Indirect CO2 cost aid in Spain: changes for 2026

Spain has expanded its indirect CO2 cost aid to 22 additional industrial sectors and subsectors. The change matters to energy-intensive manufacturers because it can compensate part of the carbon cost passed through in electricity prices, including costs incurred by newly eligible sectors from 2025 under the updated EU framework.

The reform does not create an automatic payment. Eligibility depends on the activity carried out at each installation, the relevant NACE or product code, verified production and electricity data, the annual call and compliance with continuing energy and decarbonisation obligations.

What changed in Spain’s indirect CO2 cost aid in 2026

Order PJC/678/2026, published on 7 July 2026, updates Annexes I, II and III of Royal Decree 309/2022. It aligns the Spanish scheme with the European Commission’s amended EU ETS State aid guidelines and applies to the 2021–2030 indirect-cost period.

The main changes are:

1. Twenty-two new sectors and subsectors are added. They include organic chemicals, fertilisers, primary plastics, batteries, glass, ceramics, textiles, wood products and metal mining.
2. Previously eligible activities can receive up to 80% of eligible indirect emission costs, compared with the previous 75% maximum.
3. Newly added activities can receive up to 75% of eligible indirect emission costs.
4. The Spanish regional emission factor falls to 0.47 tCO2/MWh for 2026–2030, from 0.53 tCO2/MWh for 2021–2025, subject to the adjustment possibilities provided by the rules.
5. The scheme remains annual and competitive. The percentage is a legal ceiling, not a guaranteed award, because the available budget is distributed under the annual call.

According to the Ministry of Industry and Tourism, the 2025 call allocated EUR 600 million and the 2026 call was expected within weeks of the reform. Companies should monitor the official call rather than treating the press announcement as the opening of the application period.

What indirect CO2 costs and carbon leakage mean

EU ETS allowance costs affect industry in two ways. An installation covered by the EU ETS may face a direct cost for its own emissions. Electricity producers also include part of their carbon cost in wholesale electricity prices. Energy-intensive consumers therefore bear an indirect CO2 cost even when a specific production line does not emit CO2 directly.

Carbon leakage occurs when this cost pressure contributes to production moving outside the EU, or to European products being replaced by more carbon-intensive imports from jurisdictions with weaker climate constraints. The aid mechanism aims to reduce that risk without removing the incentive for efficient electricity use.

This aid is different from free allocation and from CBAM. Free allocation addresses certain direct EU ETS exposure. CBAM places a carbon adjustment on covered imports. Indirect-cost compensation addresses carbon costs reflected in electricity. Fertilisers and iron ore require particular attention because the European Commission has identified possible overlap with CBAM for indirect emissions.

For a broader explanation of the carbon market, see Dcycle’s EU ETS overview. The operational issue is to keep direct emissions, indirect electricity costs, free allocation and any CBAM exposure separate while reconciling them to the same facility and production boundaries.

The 22 newly eligible sectors and subsectors

Eligibility is established at installation and activity level. A group operating in several industries cannot assume that all electricity consumption is eligible because one legal entity holds an eligible NACE code.

The new table in Order PJC/678/2026 includes:

No.	NACE code	Newly included activity
1	07.29	Mining of other non-ferrous metal ores
2	07.10	Mining of iron ores
3	20.17	Manufacture of synthetic rubber in primary forms
4	20.60	Manufacture of man-made fibres
5	20.16	Manufacture of plastics in primary forms
6	13.10	Preparation and spinning of textile fibres
7	23.31	Manufacture of ceramic tiles and flags
8	20.12	Manufacture of dyes and pigments
9	13.95	Manufacture of non-wovens and related articles, except apparel
10	23.14	Manufacture of glass fibres
11	27.20	Manufacture of batteries and accumulators
12	20.14	Manufacture of other organic basic chemicals
13	20.15	Manufacture of fertilisers and nitrogen compounds
14	10.41	Manufacture of oils and fats
15	11.06	Manufacture of malt
16	16.21	Manufacture of veneer sheets and wood-based panels
17	23.11	Manufacture of flat glass
18	23.13	Manufacture of hollow glass
19	24.31	Cold drawing of bars
20	24.34	Cold drawing of wire
21	20.59	Specified alkylbenzene and alkylnaphthalene mixtures
22	23.99	Specified slag wool, rock wool and similar mineral wools

Some boundaries are product-specific. Primary plastics and glass fibre also contain products that were already in the previous table and therefore may fall under the 80% group. The exact NACE, PRODCOM code, product definition and production process must be checked before assigning the applicable intensity.

How the maximum aid is calculated

The calculation is not simply electricity spend multiplied by 75% or 80%. Royal Decree 309/2022 uses formulas designed to estimate the indirect carbon cost of efficient production.

For products with an electricity-efficiency benchmark, the core variables include:

1. Aid intensity (Ai): up to 80% for the previously included table and up to 75% for the new table.
2. CO2 emission factor (Ct): 0.47 tCO2/MWh for 2026–2030 under the amended Spanish annex.
3. Forward EUA price (Pt-1): the relevant forward price for the year before the eligible cost year, calculated under Annex III.
4. Efficient electricity benchmark (E): the product-specific benchmark, reduced annually where applicable.
5. Actual output (AOt): verified production of the eligible product during the cost year.

Where no product benchmark applies, an alternative electricity-consumption reference may be used under the rules. Products affected by fuel and electricity interchangeability have a separate method intended to prevent double compensation with free allocation.

The annual call can also apply a gross-value-added cap so that the payable indirect cost can be limited to 1.5% of the beneficiary’s gross value added. A ROAC-registered auditor’s report may be required when this route is used.

The result should be treated as an estimated maximum until the annual call confirms the parameters, budget and documentation. Production changes, metering boundaries, self-generation, zero-carbon supply and aid accumulation can all affect the final amount.

Who can apply and what evidence is required

Private legal entities may apply whether or not they are themselves in the EU ETS, provided that they are validly constituted, carry out an eligible commercial activity and incurred indirect CO2 costs in the year preceding the call.

The application window is normally 20 working days from the day after the call extract is published in the BOE, unless the call sets another start date. Preparation therefore needs to begin before publication.

A robust evidence file should contain:

1. The applicant, installation and authorised representative data.
2. The eligible NACE and, where relevant, PRODCOM classification for every product.
3. A facility-level memorandum explaining eligible activities and indirect costs.
4. Verified actual production and electricity consumption for the preceding year.
5. A documented method for allocating electricity to eligible production.
6. The percentage of electricity from zero-carbon sources and the supporting instrument or investment.
7. The selected compliance option under Article 5 and its implementation timetable.
8. The latest applicable energy-audit evidence.
9. Any gross-value-added calculation and ROAC report requested by the call.
10. Reconciliation to accounting records, invoices, meters and commercialised output.

The official rules require verification by an ENAC-accredited verifier or another recognised national accreditation body for actual production and electricity data. The verification must allow production sold to be traced to accounting records and electricity to be traced to the declared production.

Obligations after receiving the aid

The grant creates continuing obligations. Beneficiaries subject to mandatory energy audits must complete one of the alternatives in Article 5 within no more than three years from the award:

1. Implement relevant energy-audit investments with a qualifying payback period and proportionate cost.
2. Invest at least 50% of the aid in projects that deliver substantial installation-level greenhouse gas reductions.
3. Source at least 30% of electricity from zero-carbon sources through qualifying instruments, self-consumption investments or similar measures.

The amended EU guidelines also allow Member States to use investment in new or modernised assets that measurably reduce electricity-system costs as an alternative. Companies should verify whether and how each Spanish annual call incorporates later EU options instead of assuming automatic application.

For each of the three years after an award, beneficiaries have a first-half reporting window to submit compliance evidence. A new award renews the monitoring period. Failure can lead to repayment and interest.

This is where ISO 50001 becomes operationally relevant. A functioning energy management system can connect audit recommendations, meters, significant energy uses, action plans and verified savings. Dcycle’s corporate energy-efficiency analysis explains how to maintain that evidence beyond a one-off subsidy application.

A numbered preparation plan for the 2026 call

1. Confirm installation-level eligibility

Map every Spanish installation to its activities, NACE codes, products and PRODCOM codes. Separate previously eligible products from newly eligible products because the maximum intensity differs.

2. Freeze the reporting boundary

Define which meters, self-generation assets, supply contracts and production lines belong to each eligible process. Document shared utilities and allocation keys before verification begins.

3. Reconcile electricity and production monthly

Tie invoices to meters, meter readings to production lines and production output to accounting records. Investigate gaps, estimates, negative readings and inconsistent units while source owners still remember them.

4. Model the aid under several scenarios

Use the applicable intensity, emission factor, forward EUA price, benchmark and verified output. Show a base case, a conservative case and the budget-proration risk. Do not book the statutory maximum as certain income.

5. Choose the post-award obligation early

Compare audit investments, the 50% decarbonisation route and the 30% zero-carbon electricity route. Select the option that fits the site’s investment plan and can be evidenced for three years.

6. Prepare verification and governance

Assign owners in energy, operations, finance, tax, sustainability and legal. Create an approval trail for classifications, allocation methods, calculations and submitted evidence.

How Dcycle supports indirect CO2 cost applications

Dcycle does not determine legal eligibility or replace an accredited verifier. It provides the governed data layer needed to prepare, explain and maintain the application evidence.

With automated data collection, teams can connect invoices, meter readings, production files and zero-carbon procurement evidence. Validation rules flag missing periods, unit changes, duplicate invoices and unexplained differences.

The platform can structure facilities, meters, products and reporting periods in one controlled model. Each value retains its source, owner, approval status and change history. That makes it easier to explain how electricity was allocated to eligible production and how the final calculation reconciles to source systems.

Dcycle’s carbon-footprint platform keeps the aid calculation distinct from Scope 2 reporting while reusing verified electricity activity data. Market-based emissions, location-based emissions and indirect-cost compensation have different methods, but they should not require three disconnected data collections.

The practical benefit is a repeatable annual close. Instead of rebuilding the file when the call opens, the company maintains application-ready electricity, production, audit and decarbonisation evidence throughout the year.

Frequently asked questions (FAQs)

This article provides general information, not legal, subsidy or tax advice. Check the final 2026 call, the consolidated Royal Decree 309/2022 and the classification of each installation before applying.