Introduction

On 5 November 2025, the Spanish government approved Royal Decree 997/2025, approving urgent measures to strengthen the electricity system (RD 997/2025), published in the Official State Gazette (Boletín Oficial del Estado) on 6 November 2025 and entered into force the following day.

RD 997/2025 reintroduces a number of measures (originally contained in the unratified Royal Decree-Law 7/2025[1]) designed to reinforce the resilience and robustness of Spain’s electricity system in the aftermath of the unprecedented nationwide blackout (cero de tensión) of 28 April 2025.

As well as enhancing overall system stability, the RD 997/2025 seeks to accelerate the deployment of energy storage capacity – with a national target of 22.5 GW of installed storage capacity by 2030 under the Spanish National Energy and Climate Plan (PNIEC) 2023-2030 – and to facilitate the repowering of existing renewable assets, among other key measures.

This briefing provides an overview of the key aspects of RD 997/2025 and its implications for the renewable energy sector, as well as for other stakeholders in the electricity system. It is not intended to be exhaustive, but rather to offer a general summary of the main legislative changes introduced.

Impact on renewable energy developers and operators

Here the provisions of RD 997/2025 are highlighted, presented in article order, as the most relevant to renewable energy developers and operators:

A new definition of “installed capacity” (potencia instalada) for generation and storage facilities is introduced, based on generation modules and other equipment within electricity production plants, with specific rules for bifacial photovoltaic panels and electrochemical storage modules.

This definition will not apply generally until expressly enacted by a future royal decree[2], but it already applies (i) for the purposes of obtaining administrative authorizations under Article 53 of the Electricity Sector Law; (ii) registration in the Administrative Register of Electricity Production Facilities (Registro Administrativo de Instalaciones de Producción de Energía Eléctrica); and (iii) to projects already in progress that have not yet obtained final operating authorisation (autorización de explotación definitiva), which will continue to be processed by the original authority even if the new definition would otherwise alter its competence – provided the project’s capacity remains unchanged and the developer confirms continuation within 3 months.

Administrative procedures for hybrid electrochemical storage projects under the competence of the General State Administration are declared urgent for reasons of public interest when no environmental impact assessment is required. These procedures benefit from halved processing times and specific procedural simplifications, namely: (i) joint processing and resolution of the prior and construction administrative authorizations; and (ii) simultaneous handling of public-information and inter-administrative consultation steps, with the complete file to be submitted to the Directorate-General for Energy Policy and Mines within 15 days for final resolution. Furthermore, the installation of an electrochemical storage module within an existing renewable project is exempt from the simplified environmental impact assessment when located within the area already evaluated in the original project’s favorable environmental declaration.

A new regulatory definition of “repowering” (repotenciación) is introduced for generation and storage facilities, broadening the scope of the concept set out in Directive (EU) 2018/2001[3]. It covers the renewal or replacement of systems, equipment, or components to upgrade technology, improve efficiency, increase energy output, or expand installed capacity, and may also include extensions of existing facilities, subject to the relevant environmental assessment procedures. Within 9 months of the entry into force of RD 997/2025, the Government must prepare a National Repowering Roadmap to promote and accelerate repowering projects, potentially including regulatory incentives, such as simplified permitting and reduced administrative timelines for repowered installations[4].

Generation or storage projects developed within R&D&I platforms may obtain both prior and construction administrative authorizations for prototype projects. Replacing an existing prototype with a new one will only require operating authorization, provided the new prototype does not exceed the technical parameters set out in the existing authorizations or in the environmental assessment.

New data requirements are introduced for guarantees linked to demand-side access permits, particularly for storage facilities that draw energy from the grid[5]. Holders of such permits have 6 months to replace their existing guarantees with updated ones that include the newly required information. Alternatively, they may renounce their access permit within the same period, in which case the existing guarantee will not be enforced. The regulation empowers the administration to impose sanctions where the holder neither updates the guarantee nor formally renounces the permit.

All new generation projects must obtain a provisional operating authorization for testing purposes before they can be granted definitive operating authorization.

Other system-wide measures

The measures referred above have a direct impact on renewable energy developers and operators. Additionally, RD 997/2025 introduces a broader set of obligations and reforms designed to further reinforce the resilience of Spain’s electricity system, with impacts across all technologies and stakeholders.

These include:

The Spanish National Commission on Markets and Competition (Comisión Nacional de los Mercados y la Competencia) will prepare regulatory reports and carry out inspections on voltage control and service restoration, while the system operator (Red Eléctrica de España) is tasked with evaluating and proposing updates to technical rules concerning voltage stability, oscillation damping, ramping and system visibility.

Several measures aimed to boost electricity demand and industrial electrification, including:

• Expiry of grid access permits for consumers connected at or above 1 kV if no access contract has been formalized for at least 50% of the capacity granted within five years. For permits granted before the entry into force of RD 997/2025, the five-year period runs from that date (i.e., 7 November 2025);
• Establishment of criteria to determine when a demand-side or storage installation is deemed unchanged for the purpose of preserving its grid access rights[6]; and
• Specific execution timelines for distribution network extensions.

This briefing is intended as an overview and does not constitute legal advice. Please contact us for a detailed analysis as applied to your specific portfolio or projects.

[1] On 24 June 2025, the Spanish Government issued Royal Decree-Law 7/2025, 24 June, approving urgent measures to strengthen the electricity system (RDL 7/2025), which was subject to parliamentary ratification within thirty days of its adoption. However, the RDL 7/2025 was ultimately not ratified by Parliament. For further background, please refer to our previous briefing on RDL 7/2025.

[2] Unlike Royal Decree-Law 7/2025, which required the Spanish Government to adopt a new regulatory definition of “installed capacity” for generation and storage facilities within 12 months, the current regulation does not set any specific deadline for the royal decree that will formally bring this definition into general effect.

[3] According to Article 2.(10) of Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources, “repowering” means “renewing power plants that produce renewable energy, including the full or partial replacement of installations or operation systems and equipment for the purposes of replacing capacity or increasing the efficiency or capacity of the installation”. 

[4] The unratified Royal Decree-Law 7/2025 had already anticipated similar measures, granting repowering projects that increased installed capacity by up to 25% halved administrative and environmental permitting timelines, with the environmental assessment limited to the additional or differential impact caused by repowering or expansion. 

[5] The new wording of Article 23 bis.4) of Royal Decree 1183/2020, on access and connection to electricity transmission and distribution networks, as introduced by RD 997/2025, provides that “In the case of storage, the CNAE code will not be necessary, but it must be specified that the economic activity carried out is storage”. 

[6] The installation will be deemed unchanged if (i) its geographical centre remains within 10 km of the original site; (ii) its CNAE code remains within the same Division or Group under CNAE-2025; and (iii) any reduction in contracted demand capacity does not exceed 50% of the capacity originally granted. Otherwise, any modification to the guarantees prior to the access contract will automatically result in the loss or expiry of the corresponding access and connection permits.