The transport sector is facing a scenario in which measuring and managing greenhouse gas emissions is becoming increasingly important. The evolution of Spanish regulations, together with growing environmental requirements from customers, tenders and supply chains, means that understanding a company’s carbon footprint is no longer solely an environmental issue, but also a valuable business management tool.

The Sustainable Mobility Law 9/2025 of 3 December reinforces this trend by introducing specific provisions on the calculation and reporting of the carbon footprint associated with transport and mobility services. At the same time, Royal Decree 214/2025 establishes annual carbon footprint calculation and emissions reduction planning requirements for certain companies.

What is changing in terms of carbon footprint requirements?

Spanish regulations are moving towards greater quantification and transparency of emissions associated with transport.

One of the main changes is set out in Article 36 of the Sustainable Mobility Law 9/2025. The law establishes that public and private entities providing or marketing passenger or freight transport or mobility services originating from or destined for Spain will have to calculate the greenhouse gas emissions associated with those services, in accordance with the conditions to be established through the corresponding regulatory methodology.

The law itself establishes that this methodology will need to define aspects such as the minimum scope, deadlines, possible exemptions, and flexibility depending on the type, size or turnover of the entities concerned. The framework is therefore already defined, although some of the practical requirements for its implementation are still to be established.

Europe narrows the reporting scope while Spain maintains its own requirements

The direction of travel is not the same at both levels. In the European Union, Directive (EU) 2026/470 (Omnibus I), in force since March 2026, has raised the CSRD thresholds: only companies with more than 1,000 employees and €450 million in net turnover will be required to report for financial years beginning on or after 1 January 2027. The result is a significant reduction in the number of companies subject to mandatory reporting.

In Spain, the trend is moving in the opposite direction. Royal Decree 214/2025 maintains the obligation for certain companies to calculate their organisational carbon footprint annually (Scopes 1 and 2) and publish a reduction plan with a quantified target over a minimum five-year period. As it is not affected by the European simplification, this framework is becoming a stable reference point in the Spanish market.

There is also a direct commercial impact: the Royal Decree reinforces the use of carbon footprint information as a criterion in public procurement. For companies bidding for public tenders, having a carbon footprint calculation in place is becoming less a reputational matter and more a factor in competitiveness.

And even when many companies fall outside the CSRD scope, the demand for environmental information does not disappear: it moves down the value chain. Large companies subject to reporting requirements need data from their suppliers to calculate their Scope 3 emissions, and transport plays a significant role in this. However, the directive limits what they can require from suppliers with fewer than 1,000 employees to the voluntary standard for SMEs.

Which transport companies are affected?

The new framework has a broad scope. Article 36 refers to public and private entities providing or marketing passenger or freight transport or mobility services originating from or destined for Spanish territory. This brings different types of operators into focus, including companies involved in passenger and freight transport across different modes of transport.

However, it is important to distinguish between an organisation’s carbon footprint and the carbon footprint associated with a transport service.

The former quantifies the emissions generated by an organisation’s own activities, while the latter measures the emissions associated with providing a specific transport service or with an entire transport chain.

In addition, Royal Decree 214/2025 establishes an obligation to calculate an organisation’s carbon footprint annually and prepare a reduction plan for companies already falling under certain non-financial reporting requirements.

Therefore, not all transport companies are currently subject to the same obligations, and each case needs to be assessed according to the company’s activities, size, organisational structure and applicable regulatory requirements.

How is the carbon footprint of a transport company calculated?

Calculating a carbon footprint is not simply a matter of multiplying litres of fuel by an emission factor.

The first step is to clearly define what needs to be measured: the organisation, a specific activity, a route, a transport service or an entire transport chain. The calculation boundaries can then be established and the relevant emission sources identified.

For transport operations, factors may include:

• Fleet fuel consumption.
• Type and characteristics of the vehicles used.
• Distances travelled.
• Tonnes of freight or number of passengers transported.
• Type of transport and operation involved, including multimodal transport operations, where the same shipment combines several modes (road, rail, maritime or air) and each leg has a different emissions profile.
• Operations associated with logistics and intermodal transfer centres, which are also part of the transport chain.
• Data relating to other links in the transport chain when the calculation covers the complete service.

ISO 14083:2023 provides a common methodology for quantifying emissions from transport chains, covering both passenger and freight transport. Its main value in this context is that it enables multimodal chains to be assessed consistently, making different legs operated by very different modes and vehicles comparable.

What information is needed to calculate the carbon footprint?

The quality of the results depends directly on the quality of the available data. Before starting the calculation, it is therefore necessary to identify what information the company has and the level of detail available.

In most cases, it will be necessary to collect information such as activity data (litres of fuel consumed, kilometres travelled, information on routes, journeys and transport modes, tonnes transported, etc.); operational data (vehicle type and model, fuel or energy source, load capacity, distribution of goods or passengers, etc.); and corporate information (calculation period, organisational and operational boundaries, activities included, emission sources considered, etc.).

Beyond compliance: what can a carbon footprint deliver?

For a transport company, calculating its carbon footprint can be about much more than meeting a regulatory requirement. Reliable emissions data makes it possible to identify which operations, routes, vehicles or energy sources have the greatest impact and, based on this information, prioritise reduction measures.

Efficiency and cost savings. What reduces emissions often reduces consumption. Identifying inefficient routes, empty runs, underperforming vehicles or poorly distributed loads can lower fuel costs. In a sector where fuel expenditure represents such a significant cost, carbon footprint calculation can also serve as an efficiency diagnostic.

Resilience. Understanding the structure of emissions and energy consumption helps companies anticipate energy price volatility, traffic restrictions and climate-related disruptions affecting routes and infrastructure. The same information used for reporting can also support contingency planning and the development of alternative options.

Access to contracts. Environmental criteria are already becoming part of supplier assessments. A clear example is cold-chain transport for the food sector: companies operating in this field, often certified under schemes such as IFS or BRC, are increasingly incorporating carbon footprint and decarbonisation requirements into their procurement criteria.

A carbon footprint can therefore become a decision-making tool, rather than simply another indicator to report.

How can LOMARTOV help?

At LOMARTOV, we work with companies and organisations on the environmental assessment of their activities and processes, helping them turn environmental data into useful information for decision-making.

In the transport sector, we can support companies throughout the carbon footprint calculation process, from defining the scope and collecting data to applying emission factors, calculating results and identifying reduction opportunities.

Our approach combines expertise in carbon footprinting, life cycle assessment and environmental evaluation, together with experience in European research and innovation projects related to sustainability and decarbonisation.

We also work to ensure that the calculation does not end with a report, but instead serves as a starting point for identifying reduction measures, optimising resources, reducing operating costs and strengthening business resilience to regulatory, energy and climate-related risks.

Is your transport company ready?

The regulatory framework is still evolving, but waiting until everything is fully developed could mean starting to collect data too late — particularly when requirements often come from a customer or a tender before they come directly from regulation. Anticipating these requirements allows companies to understand what information is available, identify gaps and establish a robust methodology before the requirements become mandatory.

If you would like to understand what this evolving context means for your company, or need support calculating and managing your carbon footprint, get in touch with LOMARTOV.

Find out more about our carbon footprint services for transport companies.