The Energy Saving Certificates Scheme is preparing for a new phase

The Energy Saving Certificates Scheme (its Spanish acronym, CAE), established by Royal Decree 36/2023, is a mechanism for certifying the achievement of final energy savings within the framework of the National Energy Efficiency Obligations Scheme (its Spanish acronym, SNOEE). Each CAE recognises an annual saving in final energy resulting from an energy efficiency measure, and the system allows for its monetisation.

With a view to streamlining administrative procedures, strengthening the traceability of operations, defining the responsibilities of the various stakeholders more precisely, and adapting the Spanish regulatory framework to Directive (EU) 2023/1791 on energy efficiency, the Ministry for Ecological Transition and the Demographic Challenge (its Spanish acronym, MITECO) has introduced an amendment incorporating, amongst other things, the following new provisions:

• It incorporates the definitions of final energy savings, savings aggregator, assignment contract and CAE file.
• It introduces changes to the fulfilment of energy-saving obligations. The calculation criteria to be taken into account when determining the minimum percentage of the annual energy-saving obligation to be met through financial contributions to the SNOEE are adapted.
• The role of the delegated party is clarified, particularly regarding their legal, technical and economic-financial capacity requirements, and it is expressly established that they may not delegate their settlement obligation. Furthermore, the energy-saving obligation continues to rest with the obligated party, even if they have delegated its fulfilment.
• Provisions are introduced to improve the functioning of the National CAE Register (its Spanish acronym, RNCAE) and, in particular, the traceability of CAEs issued, transferred and settled.
• Greater control and accountability are provided for verifiers and the inclusion of different standardised procedures within a single application is permitted, provided they have been carried out during the same year and within the same autonomous community.
• The energy-saving auction mechanism is regulated more comprehensively. A new specific chapter is created for the auction regime, distinguishing between the ‘energy-saving commitments’ auction modality and the ‘energy-saving requirements’ auction modality. The auctions will be of a complementary nature, as the ordinary issuance and settlement of Energy Saving Certificates (CAE) will remain the system’s primary channel.
• The initial authorisation of OMIE (nominated electricity market operator) and MIBGAS (Iberian Gas Market) to develop and manage the electronic platform has been approved.

The reform aims to transform the system into a more structured and traceable mechanism, where obligated companies can enjoy greater flexibility in meeting their targets. With regard to delegated entities, verifiers, energy service companies and aggregators, the proposal may open up new opportunities, whilst also increasing the requirements regarding capacity, solvency and control.

The entities concerned should closely monitor the legislative process, review the new deadlines and prepare internal procedures to ensure the accreditation and traceability of the savings.

Until the reform is approved and published, its content should be regarded as a proposal and not as a current obligation. For the time being, MITECO has submitted the draft royal decree for public consultation and information, which will remain open from 3 to 23 September 2026.