Quién es quién en el ecosistema de los CAE: los actores del sistema de Certificados de Ahorro Energético
We continue with the CAEs. In a previous post, we explained what Energy Savings Certificates are and how a company can access them; if you missed it, we recommend reading it before continuing. Today it is time to clarify who participates in this entire system: what role each actor plays and how your company can obtain CAEs.
Obligated parties
These are the energy companies obliged by law to achieve certain energy savings figures each year. This includes gas and electricity retailers, and wholesale operators of petroleum products or LPG. These companies are subject to environmental impact reduction regulations and can meet their obligations by acquiring CAEs, or generating their own, or by contributing to the National Energy Efficiency Fund through payments.
Delegated parties
These are legal entities, public or private, that can assume, in whole or in part and on behalf of one or more obligated parties, the acquisition of new annual energy savings. This figure is defined in Royal Decree 36/2023, which regulates the Energy Savings Certificates system.
In practice, a delegated party is a company that helps obligated parties to obtain CAEs, committing to settle a certain amount of certificates on their behalf each year. This group would include Energy Service Companies (ESCOs), qualified to develop energy efficiency projects in different sectors and generate certifiable savings, as well as other public and private entities that can carry out savings measures, certify them, and sell them: hospitals, universities, town halls, or non-obligated private companies.
To act as a delegated party, a company must meet several requirements. It must have been accredited by the National Coordinator of the CAE System. In no case does it assume the annual emission reduction obligation of the obligated party. It is, alongside the obligated parties themselves, the only accredited figure to participate in the auction mechanism called by the State Secretariat for Energy. And those legal entities participating, directly or indirectly, in the design, organization, or management of the CAE system cannot be accredited as delegated parties.
All requirements and obligations of delegated parties are set out in article three of Order TED/815/2023, and the application to be accredited as such can be made through the electronic headquarters of the Ministry for the Ecological Transition and the Demographic Challenge.
Savings owner
This is the person or entity that has made the investment in one or more energy efficiency actions capable of generating savings transformable into CAEs. They can transfer that ownership to a third party in exchange for consideration.
End user
This is the person who obtains the positive impact of one or more energy efficiency actions. In most cases, they are the original owner of the savings.
And on behalf of the Administration, who intervenes?
Beyond the Ministry for the Ecological Transition and the Demographic Challenge, there are other key actors for the system to function correctly.
Regional administrators. These are the entities responsible for managing the CAE system at the regional level: they check and validate applications for obtaining CAEs, issue the favorable report with the number of certificates corresponding to the annual savings achieved, and register them in the National Registry of the CAE System. They are the first line of contact for obligated parties and, above all, for delegated parties.
National Coordinator of the CAE System. This is the administrative body that designates delegated parties and ensures that the system functions correctly as a whole. Its functions correspond to the Directorate-General for Energy Policy and Mines of the Ministry for the Ecological Transition and the Demographic Challenge, according to Royal Decree 36/2023.
Energy savings verifier. This is the entity accredited by ENAC, the National Accreditation Body, responsible for reviewing that the action has been executed correctly and that the declared savings are real.
How to become a delegated party
If your company wants to take the step and become a delegated party to directly access the acquisition of CAEs, these are, in broad terms, the requirements demanded by the regulations.
Regarding technical requirements: having on staff at least 6 professionals with EQF level 6 or higher with technical training, of which at least 2 must have 3 years of experience in energy efficiency; having at least 2 professionals with EQF level 6, with training in law, business administration, economics, or related disciplines, at least one of them with more than 3 years of experience; or, alternatively, being able to accredit the status of delegated party in another country of the European Union for at least 3 years, or having 8 professionals with EQF level 6. In addition, they must hold ISO 9001 certification covering the activity of delegated party.
Regarding economic-financial requirements: not having debts with the Administration or having declared bankruptcy, having own funds of at least 0.5 million euros, and being able to prove more than three years of experience in the sector, a turnover of more than one million euros, and civil liability insurance of at least one million euros. If the turnover does not reach one million euros, the same experience is valid along with civil liability insurance of at least two million euros.
The CAE system remains in force today, regulated by Royal Decree 36/2023 and developed each year through a ministerial order that sets the corresponding savings obligations. Knowing who is who in this ecosystem well is the first step to knowing where to start if your company wants to take advantage of its energy efficiency actions.
Do you want to know how Smarkia can help you obtain more CAEs thanks to remote management and the automation of your facilities? Write to us and we will explain it to you in detail.