SD Verdia

Day: 12 February 2026

Posted on

How does the Sustainable Mobility Law affect the energy sector?

The recent approval of Law 9/2025, of 3 December, on Sustainable Mobility (Law 9/2025) marks a new step in transforming Spain’s transport model, with the aim of moving towards more efficient, decarbonised mobility aligned with European climate commitments.

Although its central focus is mobility, this law incorporates numerous relevant changes to the regulatory framework of the electricity sector, with a direct impact on energy companies, infrastructure developers, distributors and operators linked to the electrification of transport.

The following is a general, practical overview of the main developments of interest to the energy sector.

A new framework to meet the growing electricity demand associated with mobility

One of the most relevant aspects of the Law is the introduction of mechanisms designed to facilitate the servicing of new electricity demand, especially that linked to transport-electrification and electric-vehicle charging projects.

To this end, a new mechanism for flexible planning of the transmission grid is added to the Electricity Sector Act, which will make it possible to periodically adapt substation positions where there are demand requests that cannot be met owing to a lack of capacity. This system, based on periodic reports from the system operator and resolutions of the Secretariat of State for Energy, seeks to reduce bottlenecks and speed up the electricity system’s response to new intensive-consumption projects.

For energy-sector companies, this development opens the door to greater predictability and new opportunities to develop projects that until now faced structural limitations on the grid.

A regulatory boost for EV charging infrastructure

The Sustainable Mobility Law clearly reinforces the deployment of charging infrastructure for electric vehicles, introducing relevant regulatory adjustments from an electrical and administrative standpoint.

On the one hand, administrative procedures are simplified for certain electrical infrastructure associated with charging stations, exempting them from obtaining administrative authorisations where they do not require environmental assessment or a declaration of public utility. This simplification is particularly relevant for energy operators and charging-point developers, as it reduces timelines and administrative burdens.

On the other hand, the authorisation and public-utility regime applicable to high-power charging stations is clarified and extended, assigning powers to the General State Administration in certain cases and expressly extending the declaration of public utility to the associated electrical infrastructure.

Changes to the access and connection regime and to economic guarantees

The Law also introduces changes to the regime of economic guarantees required for access and connection requests of demand installations, provided for in Article 23 bis of Royal Decree 1183/2020, of 29 December, on access to and connection with the electricity transmission and distribution grids (RD 1183/2020). Although the reform’s stated purpose was limited — to introduce an exemption for strategic projects aimed at reducing greenhouse-gas emissions in transport — the drafting technique used has produced additional effects that were not expressly intended.

Specifically, the Law operated on the original wording of Article 23 bis, without taking into account the subsequent amendments the provision had undergone. As a result, the text currently in force reproduces the version resulting from the Sustainable Mobility Law, which has meant the de facto suppression of certain provisions recently introduced, especially in relation to storage installations.

While these installations remain subject to the obligation to provide guarantees, the specific regulatory features incorporated in earlier reforms disappear, which calls for a particularly careful analysis of the regime applicable in each specific case.

Greater flexibility in electricity self-consumption

Another development of interest to the sector is the greater flexibility of the self-consumption arrangements provided for in Article 4 of Royal Decree 244/2019, of 5 April, regulating the administrative, technical and economic conditions for the self-consumption of electricity (RD 244/2019). On an exceptional basis, the Law allows a single consumer to be associated simultaneously with two different arrangements, combining individual self-consumption without surpluses with self-consumption through nearby installations associated via the grid.

This measure may be especially attractive for industrial facilities, business parks or logistics environments, as it allows distributed generation to be optimised and the energy efficiency of consumption to be improved.

Transparency and electricity-grid planning

The Law introduces new information obligations for distribution companies, which must submit detailed data on grid capacity at locations suitable for installing charging points. With this information, MITECO will draw up a state map of electricity-grid capacity.

For energy companies, this instrument can become a key tool for investment planning, identifying opportunities and reducing uncertainty in the development of charging and electrification projects.

Transport electrification and opportunities for the energy sector

Beyond the strictly electrical changes, the Law lays the groundwork for setting binding renewable-energy penetration targets in transport, promotes the electrification of rail transport and provides for specific plans to deploy charging points in small and medium-sized municipalities.

All of this consolidates a clear trend: transport is becoming one of the main drivers of growth in electricity demand and a strategic area for energy-sector companies.

Conclusion

The Sustainable Mobility Law is not limited to regulating transport; it introduces structural adjustments to the electricity-sector framework to facilitate the electrification of the economy. For energy companies, it is essential to understand this new framework, anticipate its regulatory implications and adapt their project-development strategy to an environment increasingly oriented towards electric mobility and the efficient management of demand.

Related reading: EV charging points, energy communities and energy savings certificates (CAE).

Posted on

The regulation of customer-service functions in the energy sector

After a long period in which consumer rules operated in a fragmented, scattered way, the recent approval of Law 10/2025, of 26 December, regulating customer-service functions (LSAC), marks a paradigm shift in how providers of essential services relate to their customers. Customer service ceases to be conceived as a mere administrative channel and becomes a determining parameter of service quality.

This approach is particularly relevant in the energy sector, as basic services of general interest. Here, the LSAC fits into an already consolidated sector framework, led by Law 24/2013, of 26 December, on the Electricity Sector (LSE) and Royal Decree 1955/2000, of 1 December, regulating the transmission, distribution, retail, supply and authorisation procedures for electricity installations (RD 1955/2000), creating a much more complex legal regime that requires both electricity distributors and retailers to comprehensively adapt their operational processes for handling and managing queries, complaints, claims and incidents.

The LSAC sets an adaptation period of twelve months from its entry into force (28 December 2025) and expressly enshrines the principle of speciality, so that the electricity-sector rules will continue to apply on a preferential basis in those aspects specifically regulated therein.

Scope: obliged parties and protected parties

The LSAC applies mandatorily to all companies providing basic services of general interest, regardless of their size. It expressly includes the supply and distribution of electricity, thereby placing electricity retailers and distributors within its subjective scope.

The rule does, however, provide for a more flexible regime for smaller cooperatives and specific exemptions for small retailers that meet certain size requirements (not qualifying as a large company) and have a market share below 5%.

From the perspective of the protected parties, the LSAC adopts a broad notion of “customer”, which is not limited to the final consumer with a current contract but also includes those who have received personalised commercial offers or who are affected by incidents such as non-consented sign-ups, improper billing or continuity of supply after requesting cancellation.

Protection of the most vulnerable consumers is also reinforced, imposing enhanced obligations on accessibility, information and personalised service.

The Customer Service (SAC)

The Customer Service (SAC) is defined as the set of material and human resources that the company makes available to its customers to manage any matter related to the contracted service. This service must be effective, free of charge, inclusive, non-discriminatory, measurable and universally accessible, and clearly identified and differentiated from the company’s other activities; it may be provided directly or through third parties.

These requirements translate into the obligation to guarantee personalised, multi-channel service, allowing customers to use at least the same channel through which the contractual relationship began. In any event, service must be ensured, as a minimum, by post, telephone and electronic means.

The various service channels must be free of charge, easily accessible and universally comprehensible, and their information must appear clearly and prominently in contracts, bills and on the corporate website. In the electricity sector, these obligations are coordinated with those already provided for in the LSE, which requires distributors and retailers to make free service telephone lines and permanent services available for managing incidents related to continuity of supply.

Another of the most relevant aspects of the LSAC is the reinforcement of the customer’s right to personalised service, provided by a human operator with appropriate training in the sector. Automated systems, such as answering machines or chatbots, cannot be the sole means of service and must always offer the possibility of reaching a human operator.

The law also strengthens customers’ linguistic rights, an aspect especially relevant for companies operating in autonomous communities with their own official language. In these cases, the handling, processing and resolution of queries, complaints, claims and incidents must be carried out in the language in which the customer began the communication, both in oral and written interactions.

In telephone service, the LSAC introduces particularly demanding quality standards, notably the so-called 95/3 rule, under which 95% of calls must be answered by a human operator within less than three minutes.

To this are added other relevant obligations, such as the prohibition on cutting off communications owing to long waiting times, the customer’s right to request transfer to a supervisor during the same call, the prohibition on diverting calls to premium-rate numbers, the limitation of the call cost to a basic rate, and 24-hour, 365-day availability for incidents relating to the continuity of electricity supply.

Handling and resolution of queries, complaints, claims and incidents

The LSAC introduces a strengthened regime on handling and resolution deadlines, which in the energy sector must be interpreted systematically alongside the electricity-sector rules set out in Royal Decree 1955/2000.

As a general rule, queries, complaints, claims and incidents submitted by customers must be the subject of an express, reasoned and complete resolution within a maximum of fifteen working days from submission, with generic or standardised responses being expressly prohibited.

In particular, claims relating to billing or improper charges are subject to a resolution period of 5 working days, while queries relating to continuity of electricity supply are subject to an immediate-service regime of 2 hours. In these cases, distributors and retailers must provide the customer with sufficient information on the causes of the interruption or incident and the estimated time for restoring supply.

Likewise, in situations of mass incidents affecting a significant number of users, the LSAC reinforces the information obligation, requiring it to be provided simultaneously, in an updated and accessible manner, to all affected customers, through the company’s usual communication channels and guaranteeing, in any case, alternative formats for users who do not use digital means.

SAC evaluation, audit and control systems

The LSAC imposes the obligation to implement an annual system for evaluating the quality level of the SAC, which must be duly documented, kept for a minimum of five years and subjected to periodic audits carried out by entities accredited by ENAC, in order to verify the reliability of the measurements and ensure that the margin of error does not exceed 5%.

The results of these evaluations and their corresponding audit reports must be public and accessible through the company’s corporate website. For smaller companies, the evaluation and audit may be carried out every two years.

Penalty regime

Non-compliance with the obligations under the LSAC is generally penalised as a consumer-law infringement. However, where the same conduct is punishable under both the LSAC and the electricity-sector rules, the Electricity Sector Act applies on a preferential basis, with its penalties for serious or very serious infringements reaching amounts of up to 60 million euros, far exceeding the general limits of consumer rules.

Conclusion

The LSAC thus transforms the Customer Service from an administrative cost centre into a strategic pillar of technical quality and regulatory compliance. For electricity retailers and distributors, adapting to this new framework requires a profound rethink of operational processes, integrating personalised service, traceability and accessibility as key performance indicators (KPIs) subject to control and audit.

Beyond regulatory compliance and the mitigation of penalty risk, an effective implementation of these standards represents a real competitive opportunity in an increasingly demanding energy market, reinforcing trust, corporate reputation and customer loyalty.

Related reading: electricity retail, commercial phone calls and electricity distribution.