What the 2027 draft order contains
Spain's Ministry for the Ecological Transition and the Demographic Challenge (MITECO) published the draft order on energy savings obligations for 2027 on 14 October 2026. The text is open to public hearing and information. Comments are accepted from 15 October to 6 November 2026, through an online form.
This annual order governs the Sistema Nacional de Obligaciones de Eficiencia Energética (SNOEE). The SNOEE is the mechanism created by Law 18/2014 that imposes an annual energy savings quota on certain companies, the sujetos obligados or obligated parties. They meet it by paying into the National Energy Efficiency Fund (FNEE) or, for part of it, by settling Certificados de Ahorro Energético (CAE).
The CAE system itself is governed by Real Decreto 36/2023 of 24 January 2023 and by Orden TED/815/2023 of 18 July 2023. The annual order does not change its rules: it sets the volume to be achieved and the split between the FNEE and certificates.
The 2027 draft order sets four parameters. The table compares them with the 2026 values, published in the BOE in Orden TED/133/2026.
| Parameter | 2026 (Orden TED/133/2026) | 2027 (draft order) |
|---|---|---|
| SNOEE target | 801.822 ktoe (9,325.189 GWh) | 850 ktoe (9,885.50 GWh) |
| How the obligation is calculated | Sales of the second preceding year | Rate of 1.118% applied to actual volumes in the year |
| Financial equivalence | €2.31 million per ktoe | €2.33 million per ktoe (€200,213.24 per GWh) |
| Minimum share paid into the FNEE | 8% | 5% |
According to the draft order, the 2027 obligation arises on 1 January 2027 and must be met in full by 31 March 2028 at the latest. The first payment into the FNEE is due by 30 April 2027 at the latest. The order would take effect on 1 January 2027.
The real change: an obligation calculated on the current year
Until 2026, each annual order published the list of obligated parties and their individual obligation. That obligation was based on each party's energy sales in the second year before the obligation year. The preamble of the 2027 draft order recalls this mechanism.
Real Decreto-ley 7/2026 of 20 March 2026 amended Law 18/2014 and replaced this approach from 1 January 2027. Each obligated party now calculates its own obligation, by applying the tasa de ahorro energético to its actual sales, supplies and consumption of final energy in the year.
The tasa de ahorro energético is the annual rate that converts a volume of final energy into a savings obligation. The draft order sets it at 1.118% for 2027. According to the explanatory memorandum, this rate is the ratio between the 850 ktoe target and Spain's forecast final energy consumption for 2027, estimated at 883,913.20 GWh.
The calculation becomes quarterly and cumulative. The draft order provides that each obligated party applies the rate to its cumulative volumes since 1 January 2027. It then deducts the obligations already determined and met in previous quarters. The sum of the four quarters must equal the rate multiplied by the volumes for the whole year.
Payments into the FNEE remain quarterly. The preamble of the draft sets the deadlines at 30 April, 31 July and 31 October for the first three quarters, then at 31 March of the following year for the fourth.
New obligated parties from 2027
Real Decreto-ley 7/2026 also widens the range of obligated companies. According to the draft order, the following are obligated parties from 1 January 2027:
| Category | Status before 2027 | From 2027 |
|---|---|---|
| Gas and electricity retailers | Obligated | Obligated |
| Wholesale operators of petroleum products and LPG | Obligated | Obligated |
| Direct market consumers of natural gas and electricity | Not obligated | Obligated |
| Retail distributors of petroleum products and LPG | Not obligated | Obligated |
| Consumers of petroleum products or LPG | Not obligated | Obligated, on the terms of Article 69 of Law 18/2014 |
The explanatory memorandum justifies this extension by the aim of applying the obligations in a uniform and non-discriminatory way. A company that becomes an obligated party during the year calculates its obligation on its actual volumes, from the date its relevant activity starts until 31 December 2027.
Checking the calculation falls to the Dirección General de Planificación y Coordinación Energética, according to the draft order. The identification code of an obligated party in the CAE system will consist of « SO- » followed by its NIF tax number.
Why these figures
The SNOEE target derives from Article 8 of Directive (EU) 2023/1791 on energy efficiency. According to the explanatory memorandum, Spain must achieve 53 593 ktoe of cumulative final energy savings over 2021-2030. This volume is 44% higher than the target set by the previous directive for the same period.
The pace required by the directive is accelerating. The memorandum recalls an annual rate of new savings of 1.5% for 2026-2027, then 1.9% for 2028-2030. The SNOEE is only one of two levers: Spain combines obligations with alternative measures, such as tax measures or financial support.
The lower minimum share for the FNEE follows the same logic. The explanatory memorandum presents it as a way to « flexibilizar el cumplimiento de las obligaciones por parte de los sujetos obligados en los años futuros ». In 2027, up to 95% of each obligation can therefore be covered with CAE certificates, compared with 92% in 2026.
The draft also adjusts the path announced at the start of the year. Orden TED/133/2026 forecast, for information only, 900 ktoe, €2.43 million per ktoe and 8% to the FNEE for 2027. The draft retains 850 ktoe, €2.33 million per ktoe and 5%.
The indicative path to 2029
The draft order publishes a non-binding forecast for the following two years.
| Year | SNOEE target | Financial equivalence | Minimum share to the FNEE |
|---|---|---|---|
| 2027 (draft) | 850 ktoe | €2.33m/ktoe | 5% |
| 2028 (indicative) | 875 ktoe | €2.40m/ktoe | 5% |
| 2029 (indicative) | 900 ktoe | €2.45m/ktoe | 5% |
The text states that these values remain for information only. Each annual order will set them according to Spain's European commitments, the economic situation and developments in the sector.
Finally, the draft corrects several clerical errors in the 2024, 2025 and 2026 orders, notably for companies that had ceased the activity giving rise to their obligation. It provides the application forms for refunds of sums paid into the FNEE in error.
What it means for you
For a manufacturer or large energy consumer in Spain
A manufacturer that buys its gas or electricity directly on the market, or that consumes petroleum products or LPG, should check whether it falls within the new scope of Article 69 of Law 18/2014. If so, its obligation will arise on 1 January 2027, on its own volumes. Its energy efficiency projects can then generate CAE certificates that cover part of this obligation, under the conditions of Real Decreto 36/2023.
For a project owner, social landlord or local authority
Two parameters of the draft favour demand for CAE certificates: the national target rises and the share that certificates can cover increases to 95%. Savings from a renovation, a heat generator replacement or an industrial upgrade become more attractive to buyers. The value of a saving is, however, freely negotiated, and the order sets no price.
For an existing obligated party or a sujeto delegado
The quarterly calculation on actual volumes replaces an obligation known in advance. Cash flow, CAE purchasing and reporting must follow this pace. A sujeto delegado can expect new counterparts among the newly obligated companies.
For a French company working in Spain
The Spanish mechanism moves a little further away from the French energy savings certificate scheme (CEE), where the obligation is set by period. Teams working on both sides of the Pyrenees need to distinguish these two approaches in their offers.
Our recommendations
The text is only a draft: the values may change before the final order. We are following the procedure and its outcome in the BOE.
A company concerned can make its views known during the public hearing. MITECO states that contributions are, by default, treated as non-confidential. Sensitive information must be flagged and marked out in the text, with the reasons for this request.
To place the system in context, our guide to CAE certificates in Spain details the players, the steps and the deadlines. The draft reform of Real Decreto 36/2023 is changing, in parallel, the rules for issuing and settling certificates.
IHD's engineering office supports manufacturers, project owners and operators with their energy efficiency projects in Spain, from the study through to the valorisation of the savings. Our Markets page presents this activity. To assess your position against the new 2027 scope, contact us.
