Requirements and deadlines to process a CAE.

35From what date do actions count?

Only actions whose execution started after 26/01/2023 (the entry into force of RD 36/2023) and before 01/01/2031 can be certified. Actions already completed or under way can be certified if they fall within that window.

36What is considered the "execution start date"?

The earliest of: (1) the start of the works or building work, and (2) the first firm commitment to order equipment or any other commitment that makes the investment irreversible (Orden TED/815/2023, art. 14.9.j).

37What is the maximum deadline to process after execution?

A CAE can be registered up to 3 years after the action is carried out (RD 36/2023, art. 11.5). Note: the CAE's validity is also 3 years from the end of execution (or until 31/12/2030, whichever comes first), so processing it late reduces its commercial useful life.

38Can I sign the agreement before carrying out the work?

Yes, and it is the recommended practice: the CAE agreement secures the "incentive effect" of the action. What is not possible is to sign agreements dated before 26/01/2023, because the system did not exist.

39Is it mandatory to sign the cession before starting the work?

The regulation does not formally require a signature before the start in all cases, but the agreement must guarantee the traceability of ownership and consideration, and the consideration must be certain (in €/kWh). In practice, SDs require the signature before or very close to execution; signing beforehand avoids additionality problems and ownership disputes.

40Must the old equipment that was replaced be evidenced?

Yes, when the datasheet requires it (which is usual for replacements): photographs of the removed equipment, the rating plate and, where applicable, proof of removal/scrapping, as each datasheet stipulates.

41What technical requirements must the new equipment meet?

Those set by the applicable datasheet: minimum efficiencies (SCOP/SEER, energy class), power ratings, product regulations. If the equipment does not reach the datasheet's minimums, the action cannot be certified through that route.

42Must the installation be legalised with the Industry authority?

Yes: each datasheet's documentation usually includes the installation certificate (RITE, REBT…) and the verifier and the regional manager check that the action complies with the applicable regulations. An installation that is not legalised will struggle to pass verification.

43Can I process a self-installation?

The saving must be documented with an invoice and certificates from a licensed installer when the regulations require it (RITE, REBT). Without a licensed installer and invoice, in practice the case file is not viable.

44Must the installer be licensed?

Yes, it must be a company licensed/registered for the type of installation (thermal, electrical, refrigeration), since its certificates form part of the case file.

45How long is a CAE valid? Does it expire?

Yes: it expires 3 years after the completion of the action's execution, or on 31/12/2030, whichever comes first. Once expired, it cannot be sold or settled (Orden TED/815/2023, art. 17.1).

46Which saving counts: the annual one or that of the entire useful life?

Only the final energy saving achieved in one year (annual saving), not the amount accumulated over the useful life. The declared useful life is used for reporting to the European Commission and as a commitment to maintain the measure.

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.