The Energy Performance Certificate in Spain in 2026: what owners need to know

A practical guide to the certificado de eficiencia energetica for anyone selling, letting or renovating Spanish property.

Yes. If you sell or let almost any property in Spain you need a valid Energy Performance Certificate (EPC, certificado de eficiencia energetica). The obligation has applied to sales and new tenancies since 1 June 2013, now governed by Real Decreto 390/2021 in force since 3 June 2021. The certificate rates the building A to G, is issued by a qualified tecnico competente, and must be registered with your autonomous community. A copy goes to the buyer or tenant; the rating goes in every listing. A significant amendment, Real Decreto 659/2025, enters into force on 23 July 2026 and broadens who can certify, creates a centralised technician registry, and introduces two-phase certification for new builds.

When is an EPC mandatory in Spain?

The EPC is mandatory whenever a building or part of a building is sold or let to a new tenant, and for all new builds and major reforms. Article 3.1 of RD 390/2021 also extends it to public-administration buildings over 250m2, commercial premises over 500m2, and any property due an obligatory Technical Building Inspection (ITE).

The core trigger for a private owner is Article 3.1.b: any existing building or part of a building that is sold or let to a new tenant needs a valid certificate. New buildings (3.1.a) and buildings undergoing substantial reforms (3.1.d) also need one. A “substantial reform” means a thermal-system replacement that requires a new installation project, an intervention affecting more than 25 per cent of the building’s thermal envelope, or an extension that increases surface or volume by more than 10 per cent and adds over 50m2.

One point that catches holiday-let owners: the Ministerio para la Transicion Ecologica confirms that RD 390/2021 deleted the old exclusion for dwellings used under four months a year. Any dwelling let to a new tenant, including tourist lets, must be certified from 3 June 2021, and tourist apartments treated as a service-sector use had to obtain the certificate and display the label by 3 June 2022. This sits alongside the broader Costa del Sol short-let rules that govern registration and community approval.

A renewal of an existing tenancy with the same tenant does not require a new certificate, because the law triggers on a “new tenant”, not on contract continuation.

Which buildings are exempt?

The exclusions are narrow and set out in Article 3.2: protected historic buildings where efficiency work would spoil their character, temporary structures built for two years or less, low-demand industrial and agricultural sheds, and detached standalone buildings under 50m2. A property bought for demolition can be exempted, but only via a formal declaration to the autonomous community.

The standalone-under-50m2 exemption applies only to physically detached buildings. A flat or shop of less than 50m2 that sits inside a larger block is still certifiable, because it is not “independiente”. Garages and storage rooms are excluded from the calculation regardless of size, because the certificate only measures habitable space. A buyer who plans to demolish and rebuild must file a declaracion responsable with the autonomous community to claim the demolition exemption, otherwise the obligation stands.

What does the A to G rating actually measure?

Spain uses a single A-to-G letter scale for both new and existing buildings, with A the most efficient and G the least. The IDAE confirms the classification runs from class A for the least energy-consuming buildings to class G for the most consuming, and the same scale applies to CO2 emissions. The Ministry for the Ecological Transition (MITECO) confirms there is one scale, though the underlying calculation varies by climate zone and by whether the building is new or existing.

The rating is relative, not absolute. The building’s calculated energy consumption and CO2 emissions are compared to those of a reference building of the same type in the same climate zone, as defined in the Codigo Tecnico de la Edificacion, Documento Basico de Ahorro de Energia (CTE DB-HE). The letter depends on the ratio between the building’s performance and the reference, not on a fixed kWh per square metre threshold. This means a Costa del Sol apartment rated B is not directly comparable on absolute consumption to a Madrid apartment rated B, because they sit in different climate zones with different reference buildings. The scale exists to compare like with like within a climate zone, not across regions.

The label is the coloured graphic (green for A, red for G) that appears in every property advertisement. Article 15 of RD 390/2021 gives the certificate holder the right to use the label for the whole validity period, and Article 15.2 makes its inclusion in any offer, promotion or advertising directed at the sale or rental of the building compulsory. Displaying a fake or non-matching label is expressly prohibited.

The recommendations section is not boilerplate. It sets out the cost-effective improvement measures the technician identified for that specific building, which is where the certificate connects to the grant landscape covered in our energy renovation subsidies guide.

Which Spanish property archetypes typically sit in each rating band?

The rating is relative to a reference building, so the letter a property receives depends on its climate zone, its orientation, its envelope, and its systems. Still, certain archetypes tend to cluster in specific bands because of how Spanish construction evolved. The table below maps the typical profile of each letter to the construction periods and characteristics that produce it.

Band	Typical Spanish property archetype	What drives the rating
A	New-build nZEB (nearly zero-energy) buildings certified under the current CTE DB-HE, with heat pumps, solar thermal, and high-performance envelope	Well-insulated envelope, renewable systems, low primary energy use well below the reference
B	Recent rehabilitado (post-2013 retrofit) with upgraded insulation, double glazing, and efficient HVAC	Better-than-reference envelope and systems, often after a substantive renovation
C	2000s to early 2010s build with double glazing and individual gas or aerothermal heating	Moderate envelope performance, standard systems of the era
D	Standard 1990s to early 2000s build, cavity walls, single or early double glazing, individual electric or gas heating	Around the reference building performance, typical of the pre-CTE tightening era
E	1980s build with partial insulation, single glazing, older individual systems	Below reference on envelope and systems
F	Pre-1979 uninsulated build, single glazing, no central heating or old electric storage heaters	Significantly below reference, minimal thermal envelope
G	Pre-1979 build with no insulation, single glazing, and no modern heating or hot water system	Worst-performing stock, highest consumption relative to reference

The F and G bands matter beyond the certificate itself. Under the recast Energy Performance of Buildings Directive (Directive 2024/1275), the EPC is the entry point to the minimum energy performance standards that apply to the worst-performing residential stock. The directive, covered in detail in our EPBD retrofit obligations guide, requires member states to renovate the worst-performing homes first: at least 55 per cent of the required energy-use reduction by 2030 must come from renovating the worst-performing buildings, broadly the lowest two EPC classes in each member state. The EPC letter is how a building is identified as part of that cohort, which is why the G-rating five-year validity cap (below) exists alongside the broader retrofit trajectory.

Who can issue an EPC?

Only a tecnico competente as defined in Article 4 bis of RD 390/2021. Under the current text, that means a professional holding a habilitating qualification to draft or direct building works under the Ley 38/1999 de Ordenacion de la Edificacion, or an equivalent university degree. They must file a declaracion responsable with the autonomous community and visit the property within three months of issuing the certificate.

The “tecnico competente” is typically an architect, technical architect (arquitecto tecnico) or a building-services engineer. Before taking on any job the technician must have submitted a declaracion responsable to the energy-certification body of the autonomous community where their fiscal domicile sits (Article 4 ter). That declaration enables them to practise across all of Spain with no further local tramite. Article 6.5 requires at least one site visit within three months before the certificate is issued, so a certificate produced without anyone visiting the property is not valid.

From 23 July 2026, Real Decreto 659/2025 broadens this definition significantly. The amended Article 4 bis introduces four routes to becoming a tecnico competente: (a) holders of habilitating university qualifications under the LOE, as before; (b) holders of other university degrees in architecture, industrial engineering, electrical engineering, chemical engineering, or related fields, provided they complete Module 2 of an approved training course; (c) holders of university degrees in environmental sciences, physics, mathematics, chemistry, or related fields, provided they complete both Modules 1 and 2; and (d) holders of Formacion Professional de Grado Superior qualifications, Certificados Profesionales, or Cursos de Especializacion de nivel 3 whose competence definition specifically includes building energy certification, also requiring both training modules. The amendment also creates a centralised Registry of Competent Technicians (Article 7 bis) under the Dirección General de Planificacion y Coordinacion Energetica, transposing Article 25 of Directive 2024/1275.

How long is the certificate valid?

Article 13 sets a maximum validity of 10 years for ratings A to F, but only 5 years for a G rating. The owner is responsible for renewal, and the autonomous community sets the specific conditions. A certificate is only legally valid once it has been registered with the community’s energy-certification body, normally within one month of issue.

The G-rating five-year cap is a tightening introduced by RD 390/2021. Certificates registered before 3 June 2021 under the old RD 235/2013 keep their original 10-year term for ratings A to F, provided the building has not changed in a way that lowers its rating. The owner can voluntarily update the certificate at any time if they have improved the building’s envelope or systems and want a better letter.

What must the seller or landlord hand over?

Article 17 requires the seller to annex a registered copy of the certificate and its label to the sale contract; a landlord must annex the label to the rental contract and give the tenant a copy of the Recommendations for Use document. Crucially, Article 17.3 makes any platform, agency, portal or press listing that advertises a property include its energy rating.

This is the operational rule that turns the certificate from a paper formality into a transaction document. For a sale, the registered certificate copy travels with the escritura; for a tenancy, the tenant receives the label and the use-recommendations leaflet. The advertising rule in 17.3 covers estate agencies, portals, printed catalogues and billboards alike, which is why every Spanish property listing now carries the coloured energy letter.

What does an EPC cost?

The fee is not fixed by any statutory tariff; it is a liberalised market price set by the certifying technician and scaling with floor area and building complexity. It is a modest, one-off professional cost, not a recurring charge, and a renewal or update of an existing certificate is typically cheaper than the first issue because the technician already holds the building data.

What are the penalties for non-compliance?

Penalties sit in the Ley de Suelo y Rehabilitacion Urbana (RDL 7/2015, additional provisions 12 and 13). Light breaches carry EUR 300 to 600; grave breaches EUR 601 to 1,000; very grave breaches EUR 1,001 to 6,000. Selling or letting without handing over a valid registered certificate is grave; advertising a rating not backed by one is very grave.

Infringement class	Fine range	Examples
Light (leves)	EUR 300 to 600	Advertising a listing without the rating; not displaying the label where mandatory; failing to renew an expired certificate
Grave (graves)	EUR 601 to 1,000	Selling or letting without delivering a valid registered certificate; not registering the certificate; displaying a label that does not match the certificate
Very grave (muy graves)	EUR 1,001 to 6,000	Falsifying information in issuance or registration; acting as a certifier without the required qualifications; advertising a rating not backed by a valid registered certificate

The fine can exceed the cap where the benefit obtained from the breach is greater than the sanction, a rule in additional provision 13.2. Repeat offenders are pushed up a class: a light breach within a year of a prior firm sanction becomes grave, and a grave breach within three years becomes very grave.

How does the EPC fit into a Spanish property sale?

The EPC is one document in a stack a seller must assemble. It sits alongside the nota simple from the Land Registry, the community-debt certificate issued under Article 9.1.e of the Ley de Propiedad Horizontal, and the buyer’s independent legal checks set out in our due diligence checklist. The full selling sequence, from reservation to notary, is walked through in the selling property in Spain guide, and anyone planning a refurbishment to lift the energy letter should read the cost framework in our building or renovating a villa guide.

The practical read for a Costa del Sol owner is straightforward: book a tecnico competente early, because the site visit and the autonomous-community registration together take time, and a sale cannot complete without a registered certificate annexed to the escritura. A property advertised without its rating is a light infringement waiting to be spotted; a property sold without delivering the certificate is a grave one. With RD 659/2025 entering into force on 23 July 2026, the pool of certifying technicians will widen, but the core obligation on the owner is unchanged.