Has the Spanish non-financial information regulation become a socially accepted norm?: Special emphasis on the road passenger transport sector

There is an increasing societal awareness of social and environmental issues, and the necessity to adhere to practices that do not jeopardise the resources of current and future generations (Zanellato and Tiron-Tudor, 2022; Hichri and Alqatan, 2024). In this context, companies assume a pivotal role in the pursuit of a more sustainable world (Erin and Bamigboye, 2022), and stakeholders seek to ascertain their commitment to sustainability, as evidenced by the increase in the publication of sustainability reports (Christensen et al., 2021; Alqatan and Hichri, 2025). While sustainability reporting (SR) has been chiefly a voluntary practice (Bebbington et al., 2012), some settings, such as the European Union, have opted to establish minimum mandatory disclosure requirements for companies deemed to be in the public interest (Esteban-Arrea and Garcia-Torea, 2022).

The notion that sustainability disclosure can drive effective change (Adams and McNicholas, 2007) has led to the belief that mandatory disclosure can accelerate the institutionalisation of this type of reporting (La Torre et al., 2018; Leong and Hazelton, 2019). Furthermore, sustainability accounting regulations may address the issues of quality, comparability and neutrality that are often associated with voluntarily disclosed sustainability information (Aureli et al., 2020).

An example of confidence in the capacity of regulation to enhance corporate sustainability and overcome the limitations of voluntary disclosure is the implementation of Directive 2014/95/EU (La Torre et al., 2018). This directive requires member states to regulate the disclosure of information by public interest entities concerning environmental, social and employee matters, as well as respect for human rights, and issues related to anti-corruption and bribery (Esteban-Arrea and Garcia-Torea, 2022).

Although earlier research conducted prior to Directive 2014/95/EU on Non-Financial Information (NFI) found that sustainability accounting regulations did not consistently improve accountability (Chelli et al., 2018; Senn and Giordano-Spring, 2020), the latest empirical evidence regarding its impact remains inconclusive. Some studies found that the Directive 2014/95/EU on NFI has increased the quantity and quality of sustainability information disclosed by European companies (Zanellato and Tiron-Tudor, 2022; Asadi et al., 2024). Meanwhile, other scholars found no significant impact on the quality of sustainability disclosure levels following the implementation of the Directive (Korca, 2021; Posadas et al, 2023).

Some authors have argued that the effectiveness of regulation in institutionalising the practice of SR depends on several structural conditions (Bebbington et al., 2012; Luque-Vílchez et al., 2024). From a constructivist perspective, it is important to understand not only the law’s success but also the regulatory process and context that influence its effectiveness. This analysis can provide valuable insights into how regulation can alter collective SR behaviour.

Based on the aforementioned considerations, the primary objective of this paper is to assess the impact of Spanish NFI regulation on the processes driving SR in becoming a social norm in Spain. The focus of this study will be specifically on the road passenger transport sector, with additional evidence from other business industries. In light of the above, the following research questions (RQ) are posed:

To address the preceding RQs, we have used a qualitative research methodology, combining data from two main sources: interviews and documents, including reports and legislation. It enables us to conduct a historically informed analysis of how SR emerges and develops alongside the socio-political and cultural factors that shape this activity. The period analysed in this study extends from 2010 to 2022.

The theoretical framework underpinning these questions draws upon Bebbington et al.’s (2012) notion of normativity, which highlights how a norm becomes a practice assumed by all. In particular, it considers that the production of a norm requires the examination of three internal and structural conditions that legitimise the emergence of a norm (“why”): coherence with accepted practices, congruence with existing normative frameworks and clarity in the design of the norm.

For our research purposes, the Spanish context has been selected as the object of study, given the government’s instrumental role in promoting the disclosure of sustainability information at the institutional level (Archel et al., 2011; Reverte, 2015). Spain has demonstrated a remarkable evolution and early recognition in the disclosure of sustainability information, evidenced by pre-EU Directive initiatives and a high positioning in the recognition of climate change as a financial risk and the connection of business activity to sustainability issues (Posadas et al., 2023).

The decision to pay particular attention to the road passenger transport sector is based on its significant influence in fostering a more sustainable society, as companies in this sector are responsible for greenhouse gas emissions that negatively impact the environment (Aminzadegan et al., 2022). SDG 11, named “Sustainable Cities and Communities”, is linked to public transport and sustainability. Its target 11.2 stipulates that “By 2030, provide access to safe, affordable, accessible and sustainable transport systems for all, improving road safety, notably by expanding public transport […]”. In addition, these companies play a crucial role in reducing reliance on private vehicles, enhancing connectivity and promoting socio-economic development within communities (Hidalgo and Huizenga, 2013), as well as impacting other sectors (Escamilla et al., 2016).

This study contributes to the extant literature in different ways. Firstly, it tries to shed light on how socio-political, cultural and historical factors contribute to explaining why SR regulation becomes a socially accepted norm (Luque-Vílchez et al., 2024. Most of the extant literature focuses on the outside perspective of SR rather than considering the process of preparing these reports (Contrafatto, 2014). Therefore, some scholars have called for more research to provide a historically informed analysis of how SR becomes institutionalised (Albu et al., 2021). To fill this research gap, the notion of normativity developed by Bebbington et al. (2012) is well-suited for our purposes. The theoretical explanation and understanding of the processual dynamics related to the institutionalisation of SR remain underdeveloped (Contrafatto et al., 2019). Few studies have relied on normativity to examine how companies have changed their sustainability disclosure patterns over time after implementing laws and regulations (Chauvey et al., 2015; Chelli et al., 2018).

Secondly, the approval of the EU Directive on NFI opened a new avenue for further research on SR driven by mandatory reporting requirements (La Torre et al., 2018). Since its approval, the literature has explored how the shift from voluntary to mandatory SR in Europe has impacted this activity (Aureli et al., 2020; Posadas et al., 2023). Mostly, this prior empirical literature has quantitatively examined two main topics: How the European NFI regulation has affected the quality and quantity of sustainability information provided by companies (Donner et al., 2024); and How corporate characteristics, general contextual factors and internal attributes, influence the quality and quantity of the sustainability information disclosed (Zarzycka and Krasodomska, 2022). Given the increasing institutional interest in SR in Europe (Giner and Luque, 2022), it is very timely to investigate how the Spanish NFI regulation has affected the production of a norm in SR in a particular setting.

The remainder of this paper is structured into six sections. Section 2 presents the theoretical framing that guides the analysis. Section 3 describes the research design. Section 4 illustrates the empirical analysis. The findings are then discussed in Section 5. Finally, Section 6 outlines our conclusions.

Following Archel et al. (2011, p. 328), “the process of institutionalisation in a specific field is complex and it is driven by the interactions of social actors with different interests but also with an unequal influence on the establishment of the rules, values, beliefs and norms that will govern the behaviour within the field”. For some time now, institutionalists have advocated for structuralist approaches to examine the processual dynamics of how and why SR evolves (Eitrem et al., 2024; Mahmood et al., 2024).

Within this stream of research, normativity is defined as the degree to which actors perceive rules as binding (Bebbington et al., 2012; Chauvey et al., 2015). Therefore, norm refers to a process that results in a consistent pattern of behaviour, aligning expectations and practices, rather than simply adhering to the formal requirements established by law (Chelli et al., 2018; Luque-Vílchez et al., 2024). Normativity is not “an inherent quality of legal mandates, but instead must meet the test of legitimacy” (Chauvey et al., 2015, p. 791). Consequently, formal SR regulation does not necessarily lead to normativity (Bebbington et al., 2012; Chelli et al., 2018).

To effectively establish formal laws, there must be accompanying internal structural conditions that foster an appropriate normative climate (Luque and Larrinaga, 2016). These internal conditions are affected by how the social context creates a discourse promoting the development of SR practices (Larrinaga and Bebbington, 2021). Indeed, the conformity of the law with the social context is crucial for it to become a socially accepted norm (Luque-Vílchez et al., 2024).

Bebbington et al. (2012) identified three key internal conditions that must be met for a norm to be considered legitimate. Firstly, the norm should be integrated into a coherent normative framework. Secondly, the norm should be consistent with similar practices that have been previously adopted. Finally, the norm should be unambiguous, so that it can be easily applied in practice.

The first condition stems from the alignment with existing accepted frameworks or standards. Institutional theorists have long highlighted that SR has become an institutionalised practice among the largest companies around the world (Higgins et al., 2018). Initially, the Global Reporting Initiative (GRI) guidelines were developed following the structure of the financial reporting framework provided by the Financial Accounting Standards Board (Levy et al., 2010). This analogy between SR and financial reporting gave legitimacy to the GRI and its guidelines (Etzion and Ferraro, 2010). The GRI designed its social and environmental indicators to measure the sustainability impacts of organisations following previous environmental management systems and other standards (Larrinaga and Bebbington, 2021). It meant that the reporting framework developed by the GRI was validated through the use of previously accepted performance indicators (Luque-Vílchez et al., 2024).

The second condition has its roots in the early publication of social and environmental impacts by companies. (Milne and Gray, 2013). Even before the triple-bottom-line approach, businesses started to include narrative disclosures of social and environmental topics in their annual reports (Higgins et al., 2015). In the 1990s, they began producing separate reports focusing on these issues (Milne and Gray, 2013). In agreement with Bebbington et al. (2012, p. 86), the production of a norm “depends upon its congruence with previous similar practices and conventions that create relatively stable patterns of expectations or shared understandings”. In developing its reporting frameworks, the GRI followed the model of previous environmental reports published by companies (Larrinaga and Bebbington, 2021).

The third condition for determining the effectiveness of reporting norms is whether the design of the norm is precise and clear for its intended purposes (Bebbington et al., 2012). Accounting experts have criticised the complexity of translating the term “sustainable development” to corporate reporting practices (Bebbington and Larrinaga, 2014). One of the reasons behind this is the difficulty in linking organisational performance to sustainable development through the measurement and reporting of indicators (Milne and Gray, 2013). In this regard, consultants have played an important role in clarifying the specifics of SR and how it should be carried out (Larrinaga and Bebbington, 2021).

These institutional conditions are shaped by the historical and socio-political landscape that helped us to understand how a legitimate norm could be established in SR (Luque-Vílchez et al., 2024). The study of the societal context provides exogenous evidence for the normativity production in reporting practices (Larrinaga and Bebbington, 2021).

According to previous research, normativity is not necessarily under the monopoly of governments through formal laws or legal rules (Bebbington et al., 2012; Larrinaga and Senn, 2021). Indeed, normativity can be achieved by the agency of a plurality of actors (Chelli et al., 2018; Luque-Vílchez et al., 2024). The literature identifies four main groups of institutional actors contributing to the establishment of norms in SR: institutional entrepreneurs, epistemic communities, carriers and regulators/reporters (Larrinaga and Bebbington, 2021).

According to Contrafatto et al. (2019, p. 1778), the concept of institutional entrepreneurship is used to “describe the ability of innovative individuals or collective actors to change existing institutions […] These “innovative” individual/collective actors […] are able to mobilise resources (e.g. knowledge and charisma) to exert some form of agency for challenging, transforming and disrupting institutions”. The literature identifies two primary innovative actors in the field of SR (Vinnari and Laine, 2013; Larrinaga and Senn, 2021). Firstly, the GRI’s reporting guidelines have become a significant catalyst for change in SR within the corporate sector (Brown et al., 2009). Since its inception, the GRI has become the most widely accepted standard for SR (Higgins et al., 2018). These guidelines provided legitimacy to SR and helped to institutionalise this activity among the largest companies around the world (Larrinaga and Bebbington, 2021). Secondly, employees or managers in an organisation often take on the role of internal champions, leading the way for SR (Bebbington et al., 2012; Vinnari and Laine, 2013). They took on the role of an innovative actor by creating a sustainability report to communicate their social and environmental impacts to stakeholders (Contrafatto et al., 2019).

Following previous literature, epistemic communities are academics and experts who can generate new ideas about SR (Larrinaga and Senn, 2021). In this scenario, the seminal Brundtland report introduced the most widely accepted definition of sustainable development (Bebbington and Unerman, 2018). Since then, this concept has been embraced at the corporate level, with companies beginning to adopt practices aimed at pursuing a sustainable agenda (Bebbington et al., 2023). In Spain, organisations, such as the Club of Excellence in Sustainability and the Corporate Social Responsibility (CSR) Observatory, have become leading experts capable of influencing corporate practices aimed at advancing sustainable development (Husillos et al., 2011).

Carriers are actors capable of transferring practices and ideas regarding what constitutes appropriate SR (Larrinaga and Bebbington, 2021). Under the umbrella of professional organisations, consultants or auditors, they deploy experts and shape norms in the field of SR by spreading awareness and training (Larrinaga and Senn, 2021; Mahmood and Uddin, 2021). In 2016, Foretica, the World Business Council for Sustainable Development’s representative in Spain, established a Cluster focused on transparency and good governance. It advocates for a sustainable governance model and serves as a platform for companies to collaborate and share their sustainability strategies ^[1].

Finally, governments, regulators and reporters are influential actors in stabilising norms (Larrinaga and Senn, 2021). In recent decades, governments and regulatory bodies have encouraged SR through a mix of voluntary and mandatory initiatives, which include binding laws and recommendations that lack legal requirements (Archel et al., 2011; Arena et al., 2018). In a context of soft law, the European Commission, via the Eco-Management and Audit Scheme (EMAS), requires all organisations that voluntarily adopt an environmental management system to elaborate an environmental report (Higgins and Larrinaga, 2014). Reporters in soft law can modify and refine norms from two key perspectives: by participating in multi-stakeholder processes that focus on the development of SR, and by leveraging their experience and expertise to determine which types of reporting are the most relevant (Larrinaga and Bebbington, 2021).

Before the publication of the Green Paper elaborated by the European Union in 2001, the Spanish Government did not play a relevant role in the promotion of sustainability-related practices (Cantó and Lozano, 2009; Archel et al., 2011). The only exception was the issuance of the environmental disclosure standard in the financial statements elaborated by the Institute of Accounting and Auditing (ICAC in Spanish) in 2002 (Criado-Jiménez et al., 2008) ^[2]. Since the issuance of the Green Paper, the Spanish Government initiated a public debate about developing policies aimed at stimulating SR as a pillar of transparency (Archel et al., 2011). This was materialised in a process of dialogue with different stakeholders, resulting in four main consultative bodies: the Expert Forum on CSR, the Parliamentary Sub-Commission on CSR, a working group in the Roundtable on Social Dialogue and the State Council on CSR (Luque-Vílchez et al., 2024).

The Expert Forum on CSR was established by the Ministry of Labour and Social Affairs on 17 March 2005 to provide counsel to the government on CSR issues. It was integrated by a broad range of actors belonging to different socio-political and economic spheres: governmental members from different Ministries, experts from enterprises, universities and social organisations. In the same year, the Parliamentary Sub-Commission on CSR was established and composed of all interested actors. This consultative body launched the White Paper on CSR, in which the sustainability report was conceived as a key management tool to communicate the company’s efforts devoted to social and environmental activities. Two years later, the Spanish Government issued the CSR working group in the Roundtable on Social Dialogue to discuss the implementation of public policies related to sustainability issues. The State Council for Corporate Social Responsibility was established in 2008 as an advisory and consultative body attached to the Ministry responsible for public policies to promote CSR at the corporate level. Its composition encompassed 56 members, representing four distinct stakeholder groups: business organisations, trade unions, experts and professionals in CSR and public administrations. This period of dialogue crystallised in the enactment of the 2/2011 Spanish Sustainable Economy Law (Luque-Vílchez et al., 2024). Articles 35 and 39 of this legislation introduced mandatory SR requirements for State-Owned Enterprises (SOEs) and large companies, respectively (Luque and Larrinaga, 2016; Larrinaga et al., 2018).

Meanwhile, the European Strategy on CSR for the period 2011–2014 issued by the European Commission was the take-off point for the debate on SR regulation in Europe (Reverte, 2015). As a result, the European Parliament approved the Directive 2014/95/EU on NFI to improve transparency and corporate accountability in European large companies through a process of harmonisation and standardisation of the practice of SR (La Torre et al., 2018). Following EU policies, the Spanish Government transposed the EU Directive 2014/95 to its national legal system through the Law 11/2018 on NFI. Before the enactment of this legislation, regulators had enacted the Royal Decree-Law 18/2017, which required Spanish public interest entities to provide similar non-financial disclosures according to the mandatory reporting requirements indicated in the EU Directive (Sierra-Garcia et al., 2018). Spain was among the later European nations to transpose the EU Directive into its national legislation, a delay that facilitated the inclusion of supplementary issues beyond the mandatory requirements of the EU Directive.

The current scenario regarding SR regulation is marked by the Corporate Sustainability Reporting Directive (CSRD) 2022/24664 and the European Sustainability Reporting Standards (ESRS) developed by the European Financial Reporting Advisory Group (EFRAG) (Giner and Luque, 2022). The Spanish Government has not yet transposed this Directive. On 19 November 2025, the National Securities Market Commission (CNMV in Spanish), together with the ICAC published a statement to guide companies on SR until the CSRD Directive is transposed into Spain ^[3]. They recommend that major issuers prepare their 2025 sustainability information in accordance with the CSRD Directive and the ESRS and consider the flexibility introduced by the new Omnibus proposal.

The present study focused on the set of companies in the road passenger transport sector that, since 2021, must prepare an NFI statement according to Spanish regulation. Following the requirements established in the Law 11/2018 on NFI, companies with a workforce exceeding 250 people have to prepare an NFI statement if they fulfil one of the following criteria: they are deemed public interest entities, or their total assets exceed €20,000,000, or their annual turnover surpasses €40,000,000 for two consecutive years.

In Spain, the road passenger transport sector, composed of 1,750 companies^[4], has a relevant contribution to the national Gross Domestic Product, and furthermore acts as a driving factor for the economic development of other sectors (Escamilla et al., 2016). Information from the Spanish Emissions Inventory System for the period 1990–2019 indicates that the transport sector has become the main generator of Greenhouse Gas (GHG) emissions in Spain, accounting for 29% of the total emissions. Of this, 93% is attributable to land transportation, which in turn represents 27% of overall GHG emissions. Data from SABI for the financial year 2022 indicates that only 35 out of these 1,750 road passenger transport companies in Spain employ more than 250 workers. It is noteworthy that 6 of these 35 companies were not required to prepare an NFI statement, despite exceeding the 250-employee threshold. This was because they did not comply with the additional criteria related to: public interest entity, or asset, or turnover volume. Consequently, 29 companies constituted our sample. From institutional thinking, they are inserted into the same organisational field because they “interact and, by so doing, collectively shape norms and expectations within that context” (Higgins et al., 2018, p. 310). According to DiMaggio and Powell (1983), firms within the same sector tend to adopt homogeneous behaviours due to shared pressures.

To accomplish our purposes, we performed a qualitative research study, as this approach enables the capture of contextual and dynamic complexity of “living” organisations (Irvine and Gaffikin, 2006). Our qualitative study spanning 2010–2022^[5] combined two main data sources: interviews and documents. Combining these data collection procedures allows for triangulation of information, which provides validity and reliability to the information obtained (Narayanan and Adams, 2017). Also, field notes taken during attendance at meetings and workshops concerning the influence of regulation on SR served to corroborate the findings from the primary two data sources.

The empirical data of our paper was primarily based on interviews. As stated by Tucker (2021), interview-based research offers a richer analysis and interpretation of empirical data. This method yields nuanced insights into phenomena and helps to understand the historical, cultural and social context in which actions occur.

We conducted 36 structured and semi-structured interviews at two different times, using a purposive sampling method to ensure that the selected participants had specific knowledge and experience on the topic (Alqatan, 2025). Firstly, we created a list of open-ended questions that were aligned with our research objectives and theoretical framework. These questions were formulated to examine how Spanish Law 11/2018 on NFI has impacted the institutionalisation of SR in Spain. The interviews, conducted between September 2020 and June 2022, involved 12 managers from publicly listed companies and 5 managers from large SOEs in various industries. In total, these 17 participants were responsible for overseeing the SR strategies of their respective companies. These companies were required to prepare an NFI statement at the time the interviews were conducted. The protocol for these interviews was guided by the central theme of understanding how Spanish Law 11/2018 on NFI influenced the reporting behaviour of these organisations ( Appendix 1).

Secondly, 19 interviews, from March to April 2025, were conducted with three distinct groups of actors with recognised expertise in sustainability-related practices within the road passenger transport sector: managers from reporting companies, managers from non-reporting companies and experts from professional organisations. These interviews were conducted using a pre-established protocol comprising a list of questions aligned with our theoretical framework ( Appendix 2). The number of interviews conducted was deemed optimal because conducting additional interviews would yield “little or no incremental insights into the phenomena investigated” (Tucker, 2021, p. 232).

Table 1 presents detailed information about the profiles of participants based on the following attributes: actor, interviewee code, participant position/role, date, type and length of the interviews.

Of the total interviews, 9 were semi-structured, and the other 27 followed a structured format. Semi-structured interviews are the primary format used in qualitative research (Farneti et al., 2019). However, structured interviews conducted via email can also be an effective data collection method, as they consist of predetermined questions (Hawkins, 2018). One key advantage of email interviews is their flexibility, allowing participants to respond at their convenience. In addition, because responses are recorded in written form, data analysis can be more objective, eliminating the need for note-taking and reducing subjectivity. Despite these advantages, structured interviews do have limitations. One potential drawback is that the rigid format may lead to brief responses, as participants cannot deviate from the set questions (Hawkins, 2018; Farneti et al., 2019). In this way, semi-structured interviews enable the interviewer to ask standard questions while also exploring topics introduced by the interviewee (Berg and Lune, 2012).

The structured interviews varied in length, ranging from 190 to 1,843 words. The semi-structured interviews, which lasted between 16 and 45 min, were conducted via telephone or videoconference using Google Meet or Zoom. The structured interviews were conducted using the pre-established protocols previously mentioned (Appendices 1 and 2). Meanwhile, the semi-structured interview commenced by soliciting participants’ perspectives on the principal factors influencing road passenger transport companies’ engagement, or lack thereof, in SR. Subsequently, the interviewers (two members of the research team) guided the conversation towards themes corresponding to the questions outlined in the second interview protocol ( Appendix 2). By employing a standardised interview guide with relevant questions, the interviewer mitigates potential biases associated with the semi-structured interviews (Luque-Vílchez et al., 2024). Given that the participants were experts in the field, this guide ensures that we are focusing on the expertise of each interviewee.

For all semi-structured interviews, both interviewers took field notes during the interview process. Thereafter, the two interviewers met to reconcile their respective notes and thus reach a shared understanding. Finally, the information agreed upon by both researchers was transcribed into a Word document. For structured interviews, participants provided written responses via email. This simplified the transcription process into a Word document.

Three types of documents were used to validate, complement and provide context to interview findings, consistent with previous research (Narayanan and Adams, 2017; Mahmood et al., 2024).

Firstly, sustainability-related documents published by each company from 2010 to 2022 were compiled to provide a historical analysis of how SR has evolved over time. During this period, Spanish road passenger transport companies used three formats of report to reveal their sustainability impacts: the annual report, the sustainability report and the NFI statement. As a result, we collected and analysed a total of 204 corporate annual reports published by the list of companies sampled during the period of analysis.

Secondly, we examined the two main SR regulations that have been issued by the Spanish Government. They were selected to determine whether their content meet the conditions that allow the creation of a norm according to our theoretical framework.

Thirdly, we performed a historical analysis of different documents that emerged during the process by which the EU Directive was transposed into the 11/2018 Spanish law on NFI (e.g. professional reports, technical articles and media reports and blogs). These sources were selected to corroborate whether the formal regulation was in line with existing practices and reporting frameworks (Luque-Vílchez et al., 2024).

Table 2 provides a detailed list of the documents analysed in our study.

We followed the subsequent analytical procedure to accomplish our research goals.

For our first RQ, our data sources were the corporate reports published by Spanish road passenger transport companies. In particular, we tracked a historical analysis of the number of reports published by each company annually from 2010 to 2022. We grouped the reports into two categories: those published before 2018 and those published after. This grouping enabled us to evaluate the impact of the Spanish NFI regulation on the reporting strategies of Spanish road passenger transport companies. To analyse this, we conducted two distinct descriptive analyses:

1. Firstly, we looked at the length of the reports published by the sampled companies. In line with previous research (Contrafatto et al., 2019), we measured the quantity of sustainability disclosure using the number of pages.

2. Secondly, we performed a quality analysis of the reports based on two criteria: the reporting framework and external assurance. These criteria allowed us to determine whether the reports followed the GRI guidelines and the reports were verified by an external assurance provider. The descriptive analyses were performed manually.

For our second research question, we primarily used data from interviews, supported by evidence from the Spanish Law 11/2018 on NFI^[6]. We performed a thematic content analysis of the interview data to examine it in depth (Alqatan, 2025). This process involved a reflexive, interpretative and iterative approach that integrated empirical data with the institutional actors identified in our theoretical framework (Larrinaga and Bebbington, 2021). In our data analysis, we used the theme as the unit of measurement (Deegan, 2002). We then defined the categories under which each theme would be organised. Guided by our theoretical framework, we initially identified four main categories to code the information extracted from the interviews: institutional entrepreneurs, epistemic communities, carriers and regulators/reporters. For each category, we identified the actors involved in the development of sustainability-related documents within Spanish road passenger transport companies. To achieve this, we referenced the list of institutional actors outlined in our theoretical framework.

The transcribed data from the interviews were analysed as follows. Initially, one researcher read and coded a sample of the text from the transcriptions to ensure the accuracy and reliability of the coding process. This involved taking notes on relevant issues raised during the interviews. After confirming that there were no ambiguities, the researcher proceeded to read and code all of the transcribed data. This approach helped to minimise inter-coder variability and ensured consistency throughout the coding process (Kansal et al., 2018). The accuracy and validity of the thematic content analysis were supported by the categories and themes derived from our theoretical framework. To provide evidence for our findings, we selected quotations from several interviews. Following the methodology outlined in existing literature (Contrafatto, 2014), these quotations were translated from Spanish to English. Consistent with Feldermann and Hiebl (2020, p. 229), “translation is an act of sense-making and reconstruction of meaning”, involving the transfer of meaning and context, rather than merely finding the right words, to ensure its credibility. After translating the text, quotations from interviews were used to “provide a sense of meaningfulness to the interpretive claims advanced by the authors” (Dai et al., 2019, p. 29).

For the SR regulation, we used an inductive approach to examine the content of Law 11/2018 on NFI to corroborate the insights drawn from interviews (Luque-Vílchez et al., 2024). It meant reading and analysing data without preconceived categories (Azungah, 2018).

For our third RQ, the primary data source was derived from interviews. We also relied on evidence from SR regulations, reports published by professional organisations and media articles to support the findings from the interviews. Analytically, we followed the same procedure as we did for the second RQ.

The only difference in our approach was the use of a different coding scheme to categorise the information gathered from the interviews. Building on the concept of normativity, we identified four categories for coding: societal context, coherent normative framework, previous similar practices and clarity. For each category, we outlined the themes and elements related to the societal context and the institutional conditions that support the establishment of norms in SR. Table 3 summarises the data sources and the analytical procedure used to address each RQ.

The analysis of the different data sources was performed from March 2025 to July 2025.

This section analyses the evolution of SR within the road passenger transport sector from 2010 to 2022. We identified two distinct periods to present the case: the pre-implementation and post-implementation stages of the Spanish NFI regulation. The initial period spans from 2010 to 2017, during which the law did not require companies to produce an annual SR. The second period covers 2018–2022, during which certain companies were required to prepare NFI statements.

Table 4 shows the patterns of reporting behaviour among these companies from 2010 to 2017.

Our results reveal that this period, where SR was a voluntary practice, is marked by the limited number of reporters. Four Spanish road passenger transport companies started to adopt sustainability-related reports in 2010: two companies employed the format of an annual report and the other two companies used the sustainability report format. Since then, the number of reporting companies has increased from four to nine. An in-depth analysis reveals that the common trend among reporting companies during this period was the publication of a document following the format of an annual report to provide qualitative and narrative disclosure of social and environmental initiatives. Most of the information contained in such reports was related to the service provided to clients, employees, customer satisfaction, quality and the environment. Except for some cases, these companies did not use the GRI reporting framework to disclose key sustainability indicators. Indeed, they did not provide quantifiable measurements of sustainability performance. Furthermore, the reports published by the companies during this period were not externally verified by a specialised company.

Table 5 shows a change in the reporting behaviour pattern of Spanish road passenger transport companies since 2018.

During this period (2018–2022), the number of companies publishing sustainability reports has increased. However, the GRI has not become a widely accepted standard for measuring and disclosing the social and environmental impacts in these sustainability reports. Also, these sustainability reports have not been externally verified by a third-party assurance provider. The most significant change in the pattern of corporate reporting behaviour has materialised in the gradual increase in the number of companies that have prepared NFI statements. Mostly, companies that have produced these NFI statements have followed the GRI reporting framework to disclose their sustainability impacts. Also, almost all companies with NFI statements have declared in these reports that they have been subjected to external verification by an assurance service provider.

These findings appear to suggest that the transition from a voluntary to a mandatory SR regime in Spain has influenced the collective behaviour of Spanish road passenger transport companies. In line with previous research, coercive pressures, in the form of mandatory reporting requirements contained in regulations, might have constituted the initial predominant reason for SR among Spanish road passenger transport companies (Montecalvo et al., 2018). Meanwhile, in a context of voluntary reporting, normative elements, such as GRI, have played a limited role in institutionalising SR activity among Spanish road passenger transport companies. This differs from previous research, which highlighted the pivotal role exerted by GRI in creating a norm in SR (Larrinaga and Bebbington, 2021).

The next section aims to explain whether regulators (through Law 11/2018 on NFI) and other institutional actors have influenced the SR activity of Spanish road passenger transport sector companies.

The findings from our interviews suggest that the regulator has played a central role in changing the collective SR practices within this sector. Our empirical evidence indicates that all interviewees from the reporting companies within the road passenger transport sector agree that the SR activities have been significantly influenced by Spanish Law 11/2018 regarding NFI. Transport 4 asserted that “our commitment to reporting began when the regulation was passed, and we started to publish an NFI Statement, which is a legal requirement for companies in Spain and Europe”. Transport 6 stated that “our motivation to report about sustainability issues began to comply with a legal requirement as we belong to a group of companies that consolidate their financial statements”. Finally, Transport 1 expressed that “one of our goals is to adhere to regulations that mandate submitting the NFI statement alongside the annual financial statements at the end of each year”.

Five of the six experts interviewed shared the opinion that without regulatory incentives, companies are not naturally motivated to adopt SR practices. Expert 4 expressed that “the lack of mandatory reporting requirements means that most companies, particularly those run by individuals lacking moral conviction, are generally not inclined to report on sustainability issues”. Similarly, Expert 5 expressed, “the transparency of sustainability information of road transport companies will be improved due to regulatory requirements”.

The analysis of our findings shows that, besides regulators, other actors have also promoted the practice of SR within these companies. Interviewees from two road passenger transport companies expressed that, certain key internal individuals, who are attuned to social and environmental issues, played a significant role in the development of SR practices in their organisations. Transport 9 and 10 manifested, “one reason for our commitment to sustainability lies in our internal conviction. Our Quality Department is dedicated to incorporating sustainability into our corporate strategy. Similarly, senior management is focused on aligning sustainability with the company’s operations”. Transport 5 expressed that “our commitment to providing information on sustainability stems from our management team […] Sustainability is a fundamental aspect of our operations and serves as a primary competitive advantage over private vehicle use”. In agreement with previous research, internal champions may view SR as the appropriate course of action, aligned with the social context (Bebbington et al., 2009; Contrafatto, 2014). As Larrinaga and Perez (2008) noted, individuals employed within a company providing a public service (e.g. the road passenger transport sector) should possess a stronger ethical awareness that is congruent with sustainability principles. As expressed by Transport 5, this results in a convergence of the corporate values of these companies with sustainability principles.

Two other interviewees from reporting companies in the road passenger transport sector emphasised the crucial role of professional organisations, such as Foretica and AENOR, in the development of certified socially responsible management systems. Transport 3 declared, “in 2018, we received the IQNet SR10 social responsibility certification from AENOR, and since then, we have been publishing our Sustainability Report”. Similarly, Transport 6 expressed that “we are certified by Foretica in ethical, responsible and sustainable management system (SGE21), so we closely follow the work developed by this professional organisation”. However, other actors (Transport 1 and Transport 4) indicated that experts and professional organisations did not have a direct influence on their company’s reporting behaviour. Therefore, it seems that they did not play a significant role in changing the collective behaviour of companies from this sector regarding SR.

Based on the above considerations, our findings indicate that the shift from voluntary to mandatory reporting has been the primary factor influencing the SR activities of Spanish road passenger transport companies. Since the implementation of the law, the number of companies reporting has increased, and the GRI has become a widely accepted standard for measuring and disclosing information. According to Law 11/2018, companies required to report can use internationally recognised reporting frameworks, such as the GRI Sustainability Reporting Standards, to prepare their NFI statements. Consequently, it seems that companies in this sector have been more affected by coercive pressures than by normative factors in shaping their SR strategies.

The next step of our research is to elucidate whether the NFI regulation has become a socially accepted norm in Spain, with particular emphasis on the Spanish road passenger transport sector. Relying on our theoretical framework, formal laws might not be enough to create a norm in SR (Luque and Larrinaga, 2016; Larrinaga et al., 2018). A supportive normative climate is essential to facilitate the implementation of effective changes in legal rules (Bebbington et al., 2012; Senn and Giordano-Spring, 2020). In agreement with Luque-Vílchez et al. (2024), this suggests examining the structural circumstances shaped by historical and socio-economic contexts to better understand whether the law has become a norm.

Relying on the notion of normativity, the upcoming sections aim to offer a historically informed analysis of the societal context surrounding the development of Law 11/2018 on NFI in Spain; and assess whether the law’s development aligns with existing standards and practices related to SR activities.

Directive 2014/95/EU stipulated that Member States had until 6 December 2016 to implement the laws, regulations and administrative provisions necessary to comply with the provisions of this Directive. According to a press release published in Diario Responsable on 5 December 2017, Spain failed to comply with this deadline, and the European Commission initiated a formal infringement procedure. According to the EU, Spain routinely transposes EU regulations late and incorrectly. Finally, after several requests, the Spanish Government approved Decree-Law 18/2017 on 24 November. As noted in an opinion article published by the CSR Observatory (25 September 2018), the way the Directive was transposed raised several concerns, as did the content of its provisions. The Royal Decree-Law essentially replicated the text of Directive 2014/95, which primarily conveys apathy and disinterest, as shown in the press release published in Diario Responsable. This adaptation missed the opportunity to clarify terms and issues that were ambiguous in the European standard. This Royal Decree left out many of the proposals made by civil society.

A few months later, in May 2018, the Spanish government responsible for approving this Royal Decree was involved in a public scandal related to political corruption, known as the “Gürtel case”. This case revealed a scheme to illegally finance the ruling political party. It was discovered that for many years, parallel accounting had been conducted, involving the use of black money from business donations. A vote of no confidence initiated by the Socialist Party resulted in a change of government in Spain. This transition allowed the Socialist Party to govern with the support of several other political parties, each representing different interests.

On 28 December, Law 11/2018 on NFI was passed in a climate of political instability with little time for companies to comply with the requirements. Eight of the 36 interviewees manifested that the timings and circumstances surrounding the transposition of the Directive to the Spanish regulation resulted in most companies having to adapt quickly to a law that significantly altered the scope of application compared to the European Directive. Particularly, Expert 6 expressed, “since the approval of the law, companies had two months to prepare and verify NFI under the law. Many companies found themselves in a chaos. This reflects a lack of realism in the company’s work, giving a short timeframe […] It also reflects a lack of trust among those working in the companies to consult them […] This behaviour is typical of a regulatory regime in which transparency, accountability, and management are not key elements”. Listed Company 9 expressed that “the first year of application of the law was challenging regarding timelines due to a lack of clarity regarding the interpretation of certain requirements”.

In parallel to this, one key participant also highlighted the lack of involvement by a wide range of actors in the process of preparing the law, especially professionals with recognised knowledge and expertise in the field. Indeed, Expert 6 manifested, “there was no consultation with experts or specialists in the field who could provide their professional opinions on the drafting of the law, especially in terms of indicators, metrics and standards. Those consulted were politically qualified, rather than professionally qualified”. Experts are influential actors as their knowledge and skills are primordial to address compelling and complex sustainability issues (Luque-Vílchez et al., 2024).

Relying on the notion of normativity, the above statements indicate that the contextual factors surrounding the law’s development process suggest that such regulation was not initially established as a widely accepted societal norm.

Our findings indicate that the issuance of the law was not in line with the existing standards and practices, as well as it lacked clarity. Based on the notion of normativity, the lack of conformity of the Spanish SR regulation with these institutional conditions eroded its conversion into a legitimate norm (Bebbington et al., 2012; Luque-Vílchez et al., 2024).

The content of the Spanish Law 11/2018 on NFI does not explicitly state the use of a common and accepted reporting framework by required companies to elaborate their NFI statements. The following extract reveals the above statement: “When providing NFI, obligated companies must adhere to national and European Union frameworks. They may also use the EMAS, which has been adapted to our legal system through Royal Decree 239/2013 of April 5. In addition, companies can reference international frameworks, such as the GRI Sustainability Reporting Standards or other recognised international standards”. This statutory flexibility is reflected in our empirical findings, as 15 of the 36 interviewees manifested the heterogeneity in the use of various reporting frameworks to prepare their NFI statements.

Transport 3 expressed that “we adhered to the requirements of the IQNet SR10 certification, the GRI international standard, and the principles of the United Nations Global Compact and the Sustainable Development Goals (SDGs) to prepare our reports”. Similarly, Transport 1 stated that “the main references and standards we use to prepare our sustainability report include: the principles of the GRI, the UN SDGs, ISO standards related to environmental management (ISO 14001 and EMAS Environmental Declaration) and corporate social responsibility (SR10) and the requirements of Law 11/2018 on Non-Financial Information”. These participants were concerned about the lack of coherence in Spanish Law 11/2018 on NFI with the existing normative framework. Indeed, Listed Company 1 manifested “the absence of clearly defined standards for reporting limits comparability among companies”.

Moreover, 9 of the 36 interviewees revealed that one main shortcoming of the law is the lack of convergence between indicators stipulated by the law with previous accepted reporting frameworks. SOE 2 stated that “the introduction of Law 11/2018 created challenges for us due to the undefined nature of the requested items and the lack of a calculation method”. Expert 6 expressed that “the indicators established in the law did not correspond to previous standards […\ There’s no need to reinvent the wheel […] It would have been a good idea to have taken the GRI guidelines as a point of reference to design the indicators”. This is consistent with the evidence provided by the last report published by the CSR Observatory about sustainability information in IBEX 35 for the year 2022. This report stipulates that, given that the law does not establish the methodology of information that must be included in the NFI statement, companies tend to limit themselves to providing generic descriptions without offering quantitative data on their impacts.

Consistent with Larrinaga and Bebbington (2021), our results suggest that the NFI regulation has failed in specifying the performance indicators that should be included in the NFI statement. The regulation could be enhanced through the incorporation of the validated social and environmental indicators integrated within the most established reporting framework, the GRI (Luque-Vílchez et al., 2024). Regardless of their industry, Spanish companies had traditionally employed the GRI reporting framework to prepare their voluntary sustainability reports before the launch of the NFI regulation (Husillos et al., 2011).

As previously stated, most large Spanish road passenger transport companies lacked prior experience in SR before the launch of the Spanish Law 11/2018 on NFI. This is inextricably linked to the lack of an accountability culture within the companies in this sector, as expressed by the two interviewees from non-reporting road passenger transport companies. In this vein, Transport 12 expressed that “our reporting is influenced by the actions of our competitors. If most companies do not disclose information, we will also refrain from doing so”. Transport 13 noted that “I am not clear on the added economic value that comes from being accountable to society. Traditionally, there hasn’t been a culture in this regard”. This lack of culture towards accountability for sustainability impacts was manifested by four of the six experts who were interviewed. Therefore, unlike Larrinaga and Bebbington (2021) documented, NFI statements are perceived as an innovation among these companies rather than a transformation of a previous similar practice.

Although SR has become a widely accepted practice (Higgins et al., 2018), a thorough analysis of the Law 11/2018 reveals that the term sustainability report was practically absent. “Sustainability” appears only three times in a document that exceeds 20 pages, while the term “sustainable development” is mentioned twice. The only mention (non-explicit) of “sustainability report” is as follows: “Required companies may utilise frameworks, such as the Global Sustainability Reporting Initiative”. This explains why, since the approval of the Spanish NFI regulation, some companies have published an NFI statement jointly with a sustainability report (see Table 4). Five of the 11 interviewees from reporting companies in the road passenger transport sector manifested that the NFI statement and the sustainability report are reporting tools with different audiences and purposes. This was also manifested by three of the 12 interviewees from listed companies and two of the six participants from SOEs. These participants highlighted that their companies use the NFI statement to adhere to mandatory disclosure requirements contained in the Spanish Law 11/2018 on NFI. Meanwhile, they indicated that the sustainability report is a more suitable tool for providing stakeholders with an overview of the company’s social, economic and environmental activities. Transport 7 stated, “from the beginning, we have understood the NFI statement as a report aimed at regulatory compliance… Otherwise, we view the SR as an opportunity to present a modern image of our company that emphasises our commitment to sustainability. This is why we have included content that aligns with the company’s overall strategy”. Similarly, Transport 9 and 10 revealed that “the NFI statement is led by the economic-financial department, and its purpose is to comply with a legal reporting requirement[…] Meanwhile, our motivation to produce a sustainability report is to provide a balanced representation of our economic, environmental, social and governance performance concerning sustainability. It serves as a transparent communication channel for stakeholders”. Finally, Listed Company 9 noted that “the NFI statement aims to align non-financial with financial information as a regulatory requirement. In contrast, sustainability reports disclose the impact of sustainability actions”.

This suggests that the Spanish law on NFI is not in line with existing and accepted practices, such as SR. While the NFI statement is a legal requirement for certain large companies and public interest groups, sustainability reports are typically voluntary, depending on specific regulations and the company’s commitment to transparency and sustainability (Ambical, 2024^[7]). Compared to NFI statements, sustainability reports can have a broader and more detailed focus, addressing policies, strategies, objectives, programs, performance and results related to economic, social and environmental sustainability (Ambical, 2024). These findings suggest that producing a sustainability report is a socially expected practice that reflects the organisation’s dedication to sustainability and highlights management’s efforts to enhance social and environmental impacts (Higgins et al., 2018).

Eight of the 36 interviewees indicated that the design of the Spanish Law 11/2018 on NFI was unclear and ambiguous. It created some difficulties in how companies interpreted the way they have to comply with mandatory sustainability disclosure requirements. Particularly, Expert 6 stated “the content of the law was very vague, with vague definitions of indicators. Likewise, the text was poorly written, with a certain lack of precision in its content”. Transports 9 and 10 expressed that “the NFI statement is a very complex and technical document, intended for a more professional audience rather than for society as a whole”. Listed Company 9 manifested that “some information remains unclear and varies by interpretation, preventing real comparisons”. Meanwhile, Listed Company 4 expressed that “the law allows for interpretation, and it is unclear whether the legislator’s intention has been accurately reflected”. This opinion has also been manifested by other actors in other sources. Particularly, an opinion article published by a CSR expert highlighted that the Spanish Law 11/2018 on NFI presented numerous uncertainties regarding the proper implementation of key issues such as the formulation, verification, presentation and approval of the NFI statement (Lizcano, 2019) ^[8].

Previous researchers found the poor design of SR regulations as a negative aspect to modifying collective reporting behaviour (Senn and Giordano-Spring, 2020; Luque-Vílchez et al., 2024). In our case, this poor design is also evidenced in the flexibility and ambiguity provided by the Spanish NFI regulation regarding the format used to produce these reports. The Spanish regulation does not specify whether the NFI statement should be included in the management report or published as a standalone report. As discussed earlier, this ambiguity has led companies, both in the road passenger transport sector and others, to lack a common approach to their reporting strategies. While some companies have integrated their SR and NFI statements into a single document, others have opted to produce two separate reports with different purposes: the NFI statement to comply with a legal requirement and the SR to address broader societal demands. As a result, various actors ^[9] have developed documents and guides to provide clarity on the effective implementation of Spanish Law 11/2018 on NFI.

The current socio-political context is shaping the discourse around SR activity, especially from a regulatory perspective (Korca, 2021; Giner and Luque, 2022). Consequently, this calls for further research into the dynamics and processes associated with how regulation can drive the creation of a norm in SR.

Our findings indicate that before the Spanish SR regulation, the number of reporters in Spain’s road passenger transport sector was limited, with minimal pressure from key institutional actors, including the GRI. Previous research has clearly manifested that the GRI was a main normative source of institutionalisation of SR (Larrinaga and Bebbington, 2021). Meanwhile, the number of reporting companies within this sector notably increased after the issuance of the Spanish Law 11/2018 on NFI, and this was primarily driven by coercive forces emanating from regulation. Thus, our empirical evidence suggests that the regulator was the key institutional actor in modifying the collective corporate reporting behaviour among Spanish road passenger transport companies.

However, is regulation enough to make SR a norm? A review of the existing literature indicates two distinct perspectives on how regulations affect SR (Bebbington et al., 2012). Some scholars argue that the coercive nature of formal regulations can improve the reliability of the sustainability information provided by limiting companies’ freedom to choose which information they want to disclose (Leong and Hazelton, 2019). In contrast, constructivist scholars have criticised the coercive nature of regulations that govern SR practices (Luque-Vílchez and Larrinaga, 2016; Larrinaga et al., 2018). They documented that formal SR regulations alone do not drive better levels of accountability (Luque and Larrinaga, 2016; Chelli et al., 2018). In line with Luque-Vílchez et al. (2024, p. 35), “although formal SR legislation seems a reasonable approach to improve corporate accountability, there is mounting evidence that the corporate response to formal SR legislation tends to be rather limited in terms of the quantity and quality of the information disclosed”. This body of empirical research documented that the study of normativity production requires the combined examination of how certain conditions, shaped by the history and socio-political context, can cultivate a normative climate for the development of an SR norm (Chauvey et al., 2015; Larrinaga and Senn, 2021).

Our empirical findings appear to be better aligned with the latter school of thought. Based on our theoretical framework, the absence of multiple actors influencing SR suggests that this activity has not yet become a norm among Spanish road passenger transport companies. Moreover, our empirical study has demonstrated that Spanish Law 11/2018 on NFI does not align with various conditions that are essential for establishing a norm in SR. Specifically, this regulation was not developed in accordance with existing and widely accepted practices and standards. The unclear nature of the Spanish NFI regulation, along with the turbulent socio-political context at its introduction, also contributed to its failure to establish a norm in SR in Spain.

Our results are consistent with what has been found by scholars from other European countries. They criticised the limited effects of the transposition of the EU Directive on NFI on transparency, data comparability, assurance practices and business models (Zarzycka and Krasodomska, 2022). In particular, criticisms about the EU Directive revolve around the coexistence of several reporting frameworks, the lack of specific requirements for reporting standards or the absence of mandatory assurance required for NFI statements (La Torre et al., 2018). Consequently, the European Union, in its revision of the SR regulation (CSRD 2022/2464), appears to have acknowledged the pivotal role of professional bodies, as evidenced by its close collaboration with the EFRAG in delineating the disclosure framework. This professional body is promoting active and diverse participation in the development of the ESRS, including standard setters, regulators, sectoral experts and other stakeholders in both its membership structure and the public consultation processes for the standards it develops.

The present socio-political context makes our paper’s results of special interest for practitioners and auditors. The Omnibus proposal, presented by the European Commission and currently under review, introduces significant changes to the scope, reach and content of obligations in the CSRD 2022/2464. This proposal represents a setback compared to previous regulatory efforts aimed at improving transparency and accountability. Also, the Omnibus proposal has raised concerns among companies, investors and other stakeholders regarding their obligations for corporate sustainability management and transparency. It can be argued that these parties find themselves in a “no man’s land”, trying to navigate transparency regulations that European institutions are attempting to amend hastily, with a limited public consultation and before full implementation. Under the guise of “simplification”, a regulatory framework that has undergone years of development and for which companies have already incurred significant adaptation costs is now being challenged. This proposal introduces its complexities and additional costs, while simultaneously casting doubt on the EU’s values and strategic vision. In light of the uncertainty in the European regulatory landscape, companies should prioritise sustainability as a driver of long-term value creation and integrate SR into their strategy and management accounting system.

Like other papers, this study has some limitations. One potential limitation lies in the relatively small number of interviewees. In the future, engaging a large cohort of managers and stakeholders involved in SR would improve the comprehensiveness of the qualitative research. Another limitation could be attributed to the format used for interviews. While email interviews offer some advantages over face-to-face interviews, they also come with drawbacks. For instance, we were unable to observe or interpret visual cues, tones, hesitations or silences. In addition, written responses via email tended to be more time-consuming than those obtained through other interview formats. Finally, the study’s exclusive focus on the Spanish context constitutes another limitation. Future research would benefit from conducting interviews with managers of companies and professional organisations from various European countries to explore whether the geographical context influences the processes and dynamics of institutionalising SR.

The authors would like to thank the reviewers for their comments, which have helped improve the quality of their work. This paper is a part of the research project entitled “Causes and effects of accountability in transport companies: A proposed integrated reporting framework”.

1. Did your company voluntarily prepare and publish sustainability or social responsibility reports before Law 11/2018 came into effect? If so, approximately what year did this begin?

2. Since the implementation of Law 11/2018, have you noticed any improvements in the quality and quantity of non-financial information disclosed?

3. What are the main consequences of Law 11/2018 coming into effect in practical terms? Consider aspects such as format, deadlines and strategies for preparing and presenting your non-financial report.

4. Has the preparation of the non-financial information statement followed the same sustainability or social responsibility reporting strategy that your company used before Law 11/2018?

5. Do you believe that the purpose of the non-financial information statement is the same as that of the sustainability or social responsibility report?

6. What are the main benchmarks and standards your company has used to prepare the non-financial information statement?

7. Based on your experience, what are the main benefits of making the preparation and presentation of non-financial information mandatory?

8. From your perspective, what are the main weaknesses of Law 11/2018 regarding the disclosure of non-financial information?

1. What are the primary factors that motivate your company to regularly prepare and publish a sustainability-related report?

2. What are the main references and standards that your company has used to prepare this report?

3. What role have the different administrations played or are playing in the development of these sustainability reports in your company?

4. What impact is the current social context in the area of sustainability reporting having on the sustainability strategy in your company?

5. What role are professional organisations and/or expert groups playing in your company’s commitment to sustainability reporting?

6. What other actors are playing a key role in developing sustainability reporting at your company?

7. Does your company outsource the preparation of this type of reporting?