Bollas, H. & Sierra-García, L. (2021). Assurance on
non-financial information in Spain. Contaduría
Universidad de Antioquia, 79, 13-37. Doi: https://
doi.org/10.17533/udea.rc.n79a01
Assurance on non-financial
information in Spain
Helena María Bollas Araya
Universitat Politècnica de València
hebolar@cegea.upv.es
Orcid: 0000 0001 8266 3622
Laura Sierra-García
Universidad Pablo de Olavide
Lnsiegar@upo.es
Orcid: 0000-0001-8880-0683

Assurance on non-financial information in Spain
Abstract: By means of the Directive 2014/95/EU, the EU established new requirements regarding the
disclosure of non-financial information (NFI). The Spanish Act 11/2018 expands these requirements,
imposing mandatory external assurance on NFI. This is a pioneering study in Spain, since it was conducted
during the first year in which external assurance is mandatory. The aim of this paper is to analyse whether
Spanish listed companies fulfil this requirement and to compare assurance practices before the entry into
force of the Act and afterwards. Our findings indicate that some companies still fail to adopt external
assurance in spite of being mandatory. We found no significant association between the choice of type of
assuror and the entry into force of the Act, but this choice depends on some corporate characteristics. On
the other hand, we found that the Act implementation and the type of assuror are associated with some
assurance features.
Keywords: Non-financial information, Directive 2014/95/EU, Act 11/2018, mandatory assurance,
assurors.
Aseguramiento de la información no financiera en España
Resumen: Mediante la Directiva 2014/95/UE, la UE estableció nuevos requisitos sobre la divulgación
de información no financiera (INF). La Ley española 11/2018 amplía estos requisitos, imponiendo la
obligatoriedad de la verificación externa de la IFN. Este es un estudio pionero en España, ya que se ha
realizado durante el primer año en el que la verificación externa es obligatoria. El objetivo de este trabajo
es analizar si las empresas cotizadas españolas cumplen con este requisito y comparar las prácticas de
aseguramiento antes y después de la entrada en vigor de la Ley. Nuestros resultados indican que algunas
empresas siguen sin adoptar la verificación externa a pesar de ser obligatoria. No encontramos una
asociación significativa entre la elección del tipo de asegurador y la entrada en vigor de la Ley, pero esta
elección depende de algunas características de la empresa. Por otro lado, encontramos que la aplicación
de la Ley y el tipo de asegurador están asociados con algunas características del aseguramiento.
Palabras clave: Información no financiera, Directiva 2014/95/UE, Ley 11/2018, aseguramiento
obligatorio, aseguradores.
Asseguramento da informação não financeira na Espanha
Resumo: Mediante a Diretiva 2014/95/UE, a UE estabeleceu novos quesitos sobre a divulgação
de informação não financeira (INF). A lei espanhola 11/2018 amplia estas exigências, impondo a
obrigatoriedade da verificação externa da INF. Este é um estudo pioneiro na Espanha, dado que tem se
realizado durante o primeiro ano no que a verificação externa é obrigatória. O objetivo deste trabalho
é analisar se as empresas espanholas listadas cumprem com este requisito e comparar as práticas de
asseguramento antes da entrada em vigor da lei e depois. Nossos resultados mostram que algumas
empresas seguem sem adotar a verificação externa embora seja obrigatória. Não se encontra uma
associação significativa entre a eleição do tipo de assegurador e a entrada em vigor da lei, mas esta
eleição depende de algumas características da empresa. Por outro lado, encontramos que a aplicação da
lei e o tipo de assegurador estão associados com algumas características da garantia.
Palavras chave: Informação não financeira, Diretiva 2014/95/UE, Lei 11/2018, asseguramento
obrigatório, asseguradores.
L’Assurance de l’information non financière en Espagne
Résumé: Par la Directive 2014/95/UE, l’Union Européenne a établi de nouvelles exigences en matière
de publication d’informations non financières (INF). La loi espagnole 11/2018 étend ces exigences en
imposant une vérification externe obligatoire des INF. Il s’agit d’une étude pionnière en Espagne, car
elle a été menée au cours de la première année où la vérification externe est obligatoire. L’objectif de ce
document est d’analyser si les entreprises espagnoles cotées en bourse respectent cette exigence, et de
comparer les pratiques d’assurance avant et après l’entrée en vigueur de la loi. Nos résultats indiquent que
certaines entreprises n’adoptent toujours pas l’assurance externe malgré le fait qu’elle soit obligatoire.
Nous ne trouvons pas d’association significative entre le choix du type d’assureur et l’entrée en vigueur
de la loi, mais ce choix dépend de certaines caractéristiques de l’entreprise. D’autre part, nous constatons
que l’application de la loi et le type d’assureur sont associés à certaines caractéristiques de la garantie.
Mots clés: Information non financière, Directive 2014/95/UE, loi 11/2018, assurance obligatoire, assureur.

Cont. udea (julio-septiembre, pp. 13-37. © Universidad de Antioquia-2021.
Assurance on non-financial information in Spain
Helena María Bollas Araya y Laura Sierra-García
https://doi.org/10.17533/udea.rc.n79a01
Primera versión recibida en abril de 2021 – Versión aceptada en julio de 2021
I. Introduction
The 2014/95/EU Directive, which creates new obligations regarding the
disclosure of non-financial information (NFI) and information on diversity (EU,
2014), is perhaps the most important step the European Union has taken to en-
hance corporate reporting. Under the Directive, Public Interest Entities (PIEs),
that is, public and private limited companies with more than 500 employees,
must periodically publish a ‘non-financial statement’ addressing the following
areas: environmental and social issues, employment, respect for human rights
and measures to combat corruption and bribery. In each of these areas, PIEs
should describe the policy pursued, their outcomes (including due diligence
processes implemented), the most important sustainability-related risks iden-
tified, and key performance indicators. PIEs should provide this information
within the management report or within a separate report (for example, on CSR
or sustainability), in accordance with international guidelines or standards, such
as the UN Guiding Principles on Business and Human Rights, ISO 26000, the
OECD Guidelines for Multinational Enterprises, the Global Reporting Initiative
or the EU Eco-Management and Audit Scheme.
Under EU rules, the Directive must be transposed into the national legis-
lation of the Member States. Spain did so by Royal Decree-Law 18/2017 of 24
November 2017, which closely mirrored the provisions of the EU Directive and
contained no additional requirements (Hernández, 2017). In addition, on 29
December 2018, the Spanish Parliament passed Act 11/2018 (published in the
Spanish Official Gazette), which required the provision of new information on
non-financial issues and diversity. This Act modified the Code of Commerce,
Corporation Law and Audit Law, and introduced important changes in how
Spanish companies act. Specifically, it extended the scope of regulatory requi-
rements to all companies with more than 250 employees, imposing mandatory

16Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
external assurance by an independent provider, expanding the content to be
reported to include tax payments and issues of diversity related to the wage
gap, and requiring companies to disclose NFI online within six months of year-
end and to maintain its availability for five years. This Act came into force on 30
December 2018 and therefore affected the data for the fiscal year starting on 1
January 2018, which are reported from the beginning of 2019.
In this paper, we focus on the external assurance requirement. According
to KPMG (2020), “assurance of sustainability information has become standard
practice for large and mid-cap companies worldwide”. The provision of external
assurance on the content and structure of sustainability reports enhances their
importance, reliability and comparability, and therefore their global credibi-
lity (Simnett, 2012). This service is provided by independent experts, termed
assurors, who are usually classified as accountants and/or non-accountants.
Assurors conduct their activities according to standards such as the AA1000
Assurance Standard (AA1000AS) issued by AccountAbility, and the International
Standard of Assurance Engagements Other Than Audits or Reviews of Historical
Financial Information (ISAE 3000), published by the IAASB.
The AA1000AS stipulates the requirements for conducting sustainability as-
surance, that is, to evaluate and provide conclusions on the nature and extent
of adherence to the AA1000 AccountAbility Principles of inclusivity (participa-
tion of stakeholders), materiality (relevance and significance of an issue) and
responsiveness (response to stakeholders), and where applicable the quality of
publicly disclosed information on sustainability performance. This standard es-
tablishes two levels of assurance: moderate and high (AccountAbility, 2008a, b).
ISAE 3000, on the other hand, sets out principles and procedures for ac-
counting firms to review non-financial information. This standard establishes
two levels of assurance, limited and reasonable, and two types of conclusions,
unmodified and modified (IAASB, 2013).
The outcome of an assurance process is an assurance statement, the form
and content of which differ according to the assuror responsible and the as-
surance standards applicable (GRI, 2013). According to the AA1000AS and the
ISAE 3000, an assurance statement shall include as a minimum the informa-
tion in Table 1.

17Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
Table 1. Content of an assurance statement
AA1000AS ISAE 3000
− Intended users of the assurance statement.
− The responsibility of the reporting organization
and of the assurance provider.
− Assurance standard/s used, including reference
to the AA1000AS.
− Description of the scope.
− Description of disclosures covered.
− Description of methodology.
− Any limitations.
− Reference to criteria used.
− Statement of level of assurance (moderate or
high).
− Findings and conclusions concerning adherence
to the AA1000 AccountAbility Principles of
Inclusivity, Materiality and Responsiveness (in all
instances).
− Findings and conclusions concerning the
reliability of specified performance information
(for Type 2 assurance only).
− Observations and/or recommendations.
− Notes on competencies and independence of
the assurance provider.
− Name of the assurance provider.
− Date and place.
− A title clearly indicating that it is an independent
assurance report.
− An addressee.
− An identification or description of the level of
assurance, the subject matter information and,
when appropriate, the underlying subject matter.
− Identification of the applicable criteria.
− Where appropriate, a description of any
significant inherent limitations.
− When the applicable criteria are designed for a
specific purpose, a statement alerting readers.
− A statement to identify the responsible party
and the measurer or evaluator if different,
and to describe their responsibilities and the
practitioner’s responsibilities.
− A statement that the engagement was performed
in accordance with this ISAE.
− A statement that the firm of which the
practitioner is a member applies ISQC 1, or other
professional requirements.
− A statement that the practitioner complies with
the independence and other ethical requirements
of the IESBA Code, or other professional
requirements.
− An informative summary of the work performed
as the basis for the practitioner’s conclusion.
− The practitioner’s conclusion.
− The practitioner’s signature.
− The date of the assurance report.
− The location in the jurisdiction where the
practitioner practices.
Source: AccountAbility (2008); IAASB (2013)
This paper examines the issue of mandatory external assurance in the Spa-
nish context. Spain was one of the first countries to establish this obligation
and, according to KPMG (2020), is where the independent external assurance of
sustainability reporting has increased most strongly. In view of this circumstan-
ce, we believe it useful to consider how Spanish listed companies are meeting
this requirement.
Our analysis produced the following main findings: firstly, although assuran-
ce has been mandatory since the entry into force of Act 11/2018, some com-
panies are still failing to assure their non-financial reports. In addition, certain
corporate characteristics influence companies to choose a particular type of

18Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
assuror. Finally, there are significant differences among the assurance standards
issued, conclusions drawn and recommendations made.
The rest of this paper is structured as follows. In Section Two, we present
the theoretical background considered and review the literature in this field.
We then describe the study sample and the analytical method applied. The em-
pirical results are presented in Section 4, and finally we summarise the main
conclusions drawn.
II. Theoretical background and literature review
Various studies have considered the effects of Directive 2014/95/EU on NFI
disclosure among PIEs, in different countries (Venturelli et al., 2017; Manes Ros-
si et al., 2018; Matuszak and Rozanska, 2017; Sierra Garcia et al., 2018; Mion and
Loza, 2019; Tiron-Tudor et al., 2019; Aureli et al., 2020). However, only Ventu-
relli and Pizzi (2020) specifically examined the question of external assurance.
By analysing the assurance statements published by a set of European PIEs,
these authors found that levels of assurance differed significantly among EU
countries, due to the absence of mandatory adoption of specific standards and
because of divergences in the transposition of the Directive into national laws.
The assurance process plays an important role in establishing an
organisation’s legitimacy (O’Dwyer et al., 2011), helping satisfy social demands
and thus ensuring the survival of the organisation (Martínez-Ferrero and
García-Sánchez, 2018). In Spain, Act 11/2018 made external assurance by an
independent provider mandatory. Previous studies of voluntary assurance have
concluded that the quality obtained is significantly higher when the assurors
are accountants (Romero et al., 2010; Fernández-Feijóo et al., 2012; Zorio et
al., 2013), because of their independence and professional expertise (Velte and
Stawinoga, 2017). In view of these considerations, we formulated this research
question:
RQ1: Did the entry into force of Act 11/2018 influence the type of assuror
preferred?
According to Zorio et al. (2013), the business sector in which the organi-
sation operates is a determining factor in the type of assuror chosen. In this
respect, Fernández-Feijóo et al. (2015) pointed out that large accounting firms
were usually preferred by companies operating in more visible sectors. Simi-
larly, Sierra et al. (2013) observed that companies in sectors such as oil and
energy, basic materials or financial services were more likely to choose an ac-
counting firm for this task, while Simnet et al. (2009), Kolk and Perego (2010)
and Fernández-Feijóo et al. (2015) all concluded that large companies were
more likely to choose accountants than non-accountants as their preferred as-
surer. Zorio et al. (2013) reported, moreover, that the company’s listing status
was a significant factor in its choice of assurance provider. In addition, most

19Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
advocates of the upper echelons theory assume, implicitly or explicitly, that
CEOs, in almost all organisations, are the most influential parties in this deci-
sion-making process (Finkelstein et al., 2009; Lewis et al., 2014). Many recent
arguments concerning the crucial role of CEO characteristics in organisations’
decision making refer to an earlier notion in strategy research proposed by
Chandler (1990), who argued that CEOs play the most critical role in articulating
and implementing a firm’s strategies. Reflecting these concerns, our second re-
search question inquires:
RQ2: Is the choice of the type of assuror associated with particular corporate
characteristics?
Institutional theory explains that organisations may adopt similar practices
or structures in order to conform to external expectations and to gain legi-
timacy and support (Deegan, 2002; DiMaggio and Powell, 1983), doing so via
mimetic, coercive and normative isomorphism. Mimetic isomorphism is the
process by which organisations emulate the structures and procedures adopted
by others. Coercive isomorphism takes place when external factors (e.g., gover-
nment policy, regulation or commercial pressures) persuade or oblige organi-
sations to adopt specific internal structures and procedures. Finally, normative
isomorphism is the process by which organisations adopt the structures and
procedures recommended or required by dominant professions, professional
bodies and/or consultants (DiMaggio and Powell, 1983). According to Adams and
Narayanan (2007), normative isomorphism is consistent with the ‘standardisa-
tion’ of assurance through the adoption of standards (Smith et al. 2011), such
as ISAE 3000 and AA1000AS. Research has shown that most assurors use ISAE
3000 (Manetti and Becatti, 2009; Fonseca, 2010; Ferreira et al., 2015; Seguí et
al., 2018). However, other assurors apply a combination of standards (Manetti
and Toccafondi, 2012; Perego and Kolk, 2012). Meanwhile, O’Dwyer and Owen
(2005) and Deegan et al. (2006a) noted that in many cases no mention is made
of standards. O’Dwyer and Owen (2005) commented that non-accountant
assurors are more likely than accountants to mention standards, especially
AA1000AS. In contrast, Deegan et al. (2006a, b), Mock et al. (2007, 2013) and
Bollas-Araya et al. (2018) affirm that accountants are more likely to mention
standards. In this respect, too, Perego and Kolk (2012), Manetti and Toccafondi
(2012), Bollas-Araya et al. (2018) and Seguí et al. (2018) state that accountants
are more likely to employ ISAE 3000, whereas non-accountants tend to prefer
AA1000AS. Finally, Manetti and Toccafondi (2012) and Seguí et al. (2018) obser-
ve that accountants are also more likely to combine different standards in their
assurance procedures. Taking these considerations into account, we formulated
the following research questions:
RQ3.1: Is the application of Act 11/2018 associated with the use of assurance
standards?

20Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
RQ3.2: Is the type of assuror associated with the use of assurance standards?
According to legitimacy theory, the scope and intensity of the assurance
processes performed by an independent third party essentially determine the
reliability of institutional reports. Therefore, organisations should seek a rea-
sonable/high level of assurance in order to maximise the credibility and value
of their reports (Velte and Stawinoga, 2017). Nevertheless, studies have shown
that most assurors only certify a limited/moderate level of assurance (Hasan et
al., 2005; Manetti and Becatti, 2009; Manetti and Toccafondi, 2012; Seguí et al.,
2018). In this respect, O’Dwyer and Owen (2005) and Bollas-Araya et al. (2018)
found that accountants are more likely to indicate the level of assurance and
to apply a more conservative, cautious and limited approach, thus offering low
levels of assurance, whereas non-accountants apply a more evaluative approach
and offer higher levels. The view that large accounting firms are more likely to
provide lower levels of assurance was corroborated by Mock et al. (2007, 2013)
and Martínez-Ferrero and García-Sánchez (2018). In this respect, we address the
following research questions:
RQ4.1: Is the application of Act 11/2018 associated with the level of assurance
applied?
RQ4.2: Is the type of assuror employed associated with the level of assurance
supplied?
In their study, Perego and Kolk (2012) concluded that the quality of the re-
commendations and opinions provided is positively associated with the involve-
ment of non-accountants as assurors. On the other hand, Martínez-Ferrero and
García-Sánchez (2018) showed that the greater experience of the Big 4 firms
and their specialist skills and training increased the probability of the opinions
offered being more precise. However, Mock et al. (2007, 2013) found that large
accounting firms were less likely to include recommendations in their assurance
statements. While Manetti and Toccafondi (2012) evidenced that consultants
more commonly indicated possible areas of improvement, Bollas-Araya et al.
(2018) found no association between the inclusion of recommendations and the
type of assuror involved. In view of these conflicting findings, we formulated
the following research questions:
RQ5.1: Is the application of Act 11/2018 associated with the type of conclusions
drawn?
RQ5.2: Is the type of assuror provider associated with the type of conclusions
drawn?
RQ6.1: Is the application of Act 11/2018 associated with the recommendations
made?
RQ6.2: Is the type of assuror associated with the recommendations made?

21Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
III. Methods
III.1 Sample description
This paper analyses Spanish companies’ compliance with the requirements
of Act 11/2018, derived from Directive 2014/95/EU, with respect to mandatory
assurance on non-financial reporting. In particular, we focus on the companies
listed on the IBEX 35 index of the Madrid Stock Exchange in June 2018 and June
2019. As shown in Table 2, the initial observation identified 130 companies, but
those which were foreign based were excluded from the analysis. Thus, Samples
1 and 2 were composed of 124 and 127 companies, respectively. We then deter-
mined which companies issued non-financial reports, locating 104 companies
in the first period and 101 in the second. Finally, we considered which non-
financial reports were assured by an independent provider, and found 40 and 85
reports in the first and second periods, respectively.
Table 2. Sample Description
Sample 1
(June 2018)
Sample 2
(June 2019)
Madrid Stock Exchange (IBEX 35) 130 130
Less foreign companies 124 127
Companies with non-financial report 104 101
Non-financial reports with assurance 40 85
Table 3 shows that, of the companies that assured their non-financial re-
ports, most operated in the basic materials, industry and construction sector
(31.2%), while the smallest group corresponded to the petroleum and energy
sector (9.6%). Although in both study periods assurance was more frequently
employed among companies in the basic materials, industry and construction
sector, the proportion of reports assured decreased from 35% to 29.4% between
the first and second periods. Before Act 11/2018 came into force, assurance was
least frequently employed among companies in the consumer goods sector (5%),
but by the second study period this proportion had risen to 18.8%. After the
legislation came into force, assurance was least common among companies in
the petroleum and energy sector (7.1%).
Table 3. Assurance by sector
Pre-Act Post-Act Total
Sector n % n % n %
Consumer goods 2 5.0 16 18.8 18 14.4
Basic materials, industry and construction 14 35.0 25 29.4 39 31.2

22Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
Pre-Act Post-Act Total
Petroleum and energy 6 15.0 6 7.1 12 9.6
Consumer services 4 10.0 15 17.6 19 15.2
Financial services and real estate 9 22.5 14 16.5 23 18.4
Technology and telecommunications 5 12.5 9 10.6 14 11.2
Total 40 100.0 85 100.0 125 100.0
III.2 Analytical methods and study variables
The research questions were addressed using descriptive statistics and mul-
tilogistic regression. Specifically, cross-tabulation analysis and chi-square tests
were applied to determine whether the entry into force of Act 11/2018 influen-
ced the selection of the type of assuror. In addition, the following model was
formulated to describe the corporate factors that influenced the choice of type
of assuror:
Type of Assuror = α + β1 Sustainability Committee + β2 CEO Tenure + β3
CEO Gender + β4 Sensitive sector + β5 Period + β6 Index + β7 Size + β8 Leve-
rage + β9 ROA + β8 Loss + ε
Cross-tabulation analysis and chi-square tests were also used to verify
whether the entry into force of Act 11/2018 and the type of assuror employed
impacted on certain characteristics of the assurance report, such as standards,
levels, conclusions and recommendations.
In line with the study model and research questions established, the fo-
llowing variables were included in the analysis (see Table 4).
Table 4. Study variables
Variable Definition
ASSURANCE A dichotomous variable that takes the value ‘1’ if the company assured its non-
financial report and ‘0’ otherwise.
TYPE OF ASSUROR A categorical variable that takes the value ‘0’ if the assuror was Ernst & Young,
‘1’ if it was Deloitte, ‘2’ if it was KPMG, ‘3’ if it was PwC and ‘4’ if it was a non-
Big 4 firm.
PERIOD A categorical variable that takes the value ‘1’ after the entry into force of Act
11/2018 and ‘0’ before this date.
SUSTAINABILITY
COMMITTEE
A dichotomous variable that takes the value ‘1’ if the company had a sustainability
committee or similar and ‘0’ otherwise.
CEO TENURE Experience (years) of the CEO in this position.
CEO GENDER A categorical variable that takes the value ‘1’ if the CEO was female and ‘0’ if
the CEO was male.
SENSITIVE SECTOR A dichotomous variable that takes the value ‘1’ for sensitive sectors and ‘0’
otherwise.

23Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
Variable Definition
INDEX A dichotomous variable that takes the value ‘1’ if the company was listed on the
IBEX-35 index and ‘0’ otherwise.
SIZE Natural log of total assets.
LEVERAGE Total debt divided by equity.
ROA Profit divided by total assets.
LOSSES A dichotomous variable that takes the value ‘1’ if the company made financial
losses during the previous year and ‘0’ otherwise.
STANDARDS A dichotomous variable that takes the value ‘1’ if the assurors mentioned the
standards used in the assurance process and ‘0’ otherwise.
ISAE 3000 + AA100AS A dichotomous variable that takes the value ‘1’ if the assurors used both the
ISAE 3000 and the AA1000AS standards and ‘0’ otherwise.
ISAE3000 A dichotomous variable that takes the value ‘1’ if the assurors used the ISAE
3000 standard and ‘0’ otherwise.
AA1000AS A dichotomous variable that takes the value ‘1’ if the assurors used the
AA1000AS standard and ‘0’ otherwise.
LEVEL_1 A dichotomous variable that takes the value ‘1’ if the assuror mentioned the
level of assurance provided and ‘0’ otherwise.
LEVEL_2 A categorical variable that takes the value ‘0’ if the level of assurance provided
was limited/moderate and ‘1’ when it was reasonable/high, or a combination of
the two levels.
CONCLUSION A categorical variable that takes the value ‘0’ if the conclusions were unmodified
and ‘1’ otherwise.
RECOMMENDATIONS A dichotomous variable that takes the value ‘1’ if the assuror made
recommendations and ‘0’ otherwise.
Note: Sensitive sectors include petroleum and energy, financial services and real estate, and technology
and telecommunications. According to prior research (Simnett et al., 2009; Kolk and Perego, 2010), these
sectors are likely to have specific information policies about their behaviour with respect to corporate
social responsibility.
IV. Results
Table 5 shows the descriptive statistics obtained for the dummy variables.
The following main features can be observed. Before Act 11/2018 came into
force, 32% of reports were assured, a value that had risen to 68% one year later.
Some companies are still failing to assure their non-financial report despite this
now being mandatory. Most companies employ accountants to assure their non-
financial reports (90.4%), and this sector is mainly composed of the Big 4 firms
(88%). In 2019, only 24.8% of companies had a sustainability committee. The
CEO was male in 97.6% of the companies considered. By business sector, 39.2%
of the companies operated in a ‘sensitive’ area. 49.6% of the companies were
IBEX-35 listed. Only 12.8% of the companies made a financial loss during the
previous twelve months. 96% of assurors identified the standards used, which
in most cases was the combination of ISAE 3000 and AA1000AS (83.3%); 96% of
assurors mentioned the level of assurance provided, which in most cases was

24Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
limited/moderate (94.2%); 90.4% of the conclusions drawn were unmodified, and
only 20.8% of the assurors made recommendations.
Table 5. Descriptive statistics: dummy variables
Variables n % Cum.
PERIOD
Pre-Act 40 32.0 32.0
Post-Act 85 68.0 100.0
TYPE OF ASSUROR
Non-accountants 12 9.6 100.0
Accountants
EY 22 17.6 17.6
Deloitte 25 20.0 37.6
KPMG 29 23.2 60.8
PwC 34 27.2 88.0
Others 3 2.4 90.4
SUSTAINABILITY COMMITTEE
No 94 75.2 75.2
Yes 31 24.8 100.0
CEO GENDER
Male 122 97.6 97.6
Female 3 2.4 100.0
SENSITIVE SECTOR
No 76 60.8 60.8
Yes 49 39.2 100.0
INDEX
Not included 63 50.4 50.4
Included 62 49.6 100.0
LOSSES
No 109 87.2 87.2
Yes 16 12.8 100.0
STANDARDS
Not mentioned 5 4.0 4.0
Mentioned
Only ISAE 3000 18 15.0 15.0
ISAE 3000 + AA1000AS 100 83.3 98.3
Other 2 1.7 100.0
LEVEL
Not mentioned 5 4.0 4.0
Mentioned
Limited/moderate 113 94.2 94.2
Reasonable/high or combination 7 5.8 100.0

25Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
Variables n % Cum.
CONCLUSIONS
Unmodified 113 90.4 90.4
Modified 12 9.6 100.0
RECOMMENDATIONS
No 99 79.2 79.2
Yes 26 20.8 100.0
TOTAL 125 100.0
Table 6 shows the descriptive statistics for the continuous variables. The
average company size (natural logarithm of total assets) was 15.66. The mean
leverage was .717 and individual values ranged from .21 to 2.10. Finally, the
average ROA was 4.5%, ranging from a minimum value of -41% to a maximum
of 85%.
Table 6. Descriptive statistics: continuous variables
Variables Obs. Mean Std. Dev. Min Max
CEO TENURE 125 7.704 7.136937 0 32
SIZE 125 15.65793 2.147742 10.93007 21.1012
LEVERAGE 125 .7167435 .2507664 .213071 2.10999
ROA 125 .045744 .1105386 -.4102509 .8499616
The results shown in Table 7 show that the proportion of accountants vs.
non-accountants providing external assurance fell after Act 11/2018 came into
force (from 92.5% to 89.4%). Nevertheless, this change was not statistically signi-
ficant, and at both time points a large majority of companies hired accountants
to perform this task.
Table 7. Chi-square test: type of assuror per period
Type of assuror
Non-accountant Accountant Total
Period n % n % n %
Before Act 11/2018 3 7.5 37 92.5 40 100.0
After Act 11/2018 9 10.6 76 89.4 85 100.0
Total 12 9.6 113 90.4 125 100.0
Pearson chi-square = 0.299 (p = 0.585)
Fisher’s exact test = 0.425 (p = 0.750)

26Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
As detailed in Table 8, certain corporate factors influence the choice of type
of assuror, as regards Big 4 vs. non-Big 4 firms. Specifically, companies listed
in the IBEX-35 were more likely to choose one of the Big 4 firms to provide
assurance on their non-financial reports (p < 0.05). Companies that made a fi-
nancial loss during the previous year tended to prefer EY (p < 0.01), companies
operating in a non-sensitive business sector were more likely to select KPMG
(p < 0.05), and those with a sustainability committee (p < 0.05) and/or whose
CEO had lengthy experience in this role (p < 0.05) were more inclined to opt
for PwC. The results obtained show that the model obtains a good fit, with
Prob > chi 2 significant (p < 0.01) and pseudo R 2 = 0.1727.
Table 8. Multi-logistic regression: choice of type of assuror
ASSUROR Coef. Std. Err. P>z
EY
SUSTAINABILITY COMMITTEE 1.935672 (1.23202) 0.116
CEO TENURE -.0137768 (.0599415) 0.818
CEO GENDER -.5496239 (2268.535) 1.000
SENSITIVE SECTOR -.2504062 (.3007044) 0.405
PERIOD -2.483784 (1.821648) 0.173
INDEX 17.02609 6.940296 0.014*
SIZE -2.405108 1.546988 0.120
LEVERAGE -.8427132 .9127529 0.356
ROA .0171374 .9408851 0.985
LOSSES 4.286936 1.437955 0.003**
Deloitte
SUSTAINABILITY COMMITTEE 1.086673 1.234794 0.379
CEO TENURE -.0052732 .0536349 0.922
CEO GENDER 13.70019 1346.7 0.992
SENSITIVE SECTOR .1493881 .8294164 0.857
PERIOD .2562847 .9101325 0.778
INDEX 2.755072 1.367569 0.044*
SIZE -.0269819 .2730729 0.921
LEVERAGE -1.456153 1.599515 0.363
ROA .2468696 4.401268 0.955
LOSSES .2453861 1.174972 0.835

27Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
ASSUROR Coef. Std. Err. P>z
KPMG
SUSTAINABILITY COMMITTEE .8830903 1.197703 0.461
CEO TENURE .0163623 .0487227 0.737
CEO GENDER .4805009 2089.544 1.000
SENSITIVE SECTOR -1.918706 .9213121 0.037*
PERIOD .4005886 .90138 0.657
INDEX 3.046756 1.350631 0.024*
SIZE .1533872 .2763351 0.579
LEVERAGE .7691088 1.403096 0.584
ROA .6782995 2.812949 0.809
LOSSES -.8117533 1.206361 0.501
PwC
SUSTAINABILITY COMMITTEE 1.992954 1.170823 0.089*
CEO TENURE .0992249 .0488421 0.042*
CEO GENDER 14.83224 1346.701 0.991
SENSITIVE SECTOR -.1094981 .8772217 0.901
PERIOD .2520593 .8970768 0.779
INDEX 2.863524 1.363148 0.036*
SIZE .09232 .2814459 0.743
LEVERAGE .4188503 1.735027 0.809
ROA -2.651104 5.372065 0.622
LOSSES -1.200503 1.41946 0.398
Number of obs. = 125
LR chi 2 (40) = 67.99
Prob > chi 2 = 0.0038
Pseudo R2 = 0.1727
Log likelihood =-162.89927
Note: Non-Big 4 firms are taken as the base
As concerns compliance or otherwise with the ISAE 3000 and AA1000AS
assurance standards, Table 9 shows that no association was found between the
entry into force of Act 11/2018 and reference to one or other of these standards
in the assurance report (p > 0.10). In both study periods, most assurors identify
the standards complied with in performing the assurance task. On the other
hand, there was a statistically significant association between the joint use of
the two standards and the entry into force of the Act (p < 0.01). The likelihood
of ISAE 3000 and AA1000AS being jointly used was greater after the Act be-
came law (89.2%) than before (70.3%). We also tested the application of each

28Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
standard separately, and found that the use of ISAE 3000 was not significantly
associated with the implementation of the Act (p > 0.10). Thus, in both study
periods, most assurors followed this standard. In contrast, the use of AA1000AS
was significantly associated with the Act’s entry into force (p < 0.05). Thus, the
likelihood of the assuror following this standard was higher before than after
this event (35.1% vs. 15.7%, respectively).
Table 9. Chi-square test: Use of assurance standards before and after Act 11/2018
Assurance standards
Standards Not mentioned Mentioned Total
Period n % n % n %
Before Act 11/2018 3 7.5 37 92.5 40 100.0
After Act 11/2018 2 2.4 83 97.6 85 100.0
Total 5 4.0 120 96.0 125 100.0
Pearson chi-square = 1.877 (p = 0.171)
Fisher’s exact test (p = 0.326; 0.186)
ISAE 3000 + AA1000AS No Yes Total
Period n % n % n %
Before Act 11/2018 11 29.7 26 70.3 37 100.0
After Act 11/2018 9 10.8 74 89.2 83 100.0
Total 20 16.7 100 83.3 120 100.0
Pearson chi-square = 6.572 (p = 0.010)
ISAE 3000 No Yes Total
Period n % n % n %
Before Act 11/2018 0 0.0 37 100.0 37 100.0
After Act 11/2018 2 2.4 81 97.6 83 100.0
Total 2 1.7 118 98.3 120 100.0
Pearson chi-square = 0.907 (p = 0.341)
Fisher’s exact test (p = 1.000; 0.477)
AA1000AS No Yes Total
Period n % n % n %
Before Act 11/2018 24 64.9 13 35.1 37 100.0
After Act 11/2018 70 84.3 13 15.7 83 100.0
Total 94 78.3 26 21.7 120 100.0
Pearson chi-square = 5.717 (p = 0.017)
Analysis of the application of standards by type of assuror (Table 10) shows
that only accountants mentioned the standards before the Act’s implementation.
Specifically, 70.3% combined the two standards (ISAE 3000 and AA1000AS), all

29Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
of them complied with ISAE 3000 and 35.1% also followed AA1000AS. After the
Act came into force, all assurance reports prepared by accountants referred to
the standards, whereas non-accountants alluded to them in only 77.8% of cases.
The vast majority of accountants (96.1%) combined the two standards, while only
14.3% of non-accountants did so. All of the accountant firms used ISAE 3000, as
did 71.4% of the non-accountants. With respect to AA1000AS, 11.8% of accoun-
tants adhered to this standard, while none of the non-accountants did so. In both
study periods (before and after the implementation of Act 11/2018) there is a sig-
nificant association between the type of assuror and reference to the standard(s)
used (p < 0.01). After implementation of the Act, the use of the two standards in
combination, or that of ISAE 3000 alone, was also significantly associated with
the type of assuror (p < 0.01). Accountants were more likely to mention stan-
dards, to combine standards and to use ISAE 3000.
Table 10. Chi-square test: Assurance standards by type of assuror
Assurance standards
Before the Act After the Act
Standards Not
mentioned Mentioned Total Not
mentioned Mentioned Total
Assuror n % n % n % n % n % n %
Non-accountant 3 100.0 0 0.00 3 100.0 2 22.2 7 77.8 9 100.0
Accountant 0 0.0 37 100.0 37 100.0 0 0.0 76 100.0 76 100.0
Total 3 7.5 37 92.5 40 100.0 2 2.4 83 97.6 85 100.0
Pearson chi-square = 40.000 (p = 0.000)
Fisher’s exact test (p = 0.000; 0.000)
Pearson chi-square = 17.226 (p = 0.000)
Fisher’s exact test (p = 0.010; 0.010)
ISAE 3000 +
AA1000AS No Yes Total No Yes Total
Assuror n % n % n % n % n % n %
Non-accountant 0 0.0 0 0.0 0 0.0 6 85.7 1 14.3 7 100.0
Accountant 11 29.7 26 70.3 37 100.0 3 3.9 73 96.1 76 100.0
Total 11 29.7 26 70.3 37 100.0 9 10.8 74 89.2 83 100.0
No statistics are computed because
ASSUROR is a constant.
Pearson chi-square = 44.327 (p = 0.000)
Fisher’s exact test (p = 0.000; 0.000)
ISAE 3000 No Yes Total No Yes Total
Assuror n % n % n % n % n % n %
Non-accountant 0 0.0 0 0.0 0 0.0 2 28.6 5 71.4 7 100.0
Accountant 0 0.0 37 100.0 37 100.0 0 0.0 76 100.0 76 100.0
Total 0 0.0 37 100.0 37 100.0 2 2.4 81 97.6 83 100.0

30Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
Assurance standards
Before the Act After the Act
Standards Not
mentioned Mentioned Total Not
mentioned Mentioned Total
No statistics are computed because
ASSUROR and ISAE 3000 are constants.
Pearson chi-square = 22.250 (p = 0.000)
Fisher’s exact test (p = 0.006; 0.006)
AA1000AS No Yes Total No Yes Total
Assuror n % n % n % n % n % n %
Non-accountant 0 0.0 0 0.0 0 0.0 7 100.0 0 0.0 7 100.0
Accountant 24 64.9 13 35.1 37 100.0 67 88.2 9 11.8 76 100.0
Total 24 64.9 13 35.1 37 100.0 74 89.2 9 10.8 83 100.0
No statistics are computed because
ASSUROR is a constant.
Pearson chi-square = 0.930 (p = 0.335)
Fisher’s exact test (p = 1.000; 0.433)
With regard to the level of assurance provided, analysis of the results obtai-
ned (detailed in Table 11) revealed no association between the entry into force
of the Act and any reference to the level of assurance provided (p > 0.10). In
both periods, most assurors referred to the level applied. Neither was the level
itself associated with the Act’s implementation (p > 0.10), with most assurors
certifying a limited/moderate level of assurance in both periods.
Table 11. Chi-square test: Level of assurance by period
Level of assurance
Not mentioned Mentioned Total
Period n % n % n %
Before Act 11/2018 3 7.5 37 92.5 40 100.0
After Act 11/2018 2 2.4 83 97.6 85 100.0
Total 5 4.0 120 96.0 125 100.0
Pearson chi-square = 1.877 (p = 0.171)
Fisher’s exact test (p = 0.326; 0.186)
Limited/Moderate Reasonable/High or
Combination Total
Period n % n % n %
Before Act 11/2018 34 91.9 3 8.1 37 100.0
After Act 11/2018 79 95.2 4 4.8 83 100.0
Total 113 94.2 7 5.8 120 100.0
Pearson chi-square = 0.504 (p = 0.478)
Fisher’s exact test (p = 0.675; 0.370)
The results obtained for the level of assurance by type of assuror (Table 12),
show that only accountants declared this level before the Act’s entry into force,

31Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
and that most of them (91.9%) applied a limited/moderate level. Subsequently,
all of the accountant firms mentioned the level of assurance, whereas the non-
accountants did so in only 77.8% of cases. The application of a limited/moderate
level was almost universal among the accountants (96.1%), whereas the appli-
cation of a reasonable/high level or a combination of both levels was more fre-
quent among the non-accountants (14.3%). In both periods, the likelihood of the
level of assurance being mentioned was significantly associated with the type
of assuror (p < 0.01), with accountants being more likely to mention the level.
However, the level of assurance was not significantly associated with the type
of assuror (p > 0.10).
Table 12. Chi-square test: Level of assurance by type of assuror
Level of assurance
Before the Act After the Act
Not
mentioned Mentioned Total Not
mentioned Mentioned Total
Assuror n % n % n % n % n % n %
Non-accountant 3 100.0 0 0.00 3 100.0 2 22.2 7 77.8 9 100.0
Accountant 0 0.0 37 100.0 37 100.0 0 0.0 76 100.0 76 100.0
Total 3 7.5 37 92.5 40 100.0 2 2.4 83 97.6 85 100.0
Pearson chi-square = 40.000 (p = 0.000)
Fisher’s exact test (p = 0.000; 0.000)
Pearson chi-square = 17.296 (p = 0.000)
Fisher’s exact test (p = 0.010; 0.010)
Limited/
Moderate
Reasonable/
High or
Combination
Total Limited/
Moderate
Reasonable/
High or
Combination
Total
Assuror n % n % n % n % n % n %
Non-accountant 0 0.0 0 0.0 0 0.0 6 85.7 1 14.3 7 100.0
Accountant 34 91.9 3 8.1 37 100.0 73 96.1 3 3.9 76 100.0
Total 34 91.9 3 8.1 37 100.0 79 95.2 4 4.8 83 100.0
No statistics are computed because
ASSUROR is a constant.
Pearson chi-square = 1.493 (p = 0.222)
Fisher’s exact test (p = 0.302; 0.302)
Table 13 refers to the kinds of conclusions presented in the assurance re-
port. The Act’s entry into force was found to be significantly associated with
the type of conclusions (p < 0.01). Although most assurors issued unmodified
conclusions, 14.1% issued modified conclusions after the Act came into force.

32Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
Table 13. Chi-square test: Conclusions by period
Conclusions
Unmodified Modified Total
Period n % n % n %
Before Act 11/2018 40 100.0 0 0.0 40 100.0
After Act 11/2018 73 85.9 12 14.1 85 100.0
Total 113 90.4 12 9.6 125 100.0
Pearson chi-square = 6.247 (p = 0.012)
Fisher’s exact test (p = 0.009; 0.007)
Our analysis of the conclusions presented according to the type of assuror
(Table 14) shows that all assurors issued unmodified conclusions before the Act
came into force. Afterwards, the non-accountants continued to issue unmodi-
fied conclusions, but only 84.2% of the accountants did so, while 15.8% issued
modified conclusions. Nevertheless, the type of conclusion issued was not signi-
ficantly associated with the type of assuror (p > 0.10).
Table 14. Chi-square test: Conclusions by type of assuror
Conclusions
Before the Act After the Act
Unmodified Modified Total Unmodified Modified Total
Assuror N % n % n % n % n % n %
Non-accountant 3 100.0 0 0.0 3 100.0 9 100.0 0 0.00 9 100.0
Accountant 37 100.0 0 0.0 37 100.0 64 84.2 12 15.8 76 100.0
Total 40 100.0 0 0.0 40 100.0 73 85.9 12 14.1 85 100.0
No statistics are computed because
CONCLUSIONS is a constant.
Pearson chi-square = 1.655 (p = 0.198)
Fisher’s exact test (p = 0.347; 0.236)
Table 15 shows the results obtained with respect to the recommendations
made. Notably, the entry into force of the Act is significantly associated with
the assuror making recommendations to the reporting organisation (p < 0.05).
Specifically, the likelihood of this taking place rose from 15.3% to 32.5% with
the entry into force of Act 11/2018.
Table 15. Chi-square test: Recommendations by period
Recommendations
No Yes Total
Period n % n % n %
Before Act 11/2018 27 67.5 13 32.5 40 100.0
After Act 11/2018 72 84.7 13 15.3 85 100.0
Total 99 79.2 26 20.8 125 100.0
Pearson chi-square = 4.888 (p = 0.027)

33Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
Finally, concerning the recommendations made according to the type of
assuror (Table 16), only the accountants made recommendations (35.1% doing
so before the Act’s entry into force and 17.1% afterwards). Nevertheless, the pre-
sentation of recommendations was not significantly associated with the type of
assuror (p > 0.10).
Table 16. Chi-square test: Recommendations by type of assuror
Recommendations
Before the Act After the Act
No Yes Total No Yes Total
Assuror N % n % n % n % n % n %
Non-accountant 3 100.0 0 0.0 3 0.0 9 100.0 0 0.00 9 100.0
Accountant 24 64.9 13 35.1 37 100.0 63 82.9 13 17.1 76 100.0
Total 27 67.5 13 32.5 40 100.0 72 84.7 13 15.3 85 100.0
Pearson chi-square = 1.562 (p = 0.211)
Fisher’s exact test (p = 0.538; 0.296)
Pearson chi-square = 1.817 (p = 0.178)
Fisher’s exact test (p = 0.343; 0.207)
V. Discussion and conclusions
In this paper, we analyse the situation, in the Spanish context, of the man-
datory external assurance of companies’ non-financial statements. In our opi-
nion, this study is both timely and important. Moreover, its significance was
heightened by the entry into force of Act 11/2018, as the study periods analysed
enabled us to highlight the effects of the transition from voluntary to manda-
tory external assurance.
The results obtained show that some Spanish listed companies are still not
adopting external assurance despite this being mandatory since the Act’s entry
into force. However, it should be noted that some of the companies that do not
assure their reports are not in fact obliged to do so because they have fewer
than 250 employees. Nevertheless, they might choose to do so as a means of
legitimating corporate behaviour.
Our analysis revealed no significant association between the choice of
assuror and the Act’s implementation. Regardless of the period considered,
most companies prefer accountants to perform the assurance process. On the
other hand, the type of assuror preferred does depend on certain corporate
characteristics. Specifically, companies listed in the IBEX-35 are more likely
to choose one of the Big 4 firms to assure their reports. In particular, com-
panies that made a financial loss during the previous year preferred the firm
EY, those operating in a non-sensitive business sector opted for KPMG, and
those which had a sustainability committee and a longer-serving CEO were
more inclined towards PwC.

34Assurance on non-financial information in Spain
Bollas, H. & Sierra-García, L.
The study results also show that the entry into force of the Act significantly
affected the use of applicable standards. Thus, AA1000AS was more commonly
used before the Act came into force than afterwards. This inversion might have
taken place because this standard is oriented towards sustainability reports,
whereas the ISAE 3000 focuses more on non-financial information. On the other
hand, the combined use of both standards was more common after the applica-
tion of the Act.
We also found differences according to the type of assuror hired for this
task. In line with Deegan et al. (2006a, b), we found that accountant firms were
more likely to mention the standard(s) used. Moreover, and confirming Mock
et al. (2007, 2013), we observed that accountants were more likely to use ISAE
3000, which in itself is not surprising, since this standard is issued by an inter-
national auditing body (Perego and Kolk, 2012). Following Manetti and Tocca-
fondi (2012), we found that accountants were more likely to combine the two
standards in their assurance process. The use of external standards is consis-
tent with the institutional theory approach of normative isomorphism (Smith et
al., 2011; Fernández-Feijóo et al., 2015).
Confirming the prior work of O’Dwyer and Owen (2005) and Bollas-Araya
et al. (2018), we show that accountants are more likely to indicate the level of
assurance. However, we did not measure a significant association between the
level of assurance stated and the type of assuror responsible.
The entry into force of Act 11/2018 was also relevant to the assurors’ stated
conclusions, which were more likely to be modified after the Act’s implemen-
tation. This might be because mandatory NFI reporting is relatively recent, and
therefore companies might not yet be sufficiently prepared to fully comply with
its requirements. On the other hand, we found no significant differences by
type of assuror.
Our results also indicate that implementation of the Act influenced the re-
commendations made, but in a negative sense, as the assurors actually made
more recommendations before the Act’s entry into force. However, these re-
commendations were not significantly associated with the type of assuror.
The research presented in this paper is subject to some limitations, such
as the use of just two time points, spanning twelve months. The data from a
longer period could usefully be analysed, to generalise the results obtained.
Moreover, in the future, we hope to expand the scope of our analysis to include
companies in other EU countries.
Nevertheless, our analysis has significant implications. For academics, it
enhances our understanding of how companies react to the imposition of a
mandatory system of external assurance, as recently occurred in Spain. From
a managerial perspective, the external assurance of NFI is an opportunity to
demonstrate the company’s commitment to sustainability and to enhance its

35Contaduría Universidad de Antioquia – No. 79. Medellín, j ulio-diciembre de 2021
accountability to stakeholders. Nevertheless, companies should be cautious,
taking care to employ assurance providers offering professionalism and inte-
grity. Similarly, assurance providers should act in accordance with strict ethical
principles in order to avoid situations such as the financial scandals that have
affected some members of the audit profession. Therefore, the assurors’ in-
dependence needs to be clarified. Finally, stakeholders should be made more
aware that the assurance of non-financial corporate reporting improves its qua-
lity and reliability.
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