🌍 The CAE System is entering a new phase: energy efficiency must go hand in hand with decarbonization.
From 2024, only actions that reduce consumption without resorting to direct combustion will be eligible for Energy Savings Certificates (CAE).
We explain why, according to the new European Energy Efficiency Directive (EU) 2023/1791 👇
🧩 Directive (EU) 2023/1791 and Order TED/815/2023 reinforce the decarbonization approach of the CAE System.
The Energy Savings Certificate (CAE) System is consolidating its position as one of the main tools for certifying and monetizing final energy savings achieved in Spain. Its regulation, based on Royal Decree 36/2023 and further developed through Order TED/815/2023, fully incorporates the criteria of Directive (EU) 2023/1791 of 13 September 2023 on energy efficiency.
This new regulatory framework, which is mandatory in Member States, marks a structural change in the eligibility of projects, by expressly excluding from the system any measures that involve the consumption or installation of equipment powered by fossil fuels.
🔥 Ineligible Actions: An Opportunity to Innovate
According to Annex V, point 2.i of Directive (EU) 2023/1791, Member States may not certify or count energy savings resulting from actions that use fossil fuels when such actions are implemented from 1 January 2024 onwards.
This means that:
❌ Actions that replace or install new thermal systems or combustion equipment are not eligible, even if they represent an efficiency improvement.
✅ Measures that reduce the consumption of existing fossil fuels are eligible, through optimization, control, heat recovery, or partial replacement with more efficient or electric systems.
With this approach, the Energy Savings Certification System (CAE) ceases to be an isolated efficiency tool and becomes integrated into the national strategy for the deep decarbonization of the energy and industrial sector.
🏭 Pending exception: Large industrial consumers
Point 2.j of Annex V of Directive (EU) 2023/1791 includes a specific exception: the possibility of certifying certain activities involving the use of fossil fuels when carried out in energy-intensive industrial companies.
However, this exception cannot yet be applied, as the definition of a “large energy-intensive industrial company” has not been established by law.
This exception can only be applied during the period from January 1, 2024, to December 31, 2030.
➡️ The Ministry for Ecological Transition and the Demographic Challenge (MITERD) has confirmed that the definition is currently being drafted and regulated, and that it will be crucial for future industrial activities during the 2024–2030 period.
💡 Conclusion
The CAE System is evolving from quantitative energy efficiency to qualitative climate efficiency.
This new regulatory framework doesn’t limit efficiency, but rather directs it toward projects with real environmental impact, where reducing energy consumption goes hand in hand with reducing emissions.
The coming years will be crucial for consolidating a sustainable and verifiable energy-saving model, where innovation, technology, and decarbonization converge under a single objective: cleaner and more competitive energy.
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