In the past seven days, two major regulatory reforms have been launched for public consultation in Spain. The National Commission on Markets and Competition (CNMC), Spain’s energy and competition regulator, is enabling new conditional access schemes for demand, while the Ministry for the Ecological Transition and the Demographic Challenge (MITECO) is raising technical requirements for grid connection.
The impact will extend across industry, energy storage and large electricity loads.
Spain has activated two reforms that redefine access to capacity in a context of high renewable energy penetration, accelerating industrial electrification and structural congestion at multiple nodes of the power grid.
The Comisión Nacional de los Mercados y la Competencia has opened a public consultation until 20 March 2026 on Resolution RDC/DE/003/25, which develops flexible access permits for demand.
In parallel, the Ministerio para la Transición Ecológica y el Reto Demográfico has promoted a Draft Royal Decree updating the minimum design, equipment, operational and safety requirements for installations connected to the grid.
The signal is structural: capacity will no longer depend exclusively on physical infrastructure reinforcement, but will instead be conditioned by the operational flexibility and technical robustness of consumers.
The CNMC defines flexible access capacity as capacity where supply is not guaranteed for all hours of the year. In practice, this means that the consumer accepts operational restrictions in exchange for obtaining power that, under traditional firm criteria, would be unfeasible due to congestion. The paradigm of guaranteed availability for 8,760 hours is abandoned, and a supply scheme conditioned on electrical behaviour is introduced.
To this end, four types of flexible access have been defined.
- Type 0, the most immediate to implement, operates through time patterns defined by the network operator (from 00:00 to 07:59 and from 11:00 to 17:59). These must guarantee a minimum expectation of 62.5% of annual consumption hours, and outside those intervals, no energy associated with the flexible capacity may be absorbed. Control through programmable logic controllers or intelligent relays is required, and the distribution company may disconnect the installation in case of non-compliance. This scheme enables power at congested nodes without physical expansion, transferring congestion management to the consumption profile.
- Type 1 introduces a mechanism linked to N-1 contingencies, allowing normal operation but with remote disconnection in the event of grid failures. The connection voltage exceeds 36 kV. In the event of disconnection, supply will be restored once network security criteria can be guaranteed.
- Type 2 applies to all demand installations, including storage operating in demand mode, connected directly to the distribution grid. The power associated with the flexible access capacity of the installation exceeds 1 MW. Each installation with a Type 2 flexible access permit must have the technical capabilities to receive instructions from the Distribution System Operator (DSO) when it detects non-compliance with network security criteria, and to execute the power reduction associated with its flexible access permit.
- Type 3 is aimed at consumers connected to the transmission network. In the case of demand installations connected to evacuation infrastructure, management of the flexible access permit will be carried out at the demand installation itself, not at the boundary point with the transmission network. The flexible access capacity of the installation exceeds 1 MW. Essential supplies and loads that cannot remain without grid connection for more than 24 hours are excluded. Flexibility ceases to be a voluntary attribute and becomes the regulatory tool to unlock capacity.
It should be noted that implementation of flexible permits will follow a progressive timetable: Type 0 permits may be requested within six months of the resolution entering into force; Type 2 will be enabled from 1 January 2028; and until 1 January 2029, Type 3 in transmission may only be requested where there is an exclusive dedicated consumer position. Furthermore, before 2028, distribution network operators must have the necessary analytical and operational tools to execute preventive or corrective disconnections and to issue real-time instructions in accordance with POD1, consolidating flexibility operations within the grid.
In parallel, MITECO’s Draft Royal Decree redefines the technical connection framework. It applies to generation, demand, storage and HVDC systems that were not connected or in service before 23 February 2026, as well as to substantial modifications. The deadline for submitting comments is 16 March 2026. This constitutes a comprehensive update of technical requirements in a system that already exceeds 50% annual renewable generation and is preparing to integrate increasing volumes of energy storage and newly electrified demand.
One of the central pillars is the establishment of a dedicated framework for energy storage. The text recognises that these installations were not contemplated in the first iteration of European network codes and creates a specific annex for storage modules. Maximum injection and import capacities and significance thresholds are defined, consolidating differentiated technical rules. Spain’s National Energy and Climate Plan (PNIEC) foresees 22.5 GW of operational storage by 2030, a volume that requires clear integration and stability criteria. In addition, installations with already granted permits may request, within seven months, a new assessment to adapt to flexible schemes. Storage ceases to be treated as generation by analogy and assumes a structural role in capacity management.
The Royal Decree also introduces reinforced technical robustness requirements for demand. In certain areas of the grid where capacity is limited by dynamic criteria, the text itself states that new capacity cannot be enabled solely through physical reinforcement, but rather by ensuring adequate electrical behaviour requirements.
This means that newly electrified industries and large consumers — such as green hydrogen projects or data centres — must guarantee voltage dip ride-through capability, comply with strict power quality requirements (harmonics, flicker and voltage imbalance), and avoid introducing adverse oscillations into the system. It also incorporates measures derived from Royal Decree 997/2025, requiring stable power injection, oscillation damping and appropriate disturbance response. Grid connection will no longer be assessed solely by installed capacity, but by dynamic electrical performance.
At the same time, the regulation comprehensively updates requirements applicable to non-peninsular territories, where the developments of European network codes had not yet been fully extended. With increasing renewable energy and storage penetration in islanded and isolated systems, robustness and security criteria adapted to their greater operational sensitivity are incorporated. This raises the technical standard in island systems and consolidates the integration of storage and renewable generation under a coherent and updated regulatory framework.
The regulation incorporates explicit obligations to avoid the introduction of adverse oscillations and to strengthen system stability. In an environment increasingly dominated by power electronics, systemic sensitivity rises and the regulator raises the technical connection standard. The consumer becomes an active part of the electrical balance.
Regarding hybridisation, the Royal Decree establishes specific requirements for installations combining generation and storage at a single access point. The objective is to prevent interference in system response to disturbances and to guarantee operational coordination. Hybridisation ceases to be exclusively a commercial optimisation tool and becomes subject to strict technical criteria.
A joint reading of both reforms is conclusive. Spain is not only seeking to integrate more renewable energy, but to optimise the use of existing infrastructure through active demand and dispatchable storage. Capacity ceases to be an automatic right associated with investment and becomes dependent on certified flexibility and demonstrable technical robustness. For the energy, industrial and technology sectors, the message is clear: grid access enters a new stage in which electrical behaviour will be as decisive as installed megawatts.
