Completing the works does not automatically exclude their savings from Spain’s CAE system. A final invoice is not enough, however: the measure must meet the applicable rules, remain within the regulatory window and retain evidence of the original condition, the installed solution and commissioning.
Completed measures may still be assessed
Royal Decree 36/2023 and Order TED/815/2023 allow CAEs to be requested for measures that have already been implemented. The investor did not necessarily have to open a CAE file before every project. The saving must nevertheless be new, attributable to an energy-efficiency measure and verifiable under an eligible sheet or method.
The review therefore has two dimensions: time and evidence. A recent project with before-and-after photographs, itemised invoices and commissioning records may be defensible. A newer project can still fail if the removed equipment was never identified or a mandatory condition can no longer be proven.
Do not wait for the deadline
The three-year limit is not three full years for preparing the dossier: agreements, verification, application, issue and registration must all fit before expiry.
Completion date and the three-year window
The measure must have started after 26 January 2023, when Royal Decree 36/2023 entered into force. Its start is not necessarily the invoice date: it is the earlier of the start of works and the first firm commitment that made the investment irreversible, such as an equipment order. A firm order placed before that cut-off may therefore exclude works completed later. Project records should support one coherent timeline.
A CAE expires three years after completion or on 1 January 2031, whichever comes first. This is a validity rule, not a guarantee that a file opened shortly before expiry can finish in time. Older works require an urgent timetable review with the authorised participant that would promote issuance.
Evidence usually decides the outcome
For a standardised measure, the applicable sheet defines the required form, itemised invoices, photographs, technical data, certificates, registrations and declarations. A generic invoice describing an ‘energy renovation’ rarely establishes the variables used in the savings calculation.
The original condition is often hardest to prove after completion. Nameplate photographs, inventories, earlier certificates, readings and dated reports may become critical once equipment has been removed. A later note may explain the record, but it must not be backdated or presented as contemporaneous evidence.
Evidence should also establish the physical identity of the site and assets. Addresses, cadastral references, serial numbers and quantities need to reconcile across invoices, photographs and certificates. Where several buildings or dwellings were involved, a clear allocation table is safer than an unsupported total. This allows the verifier to follow each calculation input back to a real location and item of equipment.
- Timeline. Order, works, invoice and commissioning dates must agree.
- Before. Retain photographs, nameplates, consumption data and earlier certificates.
- After. Identify models, quantities, performance, location and activation date.
- Grants. Declare support requested or received and review its conditions.
Savings ownership, CAE agreement and grants
The party that funded the measure is generally the original owner of the saving. If the CAE applicant did not make that investment, the chain of rights must be evidenced, including the required CAE agreement. Renting, leasing, energy services and third-party finance require contract review rather than assumptions based on an invoice name.
Public support must also be disclosed. Measures benefiting from a programme funded by Spain’s National Energy Efficiency Fund cannot be included in an issuance request. Other programmes require their own analysis of cumulation, eligible costs, income and double funding.
A practical completed-works screening
Collect untouched originals for the site, parties, dates, removed and installed equipment, invoices, payment where required, photographs, technical files, certificates and grants. Map every requirement and calculation input in the current sheet to a specific item of evidence. A non-standardised route demands an even stronger baseline and method.
The outcome should be a decision: suitable for preparation, suitable subject to named corrections, or unsupported by the available evidence. Only obligated and delegated parties can apply for issuance, following a favourable accredited verification opinion. An initial review can identify a route but cannot guarantee issuance.
Frequently asked questions
- Is an invoice enough?
- Usually not. Measure sheets commonly require technical evidence, dates, photographs and commissioning or regulatory records.
- Can two-year-old works qualify?
- They can be assessed, subject to the exact date, remaining validity and evidence required by the applicable rules.
- Can a missing before photograph be recreated?
- No evidence should be fabricated or backdated. Genuine alternative records may be assessed for sufficiency.