On week 45, 7 November 2025, Order TED/1252/2025 was published in Spain amending order ITC/1522/2007 that regulates Guarantees of Origin (GO) for renewable plants producing under state support. It went into effect on 8 November 2025. The law’s amendment entails the following changes:

Article 7 is deleted. This removes the producers’ obligation to ring-fence the revenue from the sale of supported GOs exclusively to improvements in the producing plant. Under the new regime, revenue generated from the sale of supported GOs can be treated as commercial revenue that can be used freely by the producer.

Article 11.2 was changed to remove the restriction to export GOs from supported production, with the limitation that these certificates can only be exported by the owners of the supported installations in question.

Market impact

The changes in the law lift the obligation for the producer to go through cumbersome bureaucratic processes to get revenue from the sale of supported GOs. The obligation to ring-fence this revenue was disincentivising some small producers from issuing GOs for their production as the administrative cost of proving the lawful revenue’s use was higher than the potential gains from the certificate’s sales. Removing the requirement to reinvest the supported GO revenue could lead to an increase of 2-3 TWh in the total supply of renewable GOs in Spain.

In addition, the abolition of reinvestment obligations stemming from Article 7 would also render GO-related revenue of commercial nature. In the current low pricing environment, this would not have significant impact, but if prices rise to EUR 1/MWh or higher it could have minor positive impact in investment attractiveness of new renewable generation capacity.

The lifting of export restrictions for supported GOs will effectively turn what is known as Spanish domestic GOs into EECS GOs that are freely traded across the AIB. This would increase cross-border trade between Spain and the rest of the AIB but is not expected to have a significant impact on GO prices AIB-wide. Despite the large amount of Spanish domestic production (96 TWh in 2024), these certificates typically oscillate between a EUR 0.05/MWh discount to and EUR 0.05/MWh premium over EECS GOs, depending on how far or close the import or cancellation deadlines are in the Spanish disclosure system. Therefore, the pooling of Spanish domestic supply with the rest of the AIB’s supply is not expected to have any significant effect on wider prices.

Spain issued in 2024 96 TWh of renewable domestic GOs and 46 TWh of exportable EECS GOs. Cancellation stood at 79 TWh of domestic and 10 TWh of exportable certificates. By October 2025, a total of 57 TWh of domestic and 20 TWh of exportable 2025 certificates have been issued.