How the DGT's position has evolved
Current position
Homeowners may apply the deduction for energy rehabilitation works by certifying, through an energy efficiency certificate, a reduction in non-renewable primary energy consumption of at least 30% or an improvement in the rating to class "A" or "B". To certify the improvement, it is necessary to compare the certificate issued after the works with one issued prior to their commencement, which must have been registered in accordance with Royal Decree 390/2021 and must not be more than two years old relative to the start of the works.
The DGT's position remains constant regarding the substantive requirements of the deduction, such as the reduction in consumption or the improvement in rating. The evolution focuses on technical precision regarding the accreditation of prior energy efficiency, specifying the validity of old certificates and the need for registration in accordance with Royal Decree 390/2021.
Turning points
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Establishes the obligation to compare the subsequent certificate with one issued before the start of the works, preventing the use of certificates issued after execution to certify the prior situation.
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Specifies that the prior certificate to certify efficiency is valid as long as it has been registered in accordance with Royal Decree 390/2021.
Analysis based on 43 of 49 rulings with a stated position. Updated 18 September 2026.