What is the energy saving obligation?
Real Decreto 36/2023 establishes a system of final energy saving obligations that falls on the obligated parties, mainly energy retailers and distributors. Each year, these players must demonstrate that they have contributed to saving a given amount of final energy, measured in GWh.
To meet this obligation, obligated parties have three options: carry out energy efficiency actions directly, delegate to delegated subjects who execute the actions and generate the CAE, or acquire CAE on the market.
The 2025 obligation: 4.942 GWh
For the year 2025, the total saving obligation set by the CNMC amounts to 4.942 GWh of final energy. This figure is allocated among the various obligated parties in proportion to their share of the energy market.
To put this figure into perspective:
- 4.942 GWh is equivalent to 4.942.000 MWh of final energy saving
- At a market price of 127,5 EUR/MWh, this represents a potential market of ~630 million EUR
- If each action generates an average of 50 MWh of CAE, around ~99.000 actions are needed to cover the obligation
Evolution of the obligation 2023-2026
RD 36/2023 provides for a progressive increase in the annual obligation:
- 2023: first obligation, initial volume. Market in start-up phase
- 2024: significant increase. The market structures itself as new delegated subjects join
- 2025: 4.942 GWh. Market consolidation and pressure on supply
- 2026: likely above 5.000 GWh, following the upward path set by the European Energy Efficiency Directive
The sustained increase in the obligation is a clear signal that the CAE market is going to grow, which offers significant opportunities for delegated subjects who position themselves now.
Who are the obligated parties?
The obligated parties are the companies subject to the saving obligation. They fall into:
- Electricity retailers: the main retailers in the Spanish market (Iberdrola, Endesa, Naturgy, EDP, Repsol, TotalEnergies, etc.)
- Gas retailers: companies that sell natural gas to the final consumer
- Fuel distributors: wholesale operators of fuels (petrol, diesel)
- LPG distributors: operators of liquefied petroleum gases
The individual obligation of each obligated party is determined according to its share of the energy market, calculated by the CNMC.
The role of delegated subjects
Delegated subjects are the operational link between the regulatory obligation of obligated parties and the concrete energy efficiency actions. The delegated subject identifies saving opportunities, executes or coordinates the actions, builds the files and obtains the CAE that it then transfers to the obligated party.
With 66 delegated subjects accredited in Spain (as of April 2026) to cover an obligation of nearly 5.000 GWh, there is a clear imbalance between demand and the capacity to produce CAE. This results in:
- Favourable purchase prices for delegated subjects (50 to 150 EUR/MWh)
- High demand for files from obligated parties
- A growth opportunity for new delegated subjects who get accredited
Sectors with the greatest CAE generation potential
Not all sectors generate the same volume of CAE. The most productive in 2025 are:
Industrial sector
The industrial sector offers the actions with the highest unit saving: variable speed drives (IND240), industrial heat pumps (IND040), high-efficiency compressors (IND090) and LED lighting (IND050). Industrial buildings with obsolete equipment represent enormous potential.
Tertiary sector
Hotels, offices and shopping centres are ideal candidates for heat pumps (TER040), LED lighting (TER030) and building management systems (TER050). The volume of tertiary buildings in Spain guarantees a steady flow of projects.
Transport sector
Fleet telematics (TRA020) offers significant savings for transport and logistics companies, although the number of available datasheets is more limited.
Opportunities for 2026
The expected increase in the obligation for 2026 will amplify the current opportunities. Delegated subjects who build a diversified portfolio of projects now and standardise their management processes will be in the best position to capture the growing demand from obligated parties.
Tools such as CertificAhorro allow delegated subjects to scale their file production capacity without proportionally multiplying their human resources, which is key in a market where processing speed and file quality determine the price obtained.