Who can verify my Non-Financial Information Statements?

Law 11/2018 establishes the need to verify the Non-Financial Information Statements by an independent service provider. Although the Law does not establish further regulation in relation to this independent service provider, we consider that it should be:

• Independent of the organization obliged to present the Non-Financial Information Statement (Obligated Subject).
• Independent of the firm that assists the organization in the preparation of the Non-Financial Information Statement (Consulting Firm).
• Independent of the accounting audit firm that, according to the law, “must only verify that the aforementioned statement of non-financial information is included in the management report or, where appropriate, the reference corresponding to the report has been incorporated into it separately” (Audit Firm).

In this sense, the Law itself already refers to the role of verification and certification entities by pointing out, for example, that EMAS verification (carried out by this type of entities) can serve as evidence of compliance with the Law on environmental matters.