Spain has launched a renewed public consultation on the draft Royal Decree aimed at accelerating the decarbonisation of the transport sector and promoting the use of renewable fuels. The consultation is conducted under the national legal framework governing public participation in the preparation of regulations and seeks to gather the views of stakeholders potentially affected by the future rules. This second consultation follows an initial round held between July and September 2025 and reflects the technical complexity of the measure and the adjustments introduced after the first set of comments. The scope of this phase is deliberately limited, with a shortened submission period, in order to refine the final text before adoption.
European context and policy rationale
The draft Royal Decree is Spain’s main vehicle for transposing the revised Renewable Energy Directive, known as RED III, into national law. RED III strengthens the role of renewable energy across the EU and significantly raises ambition in the transport sector. By 2030, Member States must ensure that fuel suppliers either achieve a minimum share of 29 percent renewable energy in final transport consumption or deliver a reduction of at least 14.5 percent in greenhouse gas intensity. The Spanish proposal mirrors this approach and aligns it with other recent EU measures affecting aviation, maritime transport, gas markets and hydrogen, ensuring coherence across overlapping regulatory frameworks.
How the new transport decarbonisation framework is structured
The proposed framework is built around modal decarbonisation objectives covering road, rail, maritime and aviation transport. In the case of aviation, the draft explicitly recognises that binding supply obligations for sustainable aviation fuels are governed by the directly applicable ReFuelEU Aviation Regulation, and therefore avoids duplicating those requirements at national level. Alongside the modal targets, the Decree introduces specific sub-objectives for renewable fuels in transport, expressed in energy terms and differentiated by fuel type. These include advanced biofuels, biogas, renewable fuels of non-biological origin, advanced bioethanol and renewable electricity, extending the policy scope beyond the traditional focus on road transport.
Renewable fuels, hydrogen and sustainability requirements
A central element of the draft concerns the treatment of renewable fuels of non-biological origin, low-carbon fuels and recycled carbon fuels. The text transposes provisions from the 2024 EU gas and hydrogen market directive to ensure a legal framework for electrolytic hydrogen that does not meet the criteria to qualify as an RFNBO. For all these fuels, the Decree establishes sustainability and greenhouse gas reduction thresholds comparable to those already applied to biofuels and biomass-based fuels under existing Spanish legislation. Only fuels that meet these criteria may be counted towards compliance, reinforcing consistency and environmental integrity across fuel categories.
Guarantees of origin, electricity credits and traceability
The draft also completes the existing framework for guarantees of origin by explicitly extending it to RFNBOs and low-carbon fuels. In parallel, it sets out the foundations of a renewable electricity credit mechanism, enabling renewable electricity supplied to transport to be used by obligated parties to meet their decarbonisation targets. To safeguard the system, the Decree introduces detailed provisions on traceability and data management, ensuring interoperability between the EU Union Database and the national database. This integrated approach is designed to reduce fraud risks and strengthen oversight of sustainability proofs across the entire supply chain, from production and aggregation to processing, storage and final market placement.
Advanced biofuels and the role of stakeholder input
Finally, the proposal transposes the latest EU amendment to Annex IX of the Renewable Energy Directive, incorporating new eligible feedstocks for the production of advanced biofuels and biogas into Spanish law. Given the breadth of the regulatory changes and the feedback already received, the government has reopened the consultation to collect targeted additional input from affected stakeholders. Contributions must comply with strict formal requirements and are subject to a short submission window, underscoring the intention to finalise a technically robust and legally coherent framework fully aligned with RED III and the wider EU decarbonisation agenda.
