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.
