Obligated Parties, Delegated Parties and verifiers.

89Who are the Obligated Parties and what is their obligation in 2026?

Electricity and gas retailers and wholesale operators of petroleum and LPG (Ley 18/2014, art. 69). The list is published in the annex to the annual order. For 2026 (Orden TED/133/2026): a target of 810 ktep (~9,420 GWh) and the option to meet up to 92% through CAE. An SO with an annual obligation < 50 MWh cannot request issuance but can buy and settle CAE.

90How is a Delegated Party accredited?

An online application to the National Coordinator (MITECO electronic office) evidencing: its own legal personality (not a UTE), a permanent establishment in Spain, equity > €500,000 in the last two financial years, ISO 9001, civil-liability insurance or a guarantee covering the activity as an SD, qualified technical staff on the payroll and experience (e.g. invoicing ≥ 1 M€ over 3 years in energy efficiency). If equity falls below €500,000, accreditation is lost.

91Where can I find the list of Delegated Parties?

In the "CAE System Agents" section of MITECO's website, together with the lists of verifiers and regional managers.

92What role does the National Coordinator play?

It is the Directorate-General for Energy Planning and Coordination (MITECO): it accredits SDs, manages the National CAE Registry, performs the final registration, accepts transfers and settlements, and supervises the system (RD 36/2023, art. 16).

93Who can be a verifier?

Legal entities accredited by ENAC in accordance with its protocol, for the scopes (standardised/non-standard and sectors) listed in their accreditation. An SO or SD cannot be a verifier (nor have been one in the previous 3 years).

94Can an SO combine CAE and payment to the FNEE?

Yes, freely, respecting the minimum contribution to the FNEE set by the annual order (8% in 2026). The FNEE part is paid in 4 equal quarterly instalments; the CAE part can be settled over the course of the year, by 31/12 at the latest (with the transitional rule: CAE requested before 1/12 can be settled until the following 1/3).

Main sources: official FAQ of the CAE System, MITECO v1.6 (23/04/2026); Real Decreto 36/2023; Orden TED/815/2023; Orden TED/845/2023; Orden TED/133/2026; 2026 market references. This text is informational and has no legal value; the applicable regulations always prevail.