Spain: Key Regulatory Developments in the Energy Sector in the Third Quarter of 2025

The third quarter of 2025 has been marked by important regulatory developments and debates in the energy sector. Following the electricity blackout on 28 April, institutions and regulators have accelerated the approval of measures aimed at strengthening security of supply and promoting the transition to a more resilient and sustainable energy model.

We have compiled and analysed the main milestones of this period:

Consequences of the energy zero of April 28

The investigations opened after the blackout have highlighted the need to strengthen the resilience of the electricity system. Royal Decree-Law 7/2025 introduced urgent measures in this area, some of which are being processed as a draft Royal Decree. All this anticipates a scenario of relevant litigation, with claims from affected parties and insurers that will last over time.

CJEU ruling on environmental assessment

The Court of Justice of the European Union ruled on August 1 on the interpretation of the Environmental Impact Assessment Directive. The ruling clarifies that consultation with authorities and public information can be carried out simultaneously, reinforcing the legal certainty of the procedures and limiting the rights of access to certain reports.

Royal Decree 917/2025: new regulation for renewables, cogeneration and waste

This regulatory text introduces significant adjustments to the remuneration regime of RECORE facilities, adapting it to an environment of zero or negative prices. It also incorporates measures that facilitate the integration of energy storage and make the management of cogeneration more flexible, in addition to transposing modifications to the European Directive on energy efficiency into Spanish regulations.

Gas and hydrocarbons: remuneration and prices

The quarter has brought with it various resolutions from the CNMC and the Directorate General for Energy Policy and Mines that update prices and methodologies in the gas system. These include the setting of reference prices for gas and oil extraction, and the definition of the remuneration of the technical manager of the gas system for 2026.

Energy efficiency and aid for decarbonisation

In terms of energy efficiency, Royal Decree 659/2025 introduces new requirements for building certifying technicians. Likewise, the regulatory bases for aid to strategic projects have been approved, including the first calls linked to the European Hydrogen Bank, within the framework of the Recovery, Transformation and Resilience Plan.

Ongoing consultations and public hearings

The quarter was also characterised by intense consultative activity and public participation. Among the projects in the pipeline are:

• the modification of the framework of electricity self-consumption,
• the transposition of the RED III Directive on renewable energy,
• the regulation of heating and cooling networks and guarantees of thermal origin,
• the electricity grid investment plans for 2026-2030,
• and the draft of the National Strategy against Energy Poverty 2026-2030.

By Marimón Abogados, Spain, a Transatlantic Law International Affiliated Firm.

For further information or for any assistance please contact spain@transatlanticlaw.com

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