Dr. Maria Bertrán Girón (University Loyola, Andalucia & Dublin City University)
Energy efficiency is often associated with simplistic actions, such as changing lightbulbs. However, this perception is far from reality. Energy efficiency is, in fact, about reducing energy consumption while maintaining the same level of comfort, through a range of measures aimed at optimizing energy use. In this sense, it refers to the capacity to achieve the best results in any activity using the least amount of energy possible. This not only helps reduce overall energy consumption but also mitigates the environmental impacts associated with it. Spain is strongly committed to energy efficiency, as seen in its implementation of the European Union Directive on energy efficiency (EED) [1].
In the context of promoting this kind of initiative, and following the well‑established French model, Spain launched its own Energy Savings Certificates (CAE) system in 2023. Now in its third year, the scheme provides benefits to all parties involved: the state gains visibility into the measures being implemented and the verifiable savings they produce; individuals can monetise their savings and receive economic compensation; and the energy‑efficiency sector benefits from renewed dynamism and investment.
How does it work?
The 2012 EU Directive on energy efficiency establishes a common framework and obliges Member States to implement policies aimed at achieving energy savings targets; however, each Member State may choose different mechanisms to fulfil such targets. Among these mechanisms, many Member States have opted for Energy Efficiency Obligation Schemes (EEOS) directed at specific operators, such as energy suppliers.
This is the case in Spain, which has established the so-called National Energy Efficiency Obligations Scheme (SNOEE), through which it commits to achieving annual energy savings. This obligation has increased in recent years due to the aforementioned EU Directive. For instance, in 2025 the target has been set at 2,20M€/ ktep—or 189.165,95 GWh—of final energy savings. To help meet this target, the National Energy Efficiency Fund (FNEE) was established, into which obligated parties must make financial contributions to support energy‑efficiency projects. Before 2023, compliance was only possible through these monetary contributions. With the implementation of the new system, however, obligated parties can now alternatively submit certified energy savings instead of funds.
This illustrates that legally obligated entities can now, as of the last couple of years, choose to submit verified savings certificates in lieu of financial payments.
Who are the obligated entities?
The obligated entities include liquefied petroleum gas operators, petroleum product suppliers and electricity retailers. These actors must make annual contributions calculated on the basis of a variable known as the financial equivalence. For 2025, this equivalence has been set at €2.2 million/ktoe saved, or €189,165.95/GWh saved, as mentioned, in which 85% can be justified by these white certificates[2]. This means that any energy savings they can purchase below this threshold will be more cost‑effective. In addition, the state can register these savings, and individuals or businesses that generate them can obtain financial compensation to fund their energy‑efficiency improvements.
What exactly are these certificates?
The certificates, (also known as “White Certificates”) are instruments that certify energy‑efficiency actions undertaken by individuals or legal entities. These actions may fall into one of two categories: (1) standard measures listed in an official catalogue that covers four sectors—tertiary, residential, industrial and transport—or (2) singular projects that must be submitted individually to the Ministry for validation. Both types of actions are certified using the same equivalence: 1 CAE = 1 kWh saved.
Once actions are completed and savings achieved, they can be sold—either directly or via intermediaries or delegated entities—to the obligated parties. From the date the regulation entered into force, the owners of these savings have three years to sell them in what is referred to as the primary market. In this market, third parties may acquire the savings and eventually connect with obligated parties for resale. Once a particular operator (whether obligated or delegated) accumulates a sufficient volume of savings, they request verification, and authorised entities issue the corresponding certificates, a process supervised by regional governments and accredited verifiers. These certificates can then enter a secondary market, where obligated parties may either settle directly with the national fund or continue trading via delegated agents.
How is the relationship established between the owner of the savings and the obligated entity or intermediary?
This relationship is formalized either through a CAE agreement or a private contract to transfer savings, depending on whether the transaction is handled by a delegated entity, an obligated party or an intermediary. The approach can be summarized as follows:
What types of actions generate certifiable savings?
Certifiable savings may be generated by either standard or singular actions. The catalogue of standard measures is organised by economic sector and includes technical datasheets specifying the parameters required to certify energy savings, as established in Order TED/845/2023 of 18 July [3]. The current catalogue (as of may 2025) includes 114 datasheets covering replicable actions across the agricultural, industrial, tertiary, residential and transport sectors. Examples include thermal‑envelope retrofits, installation of solar‑thermal systems, building‑automation systems and the purchase of high‑efficiency household appliances, among others.
In addition, singular actions can be submitted—more complex projects that combine various measures into a single proposal. Although this process is longer, it enables more significant savings. One notable example is the Royal Theatre in Madrid, which recently used this system to help finance its building renovation, drawing substantial media attention [4].
Is this system effective as a financing mechanism?
The system certainly appears to be effective. First, it gives obligated parties flexibility and cost savings, since they no longer need to make direct monetary contributions but can instead purchase CAEs in a regulated market with a yearly price cap. For the state, it facilitates the certification of savings that would otherwise go unrecorded and helps meet EU commitments. For end‑users, it offers a new opportunity to benefit financially from their energy‑saving efforts—sometimes in addition to receiving government subsidies. For instance, by replacing a window, consumers can reduce heating costs, receive a subsidy and also generate a certificate to recover part of their investment.
This is clearly an innovative mechanism with the potential to invigorate the sector and strengthen Spain’s commitment to energy efficiency. That said, a few key questions arise. Firstly, regarding implementation: the system is currently in use and has driven significant development in the energy‑efficiency market. While early assessments are positive, further analysis of 2024 contributions and future trends is needed.
Secondly, fiscal incentives should be promoted to enhance the attractiveness of the system. The success of CAEs will largely depend on their economic value. If the compensation for an CAE is too low, the agreements and contracts between users and intermediaries may not be worthwhile, depending on transaction costs and expected benefits.
Lastly, we must consider whether the system will extend to small‑scale actions. Large enterprises and major projects have already integrated CAEs effectively. But what about smaller interventions, such as replacing appliances or windows in a modest home? How efficiently is the market functioning between intermediaries and obligated parties to ensure that individual savings are valued and absorbed?
In conclusion, we believe this is a highly promising system for financing energy‑saving actions and advancing the broader goal of energy efficiency. We hope it proves effective and that new fiscal measures will be introduced to further incentivise its use.
Dr. Maria Bertrán Girón, is an Associate Professor at University Loyola, Andalucia and a Visiting Researcher at the Dublin European Law Institute (DELI), Dublin City University. This research is within the framework of the Project ‘Energy Efficiency and Taxation. Study of Energy Savings Certificates (CAE) and Other Tax Measures’ (File 20240127) funded by the Institute of Fiscal Studies (IEF), Ministry of Finance, Spain.
References
- [1] Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on Energy Efficiency (OJ L 315, 14.11.2012, p. 1–56).
- [2] Order ED/197/2025, of 26 February
- [3] Order TED/845/2023 of 18 July, approving the catalogue of standardised energy‑efficiency measures (BOE No. 171, 19 July 2023).
- [4] Teatro Real, *Sustainability Report 2024* (Madrid: Teatro Real, 2024) (https://www.prtr.miteco.gob.es/es/proyectos/teatro-real.html)
