Spanish Energy Savings Certificates for industrial heat pumps

One certificate represents one kWh

MITECO defines a CAE as an electronic document that certifies one kilowatt-hour of new annual final-energy saving following an eligible efficiency action. The owner of the saving can transfer it in return for consideration.

The legal basis

Real Decreto 36/2023 created the Spanish CAE system. Orden TED/815/2023 develops its operation and Orden TED/845/2023 approves the national catalogue of standardised energy-efficiency measures. The catalogue is updated by later resolutions, so the current sheet and version must be checked when a project is prepared.

Standardised and singular actions

A standardised action follows a catalogue sheet containing the calculation method and evidence requirements. A singular action covers a more complex or site-specific measure that is not in the catalogue and requires its own savings calculation, justification and verification dossier.

An industrial heat-pump project should not be forced into a catalogue sheet simply because the equipment category sounds similar. The baseline, process boundary and displaced final energy determine the appropriate route.

Who can request certificates

The industrial site can own and transfer the underlying saving, subject to the contractual arrangements and scheme rules. Only an obligated party under the national energy-efficiency obligation system or an accredited delegated party can apply for CAE issuance. A favourable opinion from an accredited energy-savings verifier is required before the application.

The regional CAE manager and national coordinator then perform their administrative roles. A commercial proposal from an intermediary is not the certificate itself and should state who is acting as the delegated party, who pays for verification and when ownership of the saving transfers.

Protect the evidence trail

Baseline records, measurement boundaries, commissioning results, invoices and proof of implementation should be designed into the project before work begins. For a heat pump, retain useful-heat measurements, included electrical loads, source and sink temperatures, operating hours, backup heat and evidence for the displaced boiler or process duty.

The verification method needs to prevent double counting. Simultaneous cooling, recovered heat and avoided fuel may all have value, but they cannot be claimed twice through overlapping calculations.

Do not treat CAE value as fixed

One CAE represents one kilowatt-hour of recognised annual final-energy saving. That does not establish a fixed euro price for the site. Commercial value depends on the agreement with an obligated or delegated party, documentation risk, timing, verification cost and market conditions.

Model the project without CAE income first. Then show the contracted net value as a separate scenario after eligibility, calculation method, ownership and transaction costs have been confirmed.