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BOE-A-2026-14655 ·7 July 2026 ·Royal Decree Medium impact
Tax

Industrial companies at risk of carbon leakage: 3 months to adjust indirect cost compensation annex

Order PJC/678/2026 amends Annexes I, II, and III of Royal Decree 309/2022 to adjust the industrial sectors and subsectors affected by carbon leakage risk. Exposure criteria and compensation conditions for indirect costs derived from greenhouse gas emissions have been updated. This change allows for greater precision in cost allocation to affected sectors, in alignment with EU Guidelines (2020/C 317/04).

In 2 key points

  1. Annexes I, II, and III of RD 309/2022 are amended to adjust sectors exposed to carbon leakage (art. 1)
  2. Indirect costs derived from greenhouse gas emissions are compensated according to new exposure criteria (art. 2)

How it affects those involved

For industrial companies in sectors exposed to carbon leakage, the updated compensation criteria may directly affect operating costs. Competent authorities will be able to apply the new annexes with greater precision. Advisors should review their clients' exposure and verify whether they meet the new risk thresholds. Affected sectors must evaluate whether the new criteria impact their energy costs or financial planning.

Lifecycle

2026-07-07PublishedPublished in the BOE
2026-07-08Into forceComes into force (fecha_vigencia (indice oficial del BOE))
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BMC.
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