Royal Decree-Law 7/2025, of 24 June, approving urgent measures to reinforce the electricity system

Royal Decree-Law 7/2025, of 24 June, approving urgent measures to reinforce the electricity system (the "RDl 7/2025"), was enacted in response to the electricity crisis that occurred on 28 April 2025 in the peninsular electricity system. This incident, which gave rise to a blackout of the mainland territories, highlighted the urgent need to reinforce the resilience and stability of the Spanish electricity system.

The Royal Decree-Law establishes a series of urgent measures aimed at improving supervision, verification and data transparency in the electricity sector, as well as increasing the storage capacity and flexibility of the system. It also introduces mechanisms to guarantee security of supply and promotes initiatives for industrial electrification, electric mobility and climate control.

The measures adopted in RDl 7/2025 seek not only to correct the weaknesses identified during the crisis, but also to anticipate and prevent future incidents, ensuring a robust and efficient electricity supply. The implementation of these measures is essential to guarantee the continuity of electricity supply, reduce energy costs and promote the integration of renewable energies into the system.

The main measures included in RDl 7/2025 are as follows:

I. Measures aimed at the resilience of the electricity system

• Supervision and verification: the Royal Decree-Law includes mandates for the National Markets and Competition Commission to draw up reports and inspection plans on voltage control and service restoration, and for the system operator (Red Eléctrica de España) to analyse and propose regulatory modifications in technical and operational aspects.
• Shared evacuation infrastructures: joint and several liability is established for the titleholders of generation facilities that use shared evacuation infrastructures in relation to events, requests, acts or omissions that occur or are motivated in said shared infrastructures.
• Measures are included for the reinforcement of voltage control and damping in the event of oscillations.

II.- Storage and flexibility

• Storage facilities that inject energy into the transmission or distribution grid are declared to be of public utility.
• The Government is entrusted with the modification of the definition of the installed capacity of generation and storage facilities,  determining a set of rules to determine this capacity until said modification is approved.
• RDl 7/2025 modifies the order of priority for dispatch in order not to penalise storage. The new order is as follows:

1. Renewable installations, including those hybridised with storage that do not consume from the grid or, in the opposite case, when the storage has an installed capacity that does not exceed that of the generation installation.
2. High efficiency cogeneration with or without storage.
3. Other technologies

• Progress is made in defining the functions, rights and obligations of demand aggregators.
• The Royal Decree-Law creates the figure of the self-consumption manager, representing the consumers associated with self-consumption in order to reduce the administrative burden for consumers of this type of electricity consumption.

III.- Electrification

• Electricity planning: the obligation to approve specific modifications to the transmission grid planning at least every two years is established.
• The regulation provides for a specific mechanism to include electricity demand positions in transmission planning.
• The Royal Decree-Law extends the possibility of expiry of access and connection permits for demand to facilities connected at voltages equal to or higher than 1 kV (until now this was only applicable in the case of voltages equal to or higher than 36 kV).
• Repowering of generation facilities: RDl 7/2025 halves the processing periods for repowering facilities and limits the scope of the environmental impact assessment to the differential impact arising from the extension.

IV.- Measures in relation to renewable installations

• RDl 7/2025 imposes on generation facilities the need to obtain a provisional operational authorization for testing prior to obtaining the final operational authorisation.
• RDl 7/2025 includes several provisions to make the administrative milestone mechanism established in Royal Decree-Law 23/2020 more flexible. Thus:

(a) The fifth milestone is linked to obtaining the provisional operational authorisation.

(b) Facilities that obtained access and connection permits between 27 December 2013 and 31 December 2017 are allowed to request an extension of the deadline for meeting the fifth administrative milestone of up to 3 additional years (i.e., until 25 June 2028 at the latest), extending in any case the deadline for the expiry of the milestone until 25 September 2025.

(c) The suspension of the effectiveness of the required authorizations through administrative or judicial means will result in the suspension of the calculation of the deadline for meeting the milestones.

(d) The deadline for meeting the fifth milestone for pumped hydro projects is increased to 12 years.

(e) Operators of installations that have obtained an extension of the deadline for meeting the milestone under article 28 of Royal Decree-Law 8/2023 may request an advance or delay of the date granted. 

If you would like to know more about this regulation or other energy issues, please do not hesitate to contact one of our experts listed below or your usual contact at Osborne Clarke.