The CAE system: from the obligation to save energy to the opportunity to generate value. Thierry Rodier, September 2026

For years, energy efficiency has been perceived by many companies as an obligation associated with regulatory compliance or corporate sustainability policies. However, in a context marked by the volatility of energy prices, competitive pressure and the decarbonisation objectives set by the European Union, it has come to occupy a clearly strategic position.

The reason is simple: today energy savings no longer only reduce operating costs, but can also become an economic asset capable of generating additional income for those who make the investment.

From avoided cost to economic asset

The European Union has placed reducing consumption among the pillars of its climate strategy: Article 7 of the Energy Efficiency Directive obliges Member States to achieve cumulative final energy savings over the decade. To contribute to this objective, Spain launched, through Royal Decree 36/2023, the Energy Savings Certificate System (CAE), within the framework of the National System of Energy Efficiency Obligations and as an alternative, in whole or in part, to the National Energy Efficiency Fund.

The underlying novelty is that the system transforms the savings achieved into an asset with market value. In other words, an action that demonstrably reduces energy consumption can generate an additional economic return, beyond the savings on the bill itself. And unlike subsidies – subject to calls for proposals and limited public budgets – this opportunity is directly linked to the results obtained.

A transversal opportunity for all sectors

One of the most valuable features of the CAE system is its scope. The possibility of monetizing savings extends to industry, the tertiary sector, the residential sector and transport.

In the industrial field, opportunities range from process optimisation to the replacement of equipment or the improvement of thermal and electrical installations. In the tertiary sector, air conditioning, lighting or energy control can translate into significant savings. The residential sector offers great potential through aerothermal energy, improved insulation or the renovation of the envelope. And transport has established itself as one of the sectors with the greatest potential, both in terms of the installation of telemetry and monitoring systems in fleets and the electrification of vehicles.

This diversity shows that CAE is a cross-cutting tool, capable of promoting the energy transition and bringing its benefits closer to companies, administrations and citizens.

The real challenge: turning savings into certificates

Despite its potential, the CAE market faces two barriers to its mass deployment.

The first is ignorance. Many companies are unaware that the system is retroactive: an investment (capex) executed in the last three years can continue to generate certificates today, as long as the action meets the technical criteria and the documentation that accredits it is preserved. In other words, actions already carried out can translate into an additional return that, in many cases, was never requested.

The second is technical and documentary complexity. Royal Decree 36/2023 requires that savings be calculated with a certain methodology, justified with solid evidence and verified through an accredited entity, with documentation that must meet all the established requirements. It is an essential requirement to guarantee the credibility of the system and the traceability of the results, but it also raises a barrier of specialized knowledge that few organizations can assume on their own.

The role of the delegated subject

To bridge this gap between the potential savings and the certificate issued, the regulations created the figure of the delegated subject: an entity that assumes by delegation part of the objectives of the obliged subjects and that promotes or executes the actions, taking charge of the technical and administrative burden of the process.

At Grecert, as a delegated entity, we see that the largest volume of certifiable savings comes from actions that companies have already carried out, but whose economic value they have never put into circulation. When an engineering team qualifies the action, calculates the savings according to the official methodology and builds a file that is one hundred percent defensible before the regulator, an investment already made becomes an additional source of income. Depending on the type of action, CAEs can offset between 25% and 100% of the capex of the associated investment.

Reducing barriers to access is, therefore, the decisive lever. When technical support is combined with a model that does not require prior disbursement and that only remunerates based on results, the system is democratized: numerous actions that can be certified emerge that would otherwise be left out of the market.

This is especially relevant for SMEs, which represent an essential part of the Spanish economic fabric and have enormous untapped savings potential, but which tend to have fewer technical and administrative resources to address certification processes. Facilitating their access – by simplifying procedures and accompanying them from start to finish – is key to accelerating the adoption of the mechanism and extending its benefits.

A strategic tool for decarbonization

Energy efficiency is one of the most cost-effective ways to move towards a sustainable economic model: it reduces costs, improves competitiveness, reduces energy dependence and cuts emissions.

Energy Savings Certificates also add an economic dimension that accelerates decision-making and increases the return on investment.

That is why the success of the system should not be measured only by the number of certificates issued, but by its ability to mobilise new actions, attract investment and spread a true culture of efficiency. In short, the CAE system makes it possible to transform a regulatory obligation into a competitive advantage. The greater the knowledge of the mechanism, and the more accessible it is to companies and individuals – hand in hand with the right partner – the greater its contribution will be to a more efficient, sustainable and competitive economy, fully aligned with decarbonisation objectives.

At Grecert we want to help this potential materialise. We invite the companies and organisations that are members of the Business & Climate Foundation to contact us to analyse their specific case: we can prepare, at no cost, a simulation of the economic impact that the CAE system would have on their investments.

Thierry Rodier
CEO, Grecert Iberia S.L.
Grecert Iberia is a member of the Business & Climate Foundation.