plan to report under ESG standards.

Practical example

A mid-sized industrial company with 300 employees that annually prepares a sustainability report following GRI standards and is beginning to prepare to comply with CSRD should do the following in response to this change:

Its sustainability director should identify whether the company or its industry organization has representation in CERSE. If so, they should understand how that representation changes with the new structure. In any case, they should monitor the reports and recommendations issued by the renewed CERSE from April 2026 onwards, as these can become a reference criterion for external sustainability auditors or for the Administration in future calls for CSR-related aid.

The cost of this adaptation is mainly time: regulatory monitoring and updating the internal reference framework. There is no direct economic outlay derived from this Royal Decree.

What should companies do now?

1. Verify if your company or sector has representation in CERSE: If you belong to a business organization with a seat on the Council, check how the new composition affects your participation or that of your association.
2. Monitor the recommendations of the renewed CERSE: From April 2026 onwards, the Council will issue criteria and recommendations under its new structure. These may influence voluntary reporting frameworks and public CSR policies.
3. Review your CSR strategy in the CSRD context: If your company is in the process of adapting to the CSRD Directive or the green taxonomy, keep in mind that CERSE can become an additional reference for the Spanish Administration.
4. Update internal sustainability documentation: If you prepare CSR reports or sustainability reports, ensure that your team is aware of the new CERSE framework and can incorporate its criteria when published.
5. Consult with a specialist advisor in corporate sustainability if your company is subject to non-financial reporting obligations or plans to be in the coming years.