The publication of Royal Decree-Law 7/2025 has been widely welcomed by the energy sector. The package of measures not only addresses immediate challenges stemming from the April grid blackout, but also lays out a new operational framework that many stakeholders see as both necessary and long overdue.
The regulation has been praised for its legal precision and its comprehensive approach to resolving bottlenecks in permitting, planning, and operation.
1.Storage: the flagship of this Royal Decree-Law
Storage takes centre stage. Its designation as a public utility is recognised, which enables access to compulsory purchase and easement procedures. Its access is also enabled from the demand-side perspective, and preferential treatment in redispatch is established.
In addition, the installed capacity in hybridised projects is redefined: generation and storage are no longer added together. Instead, the capacity of the shared inverter becomes the reference.
Pablo Reinoso Lozano, an energy law specialist, emphasises: “there is reassurance in knowing that the capacity is not considered to have increased merely because a plant has been hybridised with storage”.
He explains that the previous interpretation could lead to the requirement of reprocessing the prior administrative authorisation, with the associated delays and regulatory risks.
Now, by taking the inverter’s capacity as the reference, this duplication of procedures is avoided and projects gain greater legal certainty.
The decree also enables storage to act as an active market participant on equal footing with other agents. This allows it to engage in balancing markets and ancillary services, broadening its role beyond merely backing up intermittent generation.
Another innovation is the possibility of applying for grid access and connection permits both as a generator and as a consumer. This dual role facilitates greater integration, especially for stand-alone projects operating with time arbitrage or ancillary services.
In an interview with Strategic Energy Europe, Raúl García Posada, director of ASEALEN, notes: “for hybridised projects with generation, most doubts are now resolved”, though he adds that “grid access for storage is still missing, along with tenders granting both generation and demand capacity, and coordinated permitting of water concessions, grid access and administrative authorisation for pumped hydro”.
2.Operation of large-scale power plants
The operational responsibility of plants using shared evacuation infrastructure is now clarified. From now on, each plant using a shared line must respond directly to the system operator, regardless of whether a separate entity formally holds the title.
“Until now, the responsible party was the company owning the evacuation line (which could be a special purpose vehicle or private company independent from the generators). From RDL 7/2025 onwards, the generation modules using that line to evacuate electricity may also be held directly responsible,” explains Reinoso in dialogue with Strategic Energy Europe.
The decree also reinforces the role of large plants in ensuring grid stability. The system operator must develop a new operational procedure to ensure voltage control under both normal and exceptional conditions.
Red Eléctrica is authorised to require high-voltage connected installations—including solar plants—to provide reactive power regulation capacity, even through their inverters, in order to improve grid stability and avoid oscillations.
According to UNEF, this measure marks a significant step forward as solar plants will now actively contribute to system stability through voltage and reactive power regulation.
In its statement, the association welcomes the promotion of ancillary service provision and the recognition of non-synchronous technologies in the technical operation of the grid. This regulatory shift opens the door for renewables to take on roles previously reserved for conventional generation.
The obligation to establish binding agreements between owners of shared infrastructure is also introduced. In the absence of such agreements, a proportional rule based on each plant’s access capacity will apply, eliminating the legal and operational ambiguities that previously required private negotiations between developers.
The decree includes a 25% reduction in the minimum required operating hours for plants under the specific remuneration regime in 2025. This addresses the scenario of low or zero electricity market prices and seeks to safeguard the financial viability of these installations.
It also introduces penalties for installations that fail to maintain their power factor within the required margins or ignore instructions from the system operator. This amends Article 20 of RDL 413/2014 and reinforces the technical accountability of high-voltage connected facilities.
3.Permitting for renewable energy generation plants
Multiple measures are introduced to streamline administrative procedures, aiming to eliminate bottlenecks and enhance legal certainty for developers:
- Repowering projects with power increases under 25% may use simplified procedures, avoiding the need for a new prior administrative authorisation.
- Exceptional extensions to the fifth milestone deadline are provided: up to 8 years for conventional projects, 12 years for pumped hydro, and 9 years for offshore wind. These recognise the technical and permitting complexity of strategic developments.
- The fifth milestone will now be calculated from the date of provisional commissioning authorisation, not the definitive one, giving developers extra time to complete formalities.
- The suspension of deadlines due to court-ordered interim measures affecting project progress is now formally regulated, whereas it was previously applied informally.
- Regional governments may assess whether milestone compliance remains valid if delays are due to unforeseeable causes beyond the developer’s control.
- For projects adding storage without altering the authorised environmental footprint, an accelerated modification procedure is available, halving the permitting time.
“This has a significant legal effect: it is now clearly established which authorisation counts for milestones, removing previous ambiguity”, says Reinoso.
These changes directly address longstanding demands from the sector, especially from the wind industry, which has long sought greater legal certainty, administrative agility and clear rules for exceptional circumstances.
Specific issues like the lack of formal recognition for provisional authorisation or delays caused by court cases without a clear suspension mechanism were frequent hurdles.
Repowering projects also faced roadblocks due to the absence of differentiated procedures. This new legal framework aims to remove such structural barriers.
4.Flexibility, electro-intensive demand and self-consumption
The decree sets a structural shift towards a more flexible system with greater consumer participation. It introduces the independent aggregator as a new market agent able to access balancing and ancillary services markets, without needing to represent a specific production or consumption unit. This figure will facilitate aggregated flexibility contributions—such as home storage, demand response or self-consumption—to participate in the wholesale and ancillary services markets.
The collective self-consumption manager is also created, a new intermediary who will facilitate multi-user self-consumption schemes for consumers connected to the same low-voltage network. This is supported by extending the collective self-consumption radius from 2 to 5 kilometres, provided the same transformer station is used.
These measures aim to maximise demand-side participation in the electricity system—a key step towards a more distributed, efficient, and resilient model. According to Red Eléctrica, demand-side participation in balancing services currently accounts for less than 1% in Spain, compared to over 10% in countries like Germany. The new framework seeks to bridge this gap.
Roger Pasola Dolader, adviser to the Secretary of State for Energy, emphasises that the goal is to foster “greater participation in the electricity system, leading to lower electricity costs and maximising social welfare.”
Additionally, tax ordinances are modified to promote technologies such as aerothermal heating, and IBI, ICIO, and IAE tax exemptions are introduced for certain efficient electric equipment—aiming to accelerate residential thermal electrification and meet decarbonisation targets.
The 80% electricity tariff rebate is reintroduced, retroactively from January 2025, replicating the mechanism under Royal Decree 1106/2020.
This measure restores support to key industries such as steel, chemicals, and pulp and paper, which collectively account for more than 60% of high-intensity industrial electricity consumption in Spain.
The decree also enables electro-intensive installations to access new demand-side flexibility mechanisms and alternative system participation routes, including bilateral agreements and preferential access to time-based tariffs.
The creation of electrified industrial clusters is also promoted, fostering economies of scale in grid infrastructure and reducing the cost of large-scale electrification.
These measures aim to safeguard the competitiveness of Spain’s electro-intensive industry, which has been hit hard by higher energy costs compared to other European nations.
5.System operator and grids
Royal Decree-Law 7/2025 redefines the role of the system operator and grid planning, adopting a more dynamic approach linked to industrial development.
The system operator must now deliver a new operational procedure for voltage control under both normal and exceptional conditions, ensuring grid stability amid the rising share of non-synchronous renewables.
Transport network planning becomes more dynamic: the overall plan will be reviewed every three years, with Point Aspect Modifications (MAPs) approved every two years. These more frequent updates will better reflect real needs in terms of growth, electrification, and access.
One key change is the establishment of a five-year expiry period for unused access and connection rights. This aims to release blocked capacity and enable new industrial or economic activities to connect. According to aelēc and Red Eléctrica data, latent demand may exceed 9,000 MW in industrial sectors whose connection is currently hindered by grid congestion and unused reserved capacity. This situation hampers new investment and blocks Spain’s electrical reindustrialisation.
The decree also requires distribution companies to shorten connection lead times for new demand and includes provisions to optimise the use of currently underutilised networks.
Pasola Dolader underlines that this flexibility will enable new industrial activities to connect and make better use of idle networks. These reforms aim to boost electrified industrial hubs, enhance network efficiency, and promote more competitive use of the power system.
6.New operational framework to accelerate the energy transition
Royal Decree-Law 7/2025 represents a far-reaching legislative intervention that redefines the technical and legal underpinnings of Spain’s electricity system.
It also mandates that the CNMC develop an extraordinary inspection plan focused on the readiness of all system agents, including combined cycle plants and technologies with black-start capability. This oversight seeks to ensure that key actors can respond effectively to zero-voltage or exceptional events.
Institutional, business, and technical stakeholders agree that this is a long-awaited response to deep-seated obstacles that have delayed project execution and the efficient integration of renewables.
The regulation brings clarity where there was once ambiguity, speeds up processes once plagued by bottlenecks, and lays a firmer foundation for renewable and industrial deployment.
As Pablo Reinoso Lozano concludes, “it provides regulatory predictability that did not exist before and reduces the margin for administrative discretion.”
These shared views underscore a broad sectoral consensus: RDL 7/2025 marks an operational and regulatory turning point towards a more resilient, efficient model aligned with Spain’s climate goals.
BOE-A-2025-12857
