CAE system · Frequently asked questions
Processing, verification and issuance of the CAE.
How a case file progresses from verification to the registration of the CAE in the National Registry.
- What are the steps of the full process?
- (1) Ownership: the SO/SD acquires the savings through a CAE agreement. (2) Verification: an ENAC-accredited verifier issues an opinion. (3) Issuance: the SO/SD requests issuance from the regional manager, which validates, issues and pre-registers it; the National Coordinator registers it in the National Registry. (4) Settlement or sale of the CAE. The owner is paid as agreed in the agreement.
- Who submits the issuance application?
- Only an SO (with an obligation ≥ 50 MWh that year) or an SD, through its legal representative, via MITECO's electronic office while the platform under art. 20 of the RD is not operational. Neither the customer nor the installer can submit it directly.
- What is the verifier and when does it intervene?
- An independent body accredited by ENAC that verifies the savings and the documentation. It always intervenes: every action included in an issuance application needs a favourable opinion (Orden TED/815/2023, arts. 13-14). The SO/SD chooses it freely from among those accredited for that type of action.
- Does verification also apply to standardised actions?
- Yes. The difference is that for grouped standardised actions there is a single opinion for the whole set, and verifiers may be accredited only for standardised actions or also for non-standard ones in certain sectors.
- To whom is issuance requested?
- To the regional manager of the community where the action was carried out. If the action goes beyond the scope of a single CCAA, the National Coordinator issues it (art. 15.6).
- And for mobility actions?
- It is submitted by selecting the CCAA of the (registered or habitual) address of the original owner of the saving; for shared mobility (datasheets TRA030/TRA040), that of the platform's registered office.
- How long does issuance take?
- There is no single guaranteed timeframe: it depends on the regional manager and the quality of the case file. In practice, between weeks and several months, adding up verification, regional validation and national registration.
- How do I check the status of the case file?
- Through the SO/SD that processes it (it is the holder of the application) and, for your own applications, in the "Personal area" of MITECO's electronic office. The end customer has no direct access: their point of contact is whoever signs their agreement.
- What happens if rectification is required?
- The verifier or the regional manager will report the defects and give the option to rectify them. If they are not rectified or are dealt with inadequately, the opinion will be unfavourable and issuance cannot be requested for that action (RD 36/2023, art. 12.4).
- Can they inspect after the CAE has been issued?
- Yes. The system provides for control and monitoring, and the applicant undertakes to maintain the measure throughout its useful life; the National Coordinator can refuse registration if it detects irregularities.
- And if the actual saving is less than declared?
- If detected before the opinion, rectification will be required or an unfavourable opinion will be issued. The agreed consideration can be adjusted to the savings ultimately certified if the agreement provided for this (keeping the unit value €/kWh).
- Can an issued CAE be revoked?
- The final registration can be refused by the National Coordinator if it finds irregularities. Falsehoods or breaches can additionally lead to the penalty regime (Ley 18/2014) and contractual liabilities.
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.
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