Spain has emerged as a global leader in renewable energy adoption, particularly in photovoltaic (PV) systems. The country’s regulatory framework facilitates both individual and collective self-consumption while ensuring technical compliance and economic viability. This article explores the key aspects of commissioning and permitting PV projects in Spain, offering valuable insights into navigating its legal landscape.

Spain has emerged as a global leader in renewable energy adoption, particularly in PV systems

📜 Regulatory Framework

Spain’s PV sector operates under a robust legal structure that promotes self-consumption while simplifying administrative processes. The cornerstone legislations include:

1. Law 24/2013: The «Ley del Sector Eléctrico» establishes the foundation for self-consumption by defining its scope and the general framework for the electricity market in Spain. Article 9 defined self-consumption as the use of electricity generated within a consumer’s network or via a direct power line. It laid the foundation for later regulations governing PV self-consumption and grid connection.
2. Royal Decree 900/2015: Known as the «Sun Tax», it Introduced strict limitations on self-consumption, including: prohibition of energy sharing between consumers, administrative hurdles for small PV systems, the infamous «sun tax», which imposed charges on self-consumed electricity. It required PV system owners to obtain access and connection permits, even for small-scale systems. This decree was widely criticized for stifling solar development and was later repealed.
3. Real Decreto Ley (Royal Decree-Law) 15/2018: Introduces shared self-consumption models and surplus compensation mechanisms. This law introduces the «deregulation era» in Spain and became a turning point for solar energy in Spain. It abolished the «Sun Tax» and facilitated self-consumption growth, introduced collective self-consumption, allowing multiple consumers to share a PV system, streamlined administrative procedures, eliminating unnecessary paperwork for small installations (<100 kW), and allowed grid surplus compensation, enabling PV owners to receive credits for excess energy.
4. Real Decreto 244/2019: Provides detailed guidelines on administrative, technical, and economic requirements. It further simplified the administrative, technical, and economic rules for self-consumption by clearly defining two types: without surplus («sin excedentes»), which prohibits grid injection, and with surplus («con excedentes»), which allows grid injection with or without compensation. It also enabled individual and collective self-consumption via shared PV systems, introduced simplified surplus compensation for installations under 100 kW, and eliminated permit requirements for small residential setups. Additionally, it reduced penalties for improper installations, significantly boosting residential and commercial PV deployment and accelerating self-consumption adoption across Spain.

These laws enable consumers to generate their own electricity while contributing surplus energy to the grid under favorable conditions.

The main regulations governing PV permitting in Spain are Law 24/2013 RD 15/2018, and RD 244/2019

⚡ Grid Access and Connection: The Critical Bottleneck

1. Royal Decree 1183/2020 (Grid Access and Connection Regulation) This decree established new procedures for obtaining grid access and connection permits, addressing one of the biggest challenges for PV project development. It introduced capacity reservation guarantees, requiring developers to deposit €40/kW to secure grid space, discouraging speculative applications. To improve transparency, it mandated that grid operators publish available capacity, allowing developers to make informed decisions. Additionally, it set strict deadlines for project execution, preventing companies from holding unused grid capacity for extended periods. While this regulation helped reduce grid congestion, it also introduced new financial barriers that made project financing more complex.
2. Royal Decree-Law 23/2020 (Emergency Measures for Energy Transition) To further streamline the permitting process and prevent speculative grid hoarding, this decree enforced strict deadlines for PV project execution. Developers were required to prove project viability within five years to retain their grid connection rights, ensuring that only serious projects progressed. Additionally, it introduced provisions for hybrid installations (e.g., PV + wind), allowing better utilization of existing grid capacity. By enforcing these measures, the decree significantly reduced grid congestion caused by inactive projects, ensuring that connection rights were allocated more efficiently.

📜 Additional Regulations for Large-Scale and Small-Scale PV Plants

1. Royal Decree 1955/2000 (General Grid Regulation) This regulation governs grid connection procedures for large-scale PV projects (>100 kW) and establishes the requirements for public consultation before approval. While it grants priority access to renewable energy projects, this priority is subject to grid constraints, meaning that developers must navigate technical and administrative hurdles to secure connection rights. The decree remains a key regulatory framework for utility-scale PV plants, influencing grid integration policies and permitting processes.
2. Royal Decree 1699/2011 (Small-Scale PV Installations) To support distributed solar generation, this decree introduced simplified grid connection procedures for PV plants ≤100 kW. It exempted small-scale projects from complex environmental impact assessments, reducing permitting delays for rooftop and small commercial installations. Additionally, it required bidirectional metering, ensuring that energy flows were accurately tracked for self-consumption and surplus compensation. This regulation played a crucial role in facilitating residential and small-business PV adoption, making self-consumption more accessible.

🏷️ Types of Installations

PV systems in Spain are classified into two main categories:

1. Without Surplus: Designed solely for self-use; these require certified anti-spill devices to prevent grid exportation.
2. With Surplus: These are further divided into:

Collective configurations allow multiple consumers to share a single generation source, distributing energy via predefined coefficients.

🔄 Permitting Process

The permitting process varies depending on system size and type:

• Small installations (≤15 kW) in urban areas are exempt from access permits.
• Larger systems require deposits (€40/kW) and adherence to grid connection protocols.

Additionally, all installations must be registered with their respective autonomous communities using specific forms.

Total timeframe for permitting: 12–24 months

The permitting process for a large-scale PV plant in Spain typically involves the following six key steps:

1️⃣ Site Selection & Feasibility Study

• Identify land with adequate solar resources.
• Ensure compliance with municipal urban planning and land-use regulations.
• Conduct an initial grid connection feasibility study.

2️⃣ Grid Access & Connection Permit (One of the biggest challenges!)

• Submit a grid access application to the Distribution System Operator (DSO) or Red Eléctrica de España (REE) for projects >1 MW.
• Provide a financial guarantee (€40/kW for projects >100 kW) as per CNMC regulations.
• Wait for technical and economic feasibility assessments. This can take 6–12 months, depending on grid capacity.

3️⃣ Environmental Permits & Impact Assessments

• Projects >50 MW require a full Environmental Impact Assessment (EIA).
• Sensitive locations (e.g., Natura 2000, ZEPA zones) may require 1-year avifauna studies and compensation plans.
• Regional authorities assess impact on biodiversity, water resources, and local communities.

4️⃣ Municipal Licenses & Land Use Approval

• Secure urban planning approval – requirements vary by municipality.
• If the land is classified as rustic, a special permit is needed, which can delay the process significantly.
• Obtain a building permit (Licencia de Obras) from the local town hall.

5️⃣ Administrative Authorizations

• Administrative Authorization for Construction (AAC) – Requires a detailed project plan and technical documentation.
• Administrative Authorization for Operation (AAO) – Grants permission to connect the PV plant to the grid and commence operations.
• Both steps involve public consultation and can take several months due to potential objections.

6️⃣ Final Inspections & Commissioning

• Inspection by Industry & Energy Department to verify compliance.
• Certification of grid connection & electrical safety.
• Final registration with the National Energy Commission (CNMC) and local energy registries.

🕒 Total Timeframe for Permitting: 12–24 months (varies based on project size and complexity).

🌞 Conclusion: How to Navigate PV Permitting in Spain

Spain’s regulatory framework has evolved from restrictive policies (RD 900/2015) to a more favorable environment (RD 244/2019). However, permitting remains complex, especially for large-scale PV plants.

Spain’s regulatory framework has evolved from restrictive policies to a more favorable environment. However, permitting remains complex, especially for large-scale PV plants.

For small PV systems (<100 kW):

• Easier permitting, especially for self-consumption.
• No need for complex grid access permits (unless exceeding 15 kW).
• Surplus compensation available under RD 244/2019.

For large PV projects (>100 kW):

❗ Grid access is the biggest challenge → Requires financial guarantees (€40/kW).

❗ Environmental Impact Assessments (EIAs) are mandatory for projects >50 MW.

❗ Land use regulations vary by region, requiring local approvals.

For more information or assistance with your PV project in Spain, feel free to connect!