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CAE Market · Regulatory compliance
Regulatory contact and freezing procedure
This page is intended for the competent authorities (MITECO, CNMC, AEPD, courts, State law-enforcement bodies) that need to interact with CertificAhorro within the scope of their powers over the secondary market for Certificados de Ahorro Energético.
For the full technical description of the controls applied to the market (KYC, order book integrity, eIDAS signature, SEPA flow and immutable audit), please see /mercado-cae/seguridad.
Single point of contact
Email address
legal@certificahorro.esInbox monitored during business hours (Monday to Friday, 09:00 to 18:00 CET). Automatic acknowledgement of receipt within 24 business hours.
Compliance officer
CAE Market Compliance Officer
Legal operator: HM Capital SARL (publisher of CertificAhorro). Representation office in Spain available on request at legal@certificahorro.es.
Handling SLA
- Urgent precautionary measures: executed within 24 business hours (listing freeze, account suspension).
- Standard information requests: documented response within 10 business days.
- LOPDGDD / GDPR requests (AEPD): handled by our DPO, maximum 30-day deadline.
Procedure to order the freezing of a listing
CertificAhorro has a technical mechanism for freezing secondary market listings. Once frozen, a listing becomes invisible in the order book and blocks any new transaction on the affected CAE. Transactions in progress are not interrupted automatically (they require a specific instruction).
- Issue the official notice or decision stating the issuing body, the file reference, the legal basis (for example Art. 22 RD 36/2023, Art. 5 Ley 18/2014 CNMC, Art. 58 LOPDGDD, court order) and the identification of the affected listing. The minimum identification requires:
- the CAE registration number (provided by the SIICAE MITECO), or
- the file code + NIF of the holding Sujeto Delegado.
- Send the notice to legal@certificahorro.es. For certified communications, use the electronic system provided by your body (DEHu, NOTIFICA, LexNET), notifying the address listed as the official point of contact.
- Acknowledgement of receipt: issued within 24 business hours with an internal file number (CA-REG-YYYY-NNNNN).
- Execution of the measure: the compliance team freezes the listing within a maximum of 24 business hours of receiving the notice. The action is recorded in our audit journal (AdminAuditLog) with evidential value.
- Notification to the affected Sujeto Delegado: they are informed of the freeze, the issuing regulator and the notice reference, in accordance with the right to information under Art. 3 Ley 39/2015. The content of the notice itself is only shared if the regulator authorises it.
- Lifting of the measure: this requires a second official communication from the same body (closing notice, lifting decision, court order) or a decision from a higher authority.
Identified competent authorities
Non-exhaustive list of the authorities with recognised jurisdiction over the CAE market. CertificAhorro also responds to any other public body that demonstrates legitimate jurisdiction.
MITECO
Ministerio para la Transición Ecológica y el Reto Demográfico
Legal basis
RD 36/2023 · Orden TED/815/2023 · Orden TED/845/2023
Scope
Supervision of the CAE System, management of the SIICAE, favourable Resolución prior to the registration of each CAE.
Contact
bzn-sgenerg@miteco.es
CNMC
Comisión Nacional de los Mercados y la Competencia
Legal basis
Ley 3/2013 · Ley 24/2013 del Sector Electrico
Scope
Supervision of energy markets, defence of competition, control of dominant-position abuse and collusive agreements between SO/SD.
Contact
reclamaciones.energía@cnmc.es
AEPD
Agencia Española de Protección de Datos
Legal basis
RGPD · LOPDGDD (Ley Organica 3/2018)
Scope
Processing of personal data of operators and beneficiaries, ARCO rights, security breaches.
Contact
www.aepd.es · electronic office
Courts and Tribunals
Ordinary and administrative jurisdiction
Legal basis
LEC · LJCA · Código Penal (fraude, falsedad documental)
Scope
Civil and criminal precautionary measures, attachments, preliminary proceedings, production of documents.
Contact
LexNET · certified court notice
Retention and evidential value
All freezing, lifting and secondary market file access actions are recorded on an insertion-only basis in our administrative audit journal (AdminAuditLog), with timestamp, IP, user-agent and responsible user. The journal is retained for at least 10 years in accordance with Art. L102 B LPF and Art. 66 LGT (Spain).
Notices received and decisions issued are archived in HM Capital SARL's internal legal file and may be made available to the requesting authority upon documented request.
Direct contact for authorities
Guaranteed response within 24 business hours. Always include the file reference and legal basis.