Spain updates its energy savings targets

Article 8 of Directive (EU) 2023/1791 of the European Parliament and of the Council, of 13 September 2023, on energy efficiency, establishes that each Member State must achieve a cumulative amount of final energy savings in the period 2021-2030, which in the case of Spain amounts to 53,593 ktoe (kilo tons equivalent oil). In the case of Spain, a combination of the two systems permitted by the Directive has been chosen to achieve this target: the system of energy efficiency obligations and the adoption of alternative action measures.

In Spain, Law 18/2014, of 15 October, approving urgent measures for growth, competitiveness and efficiency, establishes for this purpose a National Energy Efficiency Obligations System under which certain obligated parties (gas and electricity marketing companies, wholesale petroleum product operators and wholesale liquefied petroleum gas operators) are assigned an annual energy savings quota. Law 18/2014 also creates the National Energy Efficiency Fund and, alternatively, the Energy Saving Certificates System (CAEs) with which the aforementioned annual energy saving quota can be met.

Each year, a ministerial order sets the national annual savings target and the savings obligations required of obligated parties. Thus, on 26 February, Order TED/197/2025 was published, which, in compliance with article 70.1 of Law 18/2014, establishes for the current year:

1. An energy savings target for the National Energy Efficiency Obligations Scheme, increasing from 375 ktoe or 4,361.25 GWh in 2024 to 500 ktoe or 5,815 GWh by 2025.

2. The savings obligations corresponding to each of the obligated parties, the calculation of which is based on sales in 2023, multiplied by the average annual savings target between 2015 and 2020, divided by the average sales volume of all obligated parties considered in the corresponding ministerial orders establishing the obligations to contribute to the National Energy Efficiency Fund in that period, multiplied by the coefficient C (C= 1.959597).

   It should be remembered that, for the year 2025, obligated entities can compute up to 85% of their savings obligations through the contribution of CAEs, or in other words, they will only have to comply with a minimum percentage of 15% by means of a financial contribution to the National Energy Efficiency Fund. This is a significant difference compared to the previous year, when the minimum percentage of financial contribution to the Fund was 35%.

3. A financial equivalence for the calculation of financial contributions to the National Energy Efficiency Fund of 2.20 million euros per ktoe saved, equivalent to 189,165.95 euros per GWh saved, based on the estimated average cost of mobilising the necessary investments in all sectors of action to achieve the annual savings target. In the previous year, the financial equivalence was 2.121 million euros per ktoe saved, equivalent to 182,373.17 euros per GWh saved.

Therefore, the above data shows the consolidation of the upward trend in the savings set in Spain. In fact, the Order TED/197/2025 itself makes an indicative forecast for the years 2026 and 2027 in which it anticipates a greater increase in the parameters examined, with final energy savings targets of 810 ktoe and 900 ktoe, respectively, as well as financial equivalence targets of 2.31 M€/ktoe and 2.43 M€/ktoe, respectively. It also stipulates that the obligated parties may meet their savings obligation by up to 90% through the contribution of CAEs, which represents an even greater reduction of the mandatory financial percentage through financial contribution.

Should you wish to know more about Order TED/197/2025 or any other energy issues, please do not hesitate to contact one of our experts listed below or your usual contact at Osborne Clarke.