How to become a CAE delegated subject: requirements and process

What is a delegated subject?

A delegated subject is a company or natural person who, with the agreement of an obligated party, carries out energy saving actions and receives the resulting CAE. The delegated subject acts as a technical intermediary between the obligated party (which holds the legal obligation) and the end user (who performs the efficiency improvement).

Legal requirements to be a delegated subject

According to article 11 of the Real Decreto 36/2023, to be accredited as a delegated subject you must meet the following requirements:

• Be a legal entity incorporated in Spain or domiciled in an EU Member State
• Have sufficient technical capacity (demonstrate experience in the energy sector)
• Not be subject to any of the prohibitions on contracting with the public sector
• Sign a delegation agreement with at least one obligated party

The accreditation process with the MITECO

1. Preparation of the documentation: deed of incorporation, CIF, technical capacity report, delegation agreement with the obligated party
2. Electronic application: through the MITECO Electronic Office (General Registry of Delegated Subjects)
3. Review by the MITECO: the ministry verifies the completeness and validity of the documentation (usual time frame: 2 to 3 months)
4. Accreditation: favourable resolution and inclusion in the Registry of Delegated Subjects published on the MITECO website
5. Delegated Subject accreditation number: unique identifier for all CAE operations

Technical capacity required

The technical capacity report must demonstrate:

• Staff holding a technical degree in energy, industrial or similar engineering
• Experience in energy efficiency audits or projects
• Knowledge of the standardised datasheets and the CAE regulations
• Internal quality control procedures for files

The delegation agreement with the obligated party

The delegation agreement is a contract between the delegated subject and the obligated party that establishes:

• The volume of CAE that the delegated subject undertakes to provide
• The purchase price of the CAE by the obligated party (2025 range: 50 to 150 EUR/MWh)
• The standardised datasheets enabled in the agreement
• The delivery times and verification conditions

Operational management as a delegated subject

Once accredited, the delegated subject must efficiently manage its portfolio of CAE files. The main operational challenges are:

• Correctly calculating the energy saving of each action according to the applicable datasheet
• Gathering and organising the supporting documentation (D1 to D5)
• Coordinating with ENAC verifiers within the obligated party's deadlines
• Keeping a record of the CAE issued and their traceability

Tools such as CertificAhorro automate these processes, reducing the management time per file from hours to minutes.