The Energy-related Measures In Royal Decree-Law 7/2026, Which Approves The Plan In Response To The Crisis In The Middle East

Royal Decree-Law 7/2026 of 20 March, approving the Comprehensive Plan in Response to the Crisis in the Middle East (RDL 7/2026), entered into force on 22 March. It was ultimately ratified by the Congress of Deputies on 26 March.

1. Introduction

RDL 7/2026 is an extensive piece of legislation, which implements measures that affect a number of different sectors. This note will look at the most relevant measures that affect the energy sector.

Despite the backdrop and its link to the crisis in the Middle East, RDL 7/2026 is, from the perspective of the energy sector, one of the most far-reaching pieces of legislation to have been approved in recent years. This is because, in addition to some temporary measures – aimed at alleviating energy costs for consumers – it introduces structural reforms that affect many different areas: demand-side access and connection, processing and repowering of generation facilities, self-consumption, electricity planning, energy storage, energy efficiency and biomethane. However, in certain cases the provisions are not applicable immediately, subject to further regulatory development – if so, the essential principles have been defined. 

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2. New regime for demand-side access and connection

Removal of grid access guarantees and the creation of a capacity reserve payment as the mainstay of the new system

RDL 7/2026 replaces the previous system of financial guarantees for requesting demand-side access with one that is substantially different: the capacity reserve payment (prestación por reserva de capacidad, or PRC), which has the following characteristics:

• The PRC establishes that consumers (a concept that does not include storage facilities) holding demand-side access and connection permits at voltages equal to or greater than 1 KV are obliged to make monthly payments, the amount of which will be determined by the product between the power granted in their grid access permit¹ and the power component of the tariffs corresponding to their tariff segment in hourly period P1, multiplied by a factor k that increases over time. The RDL defines the value of factor k per tariff segment² (although this may be modified by resolution of the Secretary of State for Energy).
• The holders of grid access permits associated with the development of urban infrastructure plans, industrial estates, or those where the connection infrastructure is assigned to the grid operator to connect several consumers, pursuant to article 39.3 of the Spanish Electricity Sector Law 24/2013, of 26 December (LSE), are exempt from payment of the PRC. This exemption may be modified by Royal Decree.
• The obligation to pay the PRC is triggered three months after obtaining a grid access permit (or from the entry into force of RDL 7/2026 where permits that are granted before that date) and will remain in effect until the third-party grid access contract is signed.
• The PRC is designed as a payment on account or advance payment of electricity transmission and distribution tariffs and will be deducted from those payable after signing the third-party grid access contract. If the demand-side facility does not achieve commissioning and the demand-side grid access permit expires, all PRC payments made will be forfeited.
• However, even if the facility is commissioned, it is not guaranteed that the PRC payments will be recovered in full. Subsequent discounts of the PRC from tariff payments will be moderated according to two factors: i) the ratio between the contracted power in period P1 and the capacity granted in the grid access permit³; ii) discounts will only reach 100% in the case of PRC amounts paid in the first year; in subsequent years, it will reduce to 80%.⁴ 
• Failure to pay the PRC will result in the automatic expiry of the grid access permit when it exceeds 10% of the amounts owed in the respective calendar year (in the case of non-payments that do not reach this percentage – strictly speaking, non-payment of one month of the PRC – it seems possible to waive that expiry).

Provision is made for guarantees furnished by the holders of demand-side access permits granted prior to the entry into force of RDL 7/2026. In the case of storage facilities, they may request cancellation of the guarantees as of 23 May 2026. In the case of other demand-side facilities, cancellation of the guarantees may only be requested from the moment that the cumulative PRC amounts paid exceed €40/kW (as a result, the holders of pre-existing permits, but not new applicants, will simultaneously pay the PRC and have to maintain these guarantees for a considerable period of time). 

Similarly, a window of three months is established from the entry into force of RDL 7/2026 (until 22 June 2026) in which holders of pre-existing grid access permits may: i) waive them (without this triggering the enforcement of the guarantees); or ii) carry out a single update of their permits to reduce the capacity granted (this reduction may even exceed 50%, without this triggering expiry of the grid access permit).

New grounds for expiry

RDL 7/2026 amends article 33.8 LSE to introduce new grounds for expiry of grid access and demand permits, linked to intermediate milestones. Specifically, expiry will occur in the event of failure to meet the following milestones within the established period:

• Payment of 10% of the investment in network actions: 12 months (counted from granting of the grid access permit and, in the case of permits that existed prior to the entry into force of RDL 7/2026, from 7 November 2025⁵).
• Signing of a project commissioning contract with the grid operator for the grid installations to which the demand-side facility will be connected: three years (counted from the granting of the grid access permit and, in the case of pre-existing permits, from the entry into force of RDL 7/2026).
• Signing of the technical access contract (TAC): four years (calculated from granting or from the entry into force of RDL 7/2026, depending on whether the permit is new or pre-existent).

RDL 7/2026 retains the other grounds for expiry set out in (now repealed) article 23 bis of Royal Decree 1183/2020, of 29 December, on access and connection to electricity transmission and distribution networks (RD 1183/2020), linked to modifications to the facility that result in it no longer being "the same":

• The geometric centre of the facility moving by more than 10 km.
• Change of the Division or Group of the CNAE code associated with the facility, as long as three years have not elapsed since the start of the activity (not applicable to holders of grid access permits associated with the development of urban infrastructure plans, industrial estates, or those in which the connection infrastructure is assigned to the grid operator to connect several consumers).
• Reduction of grid access capacity by more than 50% compared to what was originally applied for and granted.

Finally, a specific expiry regime is introduced for grid access and connection permits for development or urban planning actions⁶. Although subsequent regulation may provide otherwise, it is currently established that these permits will expire five years after they are obtained (entry into force of RDL 7/2026, in the case of pre-existing permits) if authorisation has not been obtained to operate the corresponding electricity infrastructure or they have been transferred to the corresponding distribution company. An application may be made to the CNMC to extend this period for a maximum of five additional years if the applicant provides evidence of justifying circumstances that are not attributable to it, either directly or indirectly.

CNAE included as part of the content of demand-side access permits

An obligation is established to include the National Classification of Economic Activities (CNAE) as part of the content of the application for demand-side access and connection permits and, as a result, in the permit itself. The Division and Group components of the CNAE cannot be modified until three years have elapsed since the energy consumption facility starts operating; otherwise the permit will expire (save for the exceptions indicated above).

Prior to RDL 7/2026, there was no obligation to indicate the CNAE in grid access permits (only in the guarantees, which have now been removed). Therefore, the holders of pre-existing permits are given six months from the entry into force of RDL 7/206 (until 22 September 2026) to update their grid access permits; otherwise the permits will expire. Alternatively, those holders may choose, within four months of the entry into force of RDL 7/206 (until 22 July 2026), to waive their grid access permit, in which case the guarantees furnished will not be enforced.

Modifications to the regime for granting demand-side access permits: priority projects

Changes are made to the regime for granting demand-side access permits. Specifically:

• Applications for grid access permits for self-consumption at generation facilities, under article 6.9 RD 1183/2020, must be made for a minimum capacity equivalent to that indicated in section "3.3 of Operating Procedure 13.1" (50 MW at 220 kV and 125 MW at 400 kV).
• A preferential scheme is established for granting grid access and connection permits to high-priority projects. This applies to real estate development projects for residential use or essential services (hospitals, police, army, water treatment facilities, public transport or its electrification, power supply to ships in ports, facilities related to national security), new industrial consumption that has been declared as strategic in accordance with the procedure established in article 29 RDL 7/2026⁷ and upward upgrades of permits for demand-side facilities that are already making effective use of the grid (they may increase by up to three times the value of the average contracted power in the last two years in hourly period P6 provided that there is no change in the CNAE code Division or Group associated with the activity).
• The preferential scheme means that: (i) network operators must suspend all ongoing applications as soon as an application for a priority project is accepted (unless they are compatible and can be dealt with simultaneously), and this will be processed and resolved in preference to all others; ii) when new access capacity emerges as a result of regulatory or planning changes, grid access permits will not be granted for a period of four months (they may be applied for and assessed, but will not be decided upon); thus, if applications for priority projects are submitted within this period, they will be processed and granted preferentially (if several priority projects exists simultaneously and are not compatible, absolute preference will be given to projects for residential use or essential services and, secondly, to strategic industrial projects); and iii) when, as a result of capacity waivers or reductions within the three-month window established by RDL 7/2026, more than 5 MW of capacity is released, this capacity will remain reserved until the list of nodes and capacities released by the Secretary of State for Energy is published; from that moment onwards that capacity will be granted preferentially to high priority facilities, in accordance with the previous section.
• Likewise, those priority projects may be directly granted grid access permits at the nodes reserved for tendering, without having to wait for an official call to tender.
• The legal regime applicable to demand-side capacity tenders has been clarified. Specifically: i) express legal status is given to reservation for tender due to a lack of "connection possibilities" (as would occur where two applications are made by different consumers at the same position, ex article 39.3⁸ LSE); ii) it is specified that, for the purposes of assessing the need to hold a tender, only applications accepted by the network operator will be taken into account; and iii) in the event of withdrawals or rejections, the transmission system operator may reassess the importance of maintaining the reservation for tender (if the withdrawals or rejections lead to the absence of competition or the possibility of simultaneously meeting the applications submitted)..

3. The development of renewable generation and electricity storage facilities

The creation of Renewable Acceleration Areas

RDL 7/2026 introduces the concept of Renewable Acceleration Areas (RAAs) into Spanish law, thus complying with the provisions of Article 15 quarter of Directive 2018/2001 of 11 December on the promotion of the use of energy from renewable sources (as per Parliamentary Directive 2023/2413 of 18 October 2023).

RAAs are areas that are considered particularly suitable, due to their lower environmental sensitivity, for the construction of renewable electricity generation facilities, including, where appropriate, electrochemical storage facilities hybridised with them.

The competent authorities of the Autonomous Regions and Cities are responsible for the designation of RAAs, further to a report from the Ministry for Ecological Transition and the Demographic Challenge. If RAAs are located in more than one Autonomous Region, the designation will be made by the Sector-wide Energy Conference.

RDL 7/2026 defers the determination of the procedure, criteria and deadlines for the designation of RAAs, as well as the environmental mitigation measures applicable to them, to subsequent regulatory development. It does, however, establish the minimum criteria that will need to be met for this purpose.

Plans for the designation of RAAs will be subject to strategic environmental assessment. As a result, projects located in RAAs will not, as a general rule, be subject to ordinary or simplified environmental impact assessment, unless it is found that they may produce significant unforeseen adverse effects which were not detected during the strategic environmental assessment and which cannot be mitigated by means of the mitigation measures defined in regulations or proposed by the project developer. Similarly, the competent authorities may establish simplified procedures for the authorisation of projects located in RAAs.

Modifications to the application for authorisation and public consultation on generation and storage projects by the General State Administration

Modifications are made to the public consultation procedure for generation and storage projects that must be processed by the General State Administration. Specifically:

• The public consultation period is increased to 45 days when an ordinary environmental impact assessment is required.
• The application for prior administrative authorisation must be accompanied by a statement from the developer certifying that the owners of the affected land and the corresponding local authorities have been informed of the project. The public authority involved may require documentary justification to be produced and, if so, the public consultation may not take place until that information has been produced.

Priority in the processing of applications for "preferential energy projects"

RDL 7/2026 creates the concept of "preferential energy projects", which includes those qualified as such in planning, those located in areas of low environmental sensitivity, as defined by ministerial order issued by the Ministry for Ecological Transition and the Demographic Challenge, those that have been declared strategic investment projects⁹ or as strategic energy facilities by Resolution of the Council of Ministers, those that have obtained the standard of social and territorial excellence referred to in article 20 RDL 7/2026¹⁰ and the repowering referred to in the following section. It is also envisaged that this status may be granted to renewable technology or storage facilities with an installed capacity that is further from the objectives of the National Integrated Energy and Climate Plan (PNIEC).

The processing of these projects will be urgent and preferential over other projects, without this in itself entailing a reduction in the regulatory processing periods.

Plant repowering

RDL 7/2026 introduces a series of amendments to expedite the processing of projects for repowering renewable generation and electrochemical storage facilities (or hybridisations between the two) that do not entail an increase in installed capacity of more than 25%. Specifically:

• In the event of an environmental assessment, this will be limited to the incremental impact on the original project.
• The applicable processing periods are reduced by half (except for the public consultation procedure).
• It will be permitted to reuse studies, measurements and cartography already included in previous files, under the terms to be developed by regulations, provided that they are still technically and legally valid.

Modifications to the environmental assessment procedure

RDL 7/2026 introduces some modifications to the environmental assessment procedure for renewable generation and storage facilities. Specifically:

• It details the conditions under which, even if the legally required reports have not been received, the environmental body may continue the procedure and issue the Environmental Impact Statement (except when the project may appreciably impact, directly or indirectly, Natura 2000 Network sites).
• It introduces the need to grant the developer a hearing on the proposed Environmental Impact Statement for a period of 10 working days, before it can be approved.

Modifications to the provisions applicable to the public utility declaration: minimum requirements for land acquisition agreements

Substantial changes are made to the regime on declarations of public utility for electricity production facilities. Specifically:

• Declarations of public utility are extended to pumped hydroelectric storage facilities.
• In order to apply for a public utility declaration, a statement on compliance must be submitted certifying that purchase agreements have been reached for at least 50% of the area affected by the project (in the case of production; that percentage is 25% in the case of pumped hydroelectric storage facilities). The public authorities may require documentary justification to be produced. These percentages may be modified by royal decree enacted by the Spanish government.
• As an exception, it will be possible to expropriate a greater percentage of area in the case of facilities declared as strategic energy facilities and a statement on compliance is submitted indicating that it has been impossible to reach sufficient acquisition agreements within 12 months.

Extending the benefits of generation facilities to citizens and local authorities

It is established, without further details, that production facilities connected to a voltage equal to or greater than 132 kV must transfer, directly or indirectly, part of the benefits of the projects to the citizens and local communities in the vicinity of these projects. The regulatory development of this provision is deferred to the approval of an Order by the Minister for Ecological Transition and the Demographic Challenge.

Shared evacuation infrastructure

RDL 7/2026 modifies article 21.5 LSE, develops the legal regime applicable to shared evacuation infrastructure. Specifically: 

• It is reiterated that power evacuation infrastructure (which includes the connection to the transmission or distribution grid and, where appropriate, the transformation of electrical energy) is part of a power generation facility and, likewise, of the storage facilities that inject energy into the grid.
• It is established that the owners of the different production and storage facilities that use shared power evacuation infrastructure to feed off power at the same position are jointly liable towards the electricity system.
• For that purpose, those same operators must sign an agreement that includes the distribution of liability among all of them – they are not allowed to transfer liability to other natural or legal persons or exonerate any of those operators from liability.
• This agreement must be signed and notified to the competent administrative body before obtaining prior administrative authorisation. If this has already been granted, it must be submitted within one year of the entry into force of RDL 7/2026.
• Likewise, the agreement must be updated and notified to the competent authority each time a new owner uses the shared infrastructure.
• Failure to submit the agreement will result in liabilities being allocated among the different owners in proportion to the access capacity of their respective grid access and connection permit.

Extension and suspension of milestones for access and connection permits for generation facilities

Several modifications have been made in relation to the expiry milestones for access and connection permits for generation facilities. Specifically:

• The holders of all access and connection permits granted after the entry into force of the LSE and up to 21 March 2026 are allowed to request, once administrative construction authorisation for the respective facility has been obtained, an extension of the deadline for compliance with the final milestone; however, that extension cannot exceed 31 December 2030.
• This extension may be requested within three months of the entry into force of RDL 7/2026 or of obtaining the administrative construction permit, whichever is later. The request must indicate the six-month period of the calendar year in which the facility will obtain the provisional administrative operating permit for testing and include an express commitment to accept that it will not be possible to obtain the provisional or definitive administrative operating permit, nor to obtain prior or definitive registration in the administrative register of electricity production facilities, before six-month period starts.
• Finally, an additional possibility is established (that is compatible with the above request for extension of the final milestone) of suspending the calculation of the administrative milestones defined in article 1 of Royal Decree-Law 23/2020, of 23 June, which approves measures in the field of energy and other areas for economic reactivation, in the event that interim measures are adopted in an administrative or contentious-administrative appeal that suspend the effectiveness of the administrative authorisations granted to a project. This provision (which is also applicable to cases of presumptive suspension in the event of an administrative appeal under article 117.3 of Law 39/2015, of 1 October, on the Common Administrative Procedure of Public Administrations) requires the developer to provide evidence of the suspension to the network manager that granted the access and connection permit, and to the body competent for granting administrative authorisations – to do so, it must send them the notification from the body that adopted the administrative or judicial interim measure or, where appropriate, the certification of the presumed act if the suspension is a result of article 117.3 of Law 39/2015, of 1 October. The developer must notify those same parties of the lifting of the interim measure within three months of receiving notice thereof; otherwise, the access and connection permits will expire automatically. 

4. Self-consumption

Various measures have been adopted to promote self-consumption: 

• The distance permitted for association in self-consumption through the grid is extended to a maximum of five kilometres and is extended to all types of photovoltaic and wind generation installations (it was previously limited to two kilometres and was limited to rooftop photovoltaic installations or photovoltaic installations on industrial land).
• It allows the same consumer to simultaneously use individual self-consumption without surplus and self-consumption with surpluses by means of nearby and associated installations through the grid.
• The concept of self-consumption officer has been created, who represents the interests of consumers associated in collective self-consumption.
• The reserve of a 10% share of available capacity at the nodes reserved for generation tenders for self-consumption projects where the ratio between the contracted power in period P1 and the installed generation power is at least 0.5 has been re-established until 22 March 2028.

5. Electricity storage: flexible access permits

In addition to the measures already mentioned in the previous sections, the following measures are included in relation to electricity storage facilities:

• At transmission grid nodes which, due to their proximity to the water resource, may be critical for the connection of pumped hydro technology electricity production facilities, access capacity for generation and storage demand may be reserved exclusively for projects of this nature.
• The deadline for obtaining the administrative operating authorisation for hydraulic pumping facilities is extended to 12 years.
• Similarly, the regime of prevalence over urban planning provided for transmission facilities in the third additional provision of Law 13/2003, of 23 May, regulating the public works concession contract, is extended to hydraulic pumping facilities.
• At nodes reserved for access tenders for generation or access tenders for demand, it will also be possible to reserve access capacity for demand and generation, respectively, for storage at the same node so that it can be awarded at the same time (thus avoiding situations where a storage facility from obtaining access capacity for demand and not for generation, or vice versa, or them being awarded at different times).
• Likewise, when a node has been reserved solely for demand tenders, the associated demand capacity for storage can be released, depending on the requests submitted, for award in chronological order.
• It is established that access and connection permits for storage facilities will be flexible from a demand-side perspective. The holders of pre-existing firm access permits are given a period of three months to adapt them to the flexible permit modality as soon as the different flexible permit modalities established by the National Markets and Competition Commission (CNMC) come into effect. If the adjustment is not carried out, the storage facilities will be subject to payment of the tariffs and charges of the electricity system and the PRC.

6. Electricity planning

The LSE is amended to introduce various measures to streamline electricity planning: 

• The obligation has been introduced to initiate a new transmission grid development plan within three years of the approval of the last Transmission Grid Plan.
• An obligation is introduced to modify specific aspects of the current Transmission Grid Plan every two years, and new eligibility criteria are established (supply of strategic investment projects and actions in the transmission grid that are necessary to meet the needs of the distribution grid that the Spanish government establishes as a priority).
• The government receives a mandate to approve a royal decree that regulates the criteria for establishing the uses of transmission substation positions, and these may establish that certain positions may only be used temporarily for the connection of certain demand that is considered to be a priority.
• New requirements and limitations are introduced in the planning mechanism for new demand positions in article 4 bis LSE, which was introduced by Law 9/2015, of 3 December, on Sustainable Mobility. Specifically: i) it is established that applications must be accompanied by the payment of 75% of the investment of the requested position (which will be returned if the position is not created, is created for another use or if it is not allocated to the applicant). (ii) this mechanism is restricted to applications for consumption that is industrial, residential or that is declared strategic.

7. Suspension of the IVPEE until 30 June 2026

RDL 7/2026 suspends the application of the tax on the value of electricity production (IVPEE) until 30 June 2026. The suspension is applied by reducing the taxable base of the first quarter by 10% and the taxable base of the second quarter by 100%.

As the IVPEE was taken into account in the calculation of the remuneration parameters for facilities entitled to the specific remuneration, the CNMC will, as on previous occasions, carry out the necessary settlement to adapt their remuneration by subtracting the IVPEE that these facilities will cease to pay.

8. Regulatory mandates in relation to data centres

Apart from the impact that some of the above measures (primarily regarding the demand-side access and connection regime) may have on data centre projects, RDL 7/2026 includes a mandate for the Spanish government to enact a royal decree to regulate the energy sustainability, environmental, resilience and digital sovereignty requirements applicable to data processing centres connected to the electricity transmission and distribution grids.

These requirements (which will apply to all data centres connected from 22 March 2026) may include, among others, additionality and hourly correlation criterial related to the consumption of electricity from renewable energy sources, energy efficiency, sustainability in the use of water, economic and social benefits, as well as those that make it possible to demonstrate their contribution to the resilience and digital sovereignty of the Spanish or European economy. And it is expressly established that failure to comply with these requirements may result in the loss of grid access and connection permits or lead to penalties.

The Spanish government was already processing a draft royal decree with content in this regard. The main legal impact of this provision of RDL 7/2026 is that it clarifies the issues of legality raised regarding the possible incompatibility of the royal decree with article 33 LSE (both in terms of competence and substance, by introducing the possibility of denying access permits for reasons other than the lack of capacity).

9. Regulatory mandates in relation to biomethane

The Spanish government is given a mandate to issue a royal decree to set annual targets for the penetration of biomethane for purposes other than transport, defining the obligated parties, the calculation methodology and the mechanisms of accreditation for ensuring compliance. It also adapts the disciplinary regime under the Spanish Hydrocarbons Law 34/1998, of 7 October, to provide for potential non-compliance.

On the other hand, the Ministry for Ecological Transition and the Demographic Challenge will implement a seal of social, territorial and environmental excellence that may be required of biomethane production plants that enter into operation after the introduction of this target and so that they can contribute to its fulfilment (a requirement that may be extended to imported biomethane).

10. Modifications to the National Scheme of Energy Efficiency Obligations: inclusion of certain consumers as obligors and abandonment of the n-2 rule

Certain modifications are made to the National Scheme of Energy Efficiency Obligations with effect from 1 January 2027.

Specifically, new obligated parties are defined as: (i) direct consumers in the electricity and gas market; (ii) retail distributors of petroleum products or liquefied petroleum gases (LPG) insofar as this is not supplied by wholesale operators or other retail distributors; and (iii) consumers of petroleum products or LPG, insofar as this is not supplied by wholesale operators or retail distributors.

At the same time, changes are made to the methodology for calculating the obligations (which are no longer referenced to sales in year n-2, but are now calculated using an ex-ante methodology, for which purpose an identical final energy savings rate is set for year "n" for all obligated parties, which they must apply to their actual sales or final energy consumption data for that year) and to the disciplinary regime.

Footnotes

1 If the grid access permit is updated to reduce power, the value of the PRC will be adjusted thereafter, but the higher amounts paid up to that point will not be refunded.

2 Specifically, these values are: 0.4 for segment 6.1 TD (up to 30 kV); 0.6 for segment 6.2 TD (between 30 and 72.5 kV); 1 for segment 6.3 TD (between 72.5 and 145 kV) and 1.5 for segment 6.4 TD (above 145 kV). In addition, these values are increased, respectively, by 0.2, 0.3, 0.5 and 0.75 per six-month period that elapses since the grid access permit was obtained or, where applicable, since the entry into force of RDL 7/2026 (in the case of permits granted before the date on which it enters into force).

3 For example, if the power ultimately reflected in the grid access contract is 60% of the power granted in the permit, only 60% of the PRC payments will be discounted in the first year, and 48% in the second and subsequent years.

4 This modulation introduces a clear incentive to commission the power consumption facility as soon as possible and establishes, in any case, an irrecoverable structural cost from the second year of payment of the PRC.

5 Royal Decree 997/2025, of 5 November, approving urgent measures to reinforce the electricity system, which already contemplated this ground for expiry, entered into force on 7 November 2025. Doubts surrounding the lawfulness of the inclusion of a new ground for expiry in a regulatory provision, which lacked express inclusion in a law, have been resolved with the approval of RDL 7/2026.

6 The CNMC had understood that these permits were not subject to expiry, as expressed in its Resolution of 10 July 2025 (CNS/DE/150/25).

7 Strategic Investment Projects are defined as all business initiatives or public-private partnerships for investment or reinvestment projects in Spain aimed at improving technological, scientific or productive capacities and in which there are reasons of public, social and/or economic interest for the country as a whole. A Strategic Investment Committee is set up, which is responsible for proposing that a project be declared a Strategic Investment Project, which must be approved by the Government's Delegated Commission for Economic Affairs. Definition of the criteria that will need to be met to declare a project as a Strategic Investment Project is deferred to regulatory development by Royal Decree.

8 RDL 7/2026 also amends article 39.3 LSE to specify that, for these purposes, hybrid or isolated storage facilities will not be considered consumers, even if they take energy from the grid.

9 See 7.

10 Article 20 provides that a voluntary standard of social and territorial excellence will be established for projects for electricity generation facilities from renewable sources, storage facilities and electricity transmission and distribution facilities, in accordance with criteria of citizen participation, local development, promotion of energy communities and self-consumption and environmental excellence, among others. This standard may confer advantages in grid access and connection, as well as in tenders for granting regulated remuneration.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.