The BOE of March 21, 2026 publishes Real Decreto-ley 7/2026, of March 20, approving Spain's Comprehensive Response Plan to the Middle East Crisis. With a total allocation of EUR 5 billion, it is the largest emergency package approved in Spain since the energy crisis of 2022.
Context
The armed conflict in Iran and the closure of the Strait of Hormuz have triggered a surge in international energy prices that threatens to feed through to the Spanish economy via energy inflation, higher transport costs, and a contraction in industrial activity. The Government invokes Article 86 of the Constitution (extraordinary and urgent necessity) to approve a package with a dual character: an immediate economic shield and an acceleration of the energy transition as a structural response.
Fiscal measures
VAT
- Electricity (contracts ≤10 kW): reduced rate of 10% (previously 21%) until June 30, 2026.
- Natural gas, biomass, and pellets: reduced rate of 10% until June 30, 2026.
- Fuels: reduced rate of 10% until June 30, 2026.
Special Electricity Tax (Impuesto Especial sobre la Electricidad)
Extraordinary reduction of the rate from 5.11% to 0.5% until June 30, 2026. Minimum thresholds: EUR 0.50/MWh (professional use) and EUR 1.00/MWh (other uses).
Hydrocarbon Tax (Impuesto sobre Hidrocarburos)
Rates reduced to the minimum permitted under Directive 2003/96/EC for diesel, unleaded petrol, fuel oil, LPG, natural gas, and kerosene. No express end date: remains in force until aligned with the directive.
Electricity Production Value Tax (Impuesto sobre el Valor de la Producción Eléctrica)
- Q1 2026: 10% exemption on revenue.
- Q2 2026: 100% exemption on revenue.
IRPF (Personal Income Tax)
- Extended deadline for the deduction on residential energy efficiency improvements.
- Extended deductions for solar self-consumption installations.
- Renewal of incentives for the purchase of electric and hydrogen fuel-cell vehicles.
Impuesto sobre Sociedades (Corporate Income Tax)
- Maintained accelerated depreciation for renewable self-consumption installations.
- Maintained incentives for investment in electric vehicle charging infrastructure.
Labor measures
Dismissal ban
Companies receiving direct aid under the plan may not carry out dismissals for force majeure or for ETOP reasons (economic, technical, organizational, or production grounds) linked to the crisis until June 30, 2026. Worker cooperatives are likewise prohibited from approving headcount-reduction agreements under the same conditions. Non-compliance obliges full repayment of all aid received.
Mandatory mobility plans
The implementation deadline for sustainable mobility plans in companies and public bodies is accelerated from 24 to 12 months. Plans must cover: active mobility, public transport, low-emission options, shared transport modes, and remote working.
COVID-year losses
Losses from fiscal years 2020 and 2021 are excluded from the calculation of the dissolution-by-losses trigger during 2026. Companies are permitted to restate their annual accounts within one month, with a general meeting to be held within the following three months.
Energy measures
Social bonuses
- Electricity social bonus: extraordinary discounts extended until December 31, 2026.
- Thermal social bonus: increase in the minimum amount and an additional allocation of EUR 90 million.
- Supply guarantee: protection extended until December 31, 2026 for vulnerable consumers (water and energy).
LPG price cap
Cap on the maximum retail price of bottled butane gas until June 30, 2026.
Energy-intensive industry (electro-intensive)
Reduction of grid access tolls to preserve the competitiveness of industrial sectors with high energy consumption.
Sector-specific measures
Road transport
- Rebate of EUR 0.20/liter of diesel for companies entitled to a hydrocarbon tax refund (February – June 30, 2026).
- Extraordinary direct aid for hauliers not entitled to a tax refund (VDE, VT, VTC, urban buses).
- ICO guarantee program for the sector: up to EUR 2 billion in bank guarantee coverage.
Agriculture and livestock
- Extraordinary temporary aid for agricultural diesel costs.
- Compensation for the increase in fertilizer prices.
- Extension of the ICO-MAPA-SAECA financing line.
Fishing
- Compensation to vessel owners for increased fuel and electricity costs.
- Exemption from the first-sale levy on fresh fish.
Foreign trade
- ICEX authorized to refund participation fees for trade fairs cancelled due to the crisis.
- Additional compensation for unrecoverable expenses.
Structural measures (renewable energy)
RDL 7/2026 includes an extensive title of permanent reforms to the energy regulatory framework:
- Renewable Acceleration Zones (Zonas de Aceleración Renovable — ZAR): national framework for designating zones with priority permitting.
- Collective self-consumption: maximum generation-to-consumption distance extended to 5 km; new “self-consumption manager” figure introduced.
- Mandatory benefit-sharing: electricity producers must transfer a portion of profits to nearby citizens and communities.
- Data centres: new requirement to offset consumption with equivalent renewable generation.
- Green hydrogen: temporary supervisory powers assigned to the gas regulator (CNMC) for projects under the H2MED corridor.
- Industrial Decarbonization Fund: renamed from FERGEI; primary instrument: Carbon Contracts for Difference.
- Auto+ Program: EUR 400 million in incentives for the purchase of electric vehicles.
Key dates
| Measure | In force until |
|---|---|
| Reduced VAT (energy, fuels) | June 30, 2026 |
| Special Electricity Tax at 0.5% | June 30, 2026 |
| Dismissal ban | June 30, 2026 |
| Diesel rebate for transport | June 30, 2026 |
| LPG price cap | June 30, 2026 |
| Electricity social bonus | December 31, 2026 |
| Vulnerable consumer supply guarantee | December 31, 2026 |
| Mobility plans | Permanent (12-month rollout) |
| ZAR, self-consumption, hydrogen | Permanent |
What your business should do now
- Review your energy invoices: the 10% VAT rate and the 0.5% electricity tax apply automatically, but it is worth verifying that your suppliers are reflecting them correctly.
- Check whether you are receiving public aid: if so, the employment safeguard clause prohibits dismissals until June 30.
- Launch your sustainable mobility plan: the deadline has been cut to 12 months and non-compliance triggers repayment of associated aid.
- Assess deductions under IRPF and Impuesto sobre Sociedades: the new deductions for energy efficiency, self-consumption, and electric vehicles may reduce your tax burden for the year.
- Transport sector: apply for the EUR 0.20/liter diesel rebate and assess the ICO guarantee line.
At BMC we are analysing the detailed impact of each measure by sector. Contact our team for a personalised assessment.
Regulatory Framework: Key Legal Instruments of RDL 7/2026
Understanding the legal architecture of RDL 7/2026 matters for businesses seeking to apply the measures correctly and to assess their durability.
Constitutional basis (Article 86, Constitución Española): Real Decreto-ley 7/2026 is approved by the Council of Ministers under the extraordinary and urgent necessity clause of Article 86 of the Spanish Constitution, which allows the Government to legislate by decree-law without prior parliamentary approval in situations of urgent necessity. This instrument must be ratified by Congress of Deputies within 30 days; failure to ratify causes the measure to lapse with retroactive effect. The ratification vote is therefore a critical date for businesses that have structured transactions or plans around the decree-law’s provisions.
VAT measures — interaction with Ley 37/1992 (Ley del IVA): The reduced VAT rates introduced by RDL 7/2026 operate as temporary modifications to the rate tables established by Ley 37/1992, the principal Spanish VAT statute transposing the EU VAT Directive (2006/112/EC). Suppliers who have already issued invoices at 21% for energy supplies during the period covered by the new 10% rate must issue rectifying invoices (facturas rectificativas) under Article 80 Ley 37/1992 and Article 15 of the Reglamento de Facturación (RD 1619/2012). Failure to issue rectifying invoices constitutes incorrect VAT invoicing under Article 203 Ley General Tributaria.
Labour measures — interaction with Ley 32/2021 (reforma laboral) and Estatuto de los Trabajadores: The dismissal ban for companies receiving direct aid operates as a condition attached to aid receipt, not as an amendment to the substantive dismissal law (Arts. 51–52 ET). Companies must verify whether aid received from the Autonomous Communities, the State or via ICO guarantee lines falls within the scope of RDL 7/2026 “direct aid” — a question that may require advance consultation with the administering authority. The ban does not affect ERTEs (temporary employment regulation proceedings) initiated before RDL 7/2026 or unrelated to the Middle East crisis.
Energy structural measures — Ley 24/2013 (Ley del Sector Eléctrico): The Renewable Acceleration Zones (ZAR), collective self-consumption reforms and green hydrogen provisions operate as amendments or additions to Spain’s electricity sector framework law. Investors in renewable energy projects should verify whether their pipeline assets are located in areas likely to be designated as ZAR, which would significantly reduce permitting timelines and provide priority grid connection rights.
