What is a Spanish CAE?
Spain's energy savings certificate system rests on Real Decreto 36/2023 of 24 January 2023. This royal decree implements article 71 of Law 18/2014 of 15 October 2014, which allows companies subject to an energy savings obligation to meet it by presenting certificates.
A Certificado de Ahorro Energético (CAE, energy savings certificate) is an electronic document that recognises the annual final energy savings achieved by an energy efficiency actuación (action). The action falls either under the catalogue of standardised measures or under a so-called singular study, for operations the catalogue does not cover.
Real Decreto 36/2023 issues each CAE at a value of 1 kWh, with no decimals, and makes it indivisible. Once entered in the national register, a CAE is valid across Spain. It can only be traded between the parties authorised to hold it: the sujetos obligados (obligated parties) and the sujetos delegados (delegated parties).
The scheme pursues the same aim as the French energy savings certificates: funding energy efficiency works through an obligation placed on energy suppliers. The two systems differ, however, in their unit, their parties and their procedure. Our guide to French energy savings certificates presents the neighbouring scheme, and our overview of energy savings obligations in Europe places them in the European framework.
The obligation that drives the market: sujetos obligados and the FNEE
A CAE has value only because an obligation exists. In Spain, it sits within the national energy efficiency obligation system (SNOEE), which allocates a national savings target each year among the sujetos obligados.
Under article 69 of Law 18/2014, a sujeto obligado is a gas or electricity retailer, a wholesale petroleum product operator or a wholesale liquefied petroleum gas operator. Each sujeto obligado receives a share of the savings to be achieved, converted into euros through a "financial equivalence".
A sujeto obligado meets its obligation in two ways: by a contribution to the National Energy Efficiency Fund (FNEE), paid in four quarterly instalments, or by settling CAE. Using CAE is voluntary, but it is capped: a minimum share of the obligation must always go to the FNEE.
Orden TED/133/2026 sets the parameters for 2026:
| Parameter | 2026 (set) | 2027 (indicative) | 2028 (indicative) |
|---|---|---|---|
| National SNOEE target | 801.822 ktep (9,325.189 GWh) | 900 ktep | 950 ktep |
| Financial equivalence | 2.31 M€/ktep (€198,624.25/GWh) | 2.43 M€/ktep | 2.50 M€/ktep |
| Minimum share paid to the FNEE | 8% | 8% | 5% |
For 2026, a sujeto obligado may therefore cover up to 92% of its obligation with CAE. The 2026 obligation arose on 1 January 2026, and the first payment to the FNEE was due by 31 March 2026 at the latest. A sujeto obligado without enough CAE pays the balance to the FNEE by 31 December 2026 at the latest.
The order specifies that the 2027 and 2028 values are informative and non-binding: each year will have its own ministerial order. They nonetheless show a clear trend, with a rising target and a falling mandatory FNEE share, and therefore a growing role for CAE.
The six parties in the system
Real Decreto 36/2023 divides roles between private parties, which produce and buy the savings, and authorities, which check and record them.
| Party | Who it is | Its role |
|---|---|---|
| Sujeto obligado | Gas or electricity retailer, wholesale petroleum or LPG operator | Carries the annual obligation; may settle CAE |
| Sujeto delegado | Legal entity accredited by the Coordinador Nacional | Obtains and settles CAE on behalf of one or more sujetos obligados |
| Savings owner | Whoever funds the action, or to whom the savings were assigned | Assigns its savings in return for consideration |
| Verificador de ahorro energético | Body accredited by ENAC | Checks the file and gives a favourable or unfavourable opinion |
| Gestor Autonómico | Body designated by each autonomous community, Ceuta and Melilla | Examines the request and issues the CAE |
| Coordinador Nacional | The system's national authority | Keeps the national register, accredits sujetos delegados, checks settlements |
The sujeto delegado is the figure closest to the French delegate. Real Decreto 36/2023 specifies, however, that it never takes on the obligation itself: it stays with the sujeto obligado. If the sujeto delegado fails to meet its commitments or ceases to exist, each sujeto obligado that had delegated part of its obligation to it must fulfil it directly. The sujeto delegado also cannot entrust its settlement commitment to a third party, even in part.
The MITECO page on the system's parties publishes the list of Gestores Autonómicos, with their dedicated address, and that of accredited sujetos delegados. It also refers to the ENAC search engine to identify the verificadores and the types of actions each is accredited for.
From site to certificate: the main steps
The path of a CAE follows four steps set by articles 12 to 14 of Real Decreto 36/2023.
Assigning the savings
When the sujeto obligado or delegado has not funded the action itself, it must acquire the savings from their original owner. The decree in force provides for a convenio CAE (CAE agreement) for this purpose: an agreement under which the owner assigns its savings in return for consideration that secures the incentive effect.
Verification
Once the action is complete, the sujeto obligado or delegado freely chooses a verificador accredited by ENAC. The verificador checks that the file meets the requirements of the catalogue or the applicable orders, requests the necessary corrections, then gives a favourable or unfavourable opinion. A single request may group several actions carried out in the same year within the same autonomous community.
Issuance and registration
The applicant files the issuance request with the Gestor Autonómico of the community where the works took place, with the file and the verificador's favourable opinion. It states whether the action received public support; if so, it must justify the CAE's own incentive effect.
| Step set by Real Decreto 36/2023 | Standardised action | Singular action |
|---|---|---|
| Issuance by the Gestor Autonómico | 15 days | 30 days |
| From request to final entry in the national register | 20 days | 35 days |
| Correction of an incomplete file | 10 days at most | 10 days at most |
In both cases, administrative silence at the end of the period counts as acceptance. Orden TED/815/2023 adds two thresholds: each issuance request must cover at least 30 MWh of savings, except in Ceuta and Melilla, and a sujeto obligado whose annual obligation is below 50 MWh cannot request CAE issuance that year.
The applicant undertakes to keep the measure active throughout its declared lifetime and to keep the file documents for at least three years after settlement.
Settlement
The holder of a CAE settles it against a savings obligation. When a sujeto delegado settles, it tells the Coordinador Nacional which sujeto obligado the savings are to be attributed to.
Catalogue of sheets and singular actions
The catalogue of standardised measures is approved by ministerial order, on a proposal from the Coordinador Nacional and after consulting the Gestores Autonómicos. Each sheet gives the method for calculating the recognised savings and the list of documents proving that the works were carried out.
The catalogue is revised regularly by resolution, to follow the market and technical developments. The revision of the public transport sheets published in 2026 is one example, which we detailed in our analysis of the CAE transport catalogue.
An action that matches no sheet can be submitted as singular. It then requires its own justification of the savings and longer processing times.
CAE lifetime and deadlines to watch
Under articles 11.5 and 14.5 of Real Decreto 36/2023, a CAE can be entered in the national register, then settled, up to three years after the action that produced the savings. The action must have been carried out after the decree came into force, and settlement must take place before 1 January 2031.
This rule creates an immediate deadline for works carried out in 2023. In a clarification note of 2 June 2026, MITECO states that CAE from 2023 actions must be issued and settled before 31 December 2026, and cannot be validly issued in 2027.
Becoming a sujeto delegado
A company that wants to act as a sujeto delegado must first be accredited by the Coordinador Nacional. Orden TED/815/2023 details the conditions:
| Requirement | What Orden TED/815/2023 provides |
|---|---|
| Legal capacity | Its own legal personality; Spanish nationality, nationality of another EU member state, or a permanent establishment in Spain |
| Technical capacity | Qualified in-house staff and a certified quality management system covering the activity |
| Financial strength | Equity above 500 000 euros; up to date with tax and social security obligations |
| Civil liability insurance | At least 1 million euros, covering at least 10% of commitments; 2 million and 20% for an entity with under three years of experience |
The insurance amount determines the maximum commitment capacity the sujeto delegado can take on. Orden TED/815/2023 also specifies that a sujeto delegado meets its commitments only by settling CAE, never by a payment to the FNEE.
A reform in preparation
The system will change. From 3 to 23 September 2026, MITECO put to public hearing a draft royal decree amending Real Decreto 36/2023: new processing times, a settlement calendar set at 20 March, a savings assignment contract replacing the convenio CAE, and the creation of the savings aggregator. Until this text is published in the Official State Gazette, the rules described in this guide apply. We analysed the draft in our article on the reform of Real Decreto 36/2023.
What this means for you
For an industrial company, a landlord or a project owner in Spain
You are the original owner of the energy savings produced by your works. Those savings have a value: you can assign them to a sujeto obligado or a sujeto delegado in return for consideration, provided the CAE keeps an incentive effect. The 30 MWh threshold per request and the three-year period for registering the certificate matter when planning a project.
For an installer or an engineering firm
The quality of the file determines the verificador's opinion, then the Gestor Autonómico's decision. An incomplete file has only 10 days to be corrected before it is rejected and archived. The value of your offer depends as much on the compliance of the documents as on the works themselves.
For a sujeto obligado or a sujeto delegado
The share of the 2026 obligation that CAE can cover reaches 92%, and the 2027 and 2028 forecasts point the same way. The volume of CAE to secure is rising, while processing times and the 31 December 2026 deadline call for early filing.
For a French company working in Spain
The sujeto delegado plays a role comparable to that of the French delegate, but the unit, the prior verification by an accredited body and the issuance by a regional authority change how a file is built. CEE experience is an asset, provided it is adapted to Spanish law.
What we recommend
Think in annual final energy savings. A CAE is counted in kWh of annual savings, not in kWh accumulated over the lifetime: a comparison with a French project is never made figure for figure.
Identify the right counterpart early. The Gestor Autonómico depends on where the works take place, and the verificador must be accredited for the type of action concerned.
Secure the assignment of the savings before the works. The consideration offered to the owner is what proves the incentive effect, and it is what will be examined if the action also received public support.
Follow the reform. Contracts and calendars drawn up today will have to be checked against the final text as soon as it is published.
Our engineering firm follows both systems, French and Spanish, and supports each action from the initial study through to the valorisation of the savings. Discover the markets we follow, including Spain, or write to us to review a specific project.
