EU Tracker – Local heating and cooling plans in Spain
Summary
What is the status of the transposition of Article 25(6) (EDD) and its implementation?
Spain is preparing the transposition of Article 25(6) of the recast Energy Efficiency Directive through the draft Royal Decree on district heating and cooling, thermal planning and waste heat recovery (RD SUCYR). The proposal would introduce mandatory local heating and cooling planning for larger municipalities and establish coordination and support arrangements across government levels. Following consultations in 2025 and 2026, adoption and publication remain pending. The proposed obligations and support mechanisms should therefore not yet be treated as operational
Detailed assessment
The legal framework and the obligations
Preparing local heating and cooling plans is neither obliged nor encouraged by law in Spain
Overview of the legal frameworks per governance level
| National | The Climate Change and Energy Transition Act, entered into force on 22 May 2021, defines the main climate and energy related policy objectives in Spain. Its main purpose is to ensure the compliance by Spain with the objectives of the Paris agreement and the European Green Deal. The law sets a normative target for climate-neutrality by 2050, with 42 % renewables target in final energy consumption in 2023 and a reduction target for primary energy consumption to at least 39.5% by 2030. Spain has not issued any national regulation on heating and cooling planning as such, but the Royal Decree 56/2016 mandates the issuing of appropriate measures to develop heating and cooling infrastructures in areas where high efficiency cogeneration has been identified. The technical building code also includes energy efficiency conditions for buildings with consideration to their climatic conditions. Such technical regulations, covered in the Long-Term Strategy for Energy Renovation in The Building Sector in Spain (ERESEE) published in 2020, are however not explicitly linked to municipal energy planning. The update of the National Climate and Energy Plan, submitted in 2024, includes a measure (2.10) on local heating and cooling planning to comply with new EED requirements for local heating and cooling plans (article 25). It identifies that 164 municipalities should draft a local heating and cooling plan. However, it does not establish targets for timing or scope. It only states that the measure is to be co-managed and co-funded by public administrations across levels of governments in line with Spain’s decentralized governance model, including The Ministry for the Ecological Transition and the Demographic Challenge (MITECO), the Ministry of Transport, Mobility and the Urban Agenda (MITMA), the Autonomous communities and local authorities. The draft RD SUCYR would establish the national framework for local heating and cooling planning under Article 25(6) EED. A first public consultation took place between 19 August and 8 September 2025, followed by a second consultation between 27 May and 17 June 2026. The proposal remains pending adoption and publication. |
| Regional | The Autonomous communities have a legal right to establish comprehensive planning systems and issue regulations on energy related issues. These mainly tend to concern targets and objectives rather than obligations, for instance on the deployment of renewable electricity production. Some regions have developed regional energy planning documents on a voluntary basis, but they lack detailed assessments on heating and cooling. Provincial and regional energy agencies have in some cases been in charge of the assessment and coordination of municipal Sustainable Energy and Climate Action Plans (SECAPs). The Law 4/2019 on the energy sustainability of the Basque Autonomous Community is one of the few subnational laws in Spain that mandates municipalities to draft energy related planning documents, but its focus is restricted to municipal buildings and activities. The draft RD SUCYR would require municipalities with at least 45.000 inhabitants to prepare local heating and cooling plans, with first versions available by 31 December 2027. It also provides for population-based submission deadlines linked to the future ministerial order, coordination with other local planning instruments, voluntary provincial plans for smaller municipalities and joint planning between neighbouring authorities under specified conditions. These provisions remain subject to adoption. |
| Local | Energy related obligations for municipalities are limited to improving the energy efficiency in public buildings and public lighting, without requirements to draft any climate and energy plans, nor heating and cooling plans. However, numerous Spanish Municipalities have on a voluntary basis conducted a Sustainable Energy and Climate Action Plans, often in the framework of the Covenant of Mayors initiative., With few exceptions, these plans do not contain detailed assessments and decarbonization scenarios on heating and cooling (including spatial analysis). In addition, the district heating sector is not well developed, and few cities study the development of district heating networks. |
The support framework
The support framework for local energy and climate planning has shown some recent improvement, but remains weak overall
Spanish local authorities lack a comprehensive support framework to undertake local heating and cooling planning. The technical support is limited, and the financial support focuses on specific projects, not on strategic planning. While some recent progress for the availability of energy-related geodata has been made, access to data remains overall a difficulty for local authorities, with no legal framework to ensure their availability and a lack of consolidated datasets on buildings, energy demand, energy infrastructures and potential of waste and renewable thermal energies.
Provided Support
| Technical and organisational | 3/5 | No comprehensive technical and organizational support framework for local heating and cooling plans has been established across Spain, with the extent of support unevenly distributed across regions. However, the publication a new Heat guide is a positive step (edited by ECODES and ADHOC). The guide should inspire more national measures. National and European networks have provided some technical guidance to and peer exchange between local administrations for developing local renewable energy plans and projects. One example is the Spanish Network of Cities for Climate (RECC), founded by the Spanish Federation of Municipalities and Provinces (FEMP) and MITECA, which has supported local authorities and energy communities to identify and increase the uptake of local renewable energy sources. Technical support to municipalities has in some cases also been provided by Regional and local energy agencies and by non-profit organizations. The draft RD SUCYR envisages methodological guides and technical guidance from MITECO in coordination with regional governments. According to ECODES, municipal workshops are planned following publication of the decree to support plan preparation and inform the subsequent ministerial order. This additional support is prospective. |
| Financial | 2/5 | While numerous national and regional funds have been made accessible to energy refurbishment projects for buildings carried out by local authorities, no dedicated financial framework provided by the national government to draft municipal energy related plans. Funding from various EU programs, including ERDF and LIFE, have been allocated to the development of SECAPS as well as projects fostering the uptake of renewable sources for heating and cooling. However, this allocation lacks coordination at the national level or level of autonomous communities. Article 29 of the draft RD SUCYR envisages guidance on financing from national, regional, EU and other sources, alongside financial mechanisms scaled to municipal size to help authorities procure technical assistance for preparing their plans. These provisions do not yet constitute an operational funding programme. |
| Staff & skills | 1/5 | Local authorities in Spain lack dedicated staff to work on energy planning and the energy dimensions of spatial development. Staff with dedicated experience on energy issues are mainly employed to work on energy efficiency improvements of municipally owned assets, and development of renewable energies (mostly electricity). Given the insufficient in-house skills to develop strategic energy-related plans, SECAPS are very often drafted by external contractors. A study by Energy cities published in 2022 estimated the staffing shortage in Spanish local administrations to meet the need for building decarbonisation to be among the highest in Europe, in both total numbers and on a per capita basis. |
| Access to data | 2/5 | Utilities operating in Spain are encouraged to provide Local Authorities with energy supply data, while detailed electricity consumption data has been made accessible for public administrations through the Dadadis platform, while data on energy infrastructure is generally not provided. Disaggregated data on energy supply needed for detailed heating and cooling planning would require agreements between DSOs and municipalities. Data regarding buildings (e.g., size, age) is accessible through the national building cadaster. Energy demand and heating systems of buildings are accessible from regional databases of energy performance standards but require a lot of data treatment to be exploited. These databases are not harmonized at national level. Data regarding techno-economic potentials of renewable sources are overall lacking, especially for thermal renewable energies. Tools for technical assessments of the potential for photovoltaics by local authorities have meanwhile progressed further. IDEA published in 2022 a heat map of Spain, showing potential areas for waste heat recovery, but it contains few data. |
