Over the last several years, ESG reporting has moved from a voluntary practice to a regulated obligation across Europe. The EU’s Corporate Sustainability Reporting Directive, in force since 2024, requires externally auditable data on workforce conditions, wages, and governance from thousands of companies? with scope expanding to mid-size businesses from the 2025 financial year.
As this reporting infrastructure matures, a secondary problem has become more visible: the gap between what companies declare and what verifiable data shows. Sustainability reports are written documents. The indicators they omit are often more informative than the ones they include.
For investors, procurement teams, and multinationals evaluating Spanish business partners or acquisition targets, this gap is a due diligence problem. Spain has a specific labor subsidy infrastructure? regional employment programs managed by Labora in Comunitat Valenciana, SAE in Andalucía, SOC in Catalunya, and SEPE at the national level? that channels significant public funding to private employers. Whether those funds translate into stable employment, or are used instrumentally, is a governance question that rarely surfaces in a sustainability report.
A free instrument calibrated for the Spanish market
The ESG Labor Audit Tool, developed by Yel Martínez and available at no cost without registration, is an open-source instrument built to cross-reference declared ESG data with publicly available sources: Spain’s SEPE employment statistics, the Labora subsidy register, the Mercantile Registry, and GRI Standards benchmarks disaggregated by CNAE-2009 sector classification.
All processing runs locally in the browser. No data is transmitted to external servers. The output is an exportable audit report scoring a company from 0 to 100 across five labor risk dimensions, with traffic-light indicators and sector benchmark comparisons.
The tool is available online without registration or payment: ESG Labor Audit Tool , and it can also be downloaded locally from GitHub as an open-source tool.
Five dimensions, five risk signals
The framework evaluates indicators that are either omitted from or poorly quantified in most Spanish sustainability reports:
Unpaid internship exposure (GRI 401-1). The proportion of interns relative to total workforce, remuneration rate, and conversion to permanent contract. In the technology sector (CNAE J), more than 20% of workforce in unpaid placements is a structural pattern, not an exception ? and a liability under CSRD’s ESRS S1.
Recurrence in public employment subsidies (GRI 205-1). How many times a company has applied to regional subsidy programmes in the last five years, whether renewals target the same job profile, and whether any subsidised position reached 12 months of seniority. Systematic recurrence without workforce consolidation is a governance risk that belongs in any third-party risk assessment.
Artificial salary pyramid (GRI 405-2). Concentration of workforce in the lowest pay categories ? Administrative Assistant or equivalent ? is a documented strategy for reducing social security contributions without exceeding legal minimums. The tool flags when this concentration exceeds sector benchmarks by CNAE, alongside short-term contract ratios and indefinite contract rates.
Gender pay gap coherence (GRI 405-2). The declared pay gap measured against sector average, and the percentage of women in senior roles. A reported 3% gap built on a workforce where 70% of female employees sit in the lowest pay bracket is a statistical artefact. The tool flags the discrepancy.
Sustainability report quality and legal compliance (GRI 2-23). Whether the report quantifies unpaid interns, discloses subsidy amounts received, and whether the legally mandated Equality Plan is registered in REGCON ? required for companies with more than 50 employees in Spain. A report that omits negative data is not a transparency document; under CSRD, that omission now has regulatory weight.
Context: a growing market with a Spain-shaped gap
The global ESG due diligence market was valued at USD 650 million in 2024 and is projected to reach USD 1.5 billion by 2034. The enterprise tools that dominate this market ? from EY, PwC, KPMG, and specialist platforms ? are not calibrated for the specific subsidy architecture, regional employment programmes, and sector benchmarks that define labour risk in Spain.
For a procurement team vetting a Spanish supplier, an investor conducting pre-acquisition analysis, or a multinational assessing a local partner’s CSRD alignment, this tool offers a first-pass instrument that costs nothing and takes under ten minutes to run.
For users with access to primary data, a companion Python kit on GitHub (GPL-3.0) enables advanced analysis: Social Security and subsidy cross-referencing, detection of functions exceeding declared job category, and NIF-level recurrence patterns across subsidy programmes.
Open source, part of a broader ESG stack
The labour audit tool is part of the Greentech suite developed by Martínez, a ten-tool open-source collection covering carbon footprint calculation, greenwashing detection, GRI report generation, and self-assessment for Spain’s SIR (Register of Socially Responsible Entities). All tools are free, unregistered, and designed for the specific regulatory context of Spain.
Yel Martínez is a digital strategist and technologist certified in environmental management and environmental audit (SEAG0211 · SEAG002PO). She develops open-source ESG tools for SMEs and public institutions in Spain.
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