Spain faces the challenge of the data center 'boom': lack of connection points, distribution network, and water stress

The country treasures international connectivity, renewable energy sources, available land, and an environment favorable to digitalization; but also a series of obstacles that hinder deployment

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Spain stands out as one of the most attractive countries to host data centers (CPDs) - the buildings where the internet lives - by meeting unique conditions. Large investments, announcements of technology campuses, and plans by digital giants converge to paint an idyllic landscape. However, beneath the surface of this boom, questions arise about whether the country has the real and solid infrastructure that these types of projects require. It is undeniable that there is a window of opportunity and the conditions are optimal, but there are also obstacles that could limit the sector: bottlenecks, scarcity of connection points, water stress, energy sustainability, lack of planning, and regulatory constraints.

Spain's growth potential in this sector is enormous; indeed, the Catalonia-Madrid tandem presented by the Government to host one of the Artificial Intelligence gigafactories that the European Union intends to have operational between 2027 and 2028 is one of the strongest candidacies.

The privileged location of the Iberian Peninsula for international connectivity, with direct access to fiber optic cables linking to Europe, America, and Africa; a solid energy infrastructure led by renewable energy sources; the availability of land; and a regulatory environment favorable to digitalization and technological investment are some of Spain's main competitive advantages.

Spain boasts international connectivity, renewable energy sources, available land, and an environment favorable to digitalization

The list of strengths is extensive, but there are also aspects that urgently need to be addressed, such as the problem of connection points, which is the keystone of any data center project.

The key piece of the puzzle

There may be available land, a favorable regulatory environment, and unlimited investment, but without a connection point to the electrical grid, a data center cannot operate, no matter how innovative it may be.

Connection points are the physical (and administrative) nodes that allow a facility to connect to the transport or distribution grid and receive the required electrical power continuously and safely. These connection points are a limited resource.

Each substation has a maximum capacity and, in many areas of the country, a good part of that capacity is already committed by industrial, energy, or other data center projects. Obtaining a connection point is not automatic: it requires administrative authorization, investments in grid reinforcement, and deadlines that can extend for several years.

Obtaining a connection point is not automatic: it requires administrative authorization, investments in grid reinforcement, and deadlines

This element is key and strategic, as without a connection point, a data center cannot even start, no matter how advanced the project is or how much capital backs it. As things stand, the competition between developers is not only for land or clients, but for securing access to the electricity grid before others.

This bottleneck explains why many announced projects still lack a clear execution schedule and why electricity planning has become the main filter for the data center boom in Spain.

The most attractive territories for growing demand

Interest among global operators, hyperscalers, and investment funds is increasing. In Spain, data center demand is expected to grow by 90% between 2024 and 2028, implying an annual growth of 20%.

In the early stages of 2025, Spain reached 355 MW of installed capacity, and if the current trend were maintained, 2,180 MW could be reached in the next five years. However, a possible power limitation is forecast for 2030 around 1,400 MW; nearly 800 MW of power that would jeopardize almost 10 billion euros in direct investment.

The leading territories in this sector are Madrid, Barcelona, and Aragon, which represent 54.8%, 18.5%, and 10.7% of the national supply. The three regions represent 84% of the current capacity, and projections are encouraging: Madrid could reach 1,105 MW in 2030; Barcelona from 66 to 199 MW; and Aragon could reach 340 MW. If this materializes, Aragon would displace the Catalan capital as second in the ranking of regions with the most development in the data center industry. Furthermore, a step forward is expected from Bilbao and Malaga.

For its part, Extremadura is emerging with planned megacenters of up to 300–500 MW, designed under criteria of energy efficiency and renewable energy, showing an alternative model outside traditional hubs

The energy challenge and the importance of 2026

The first obstacle for data center projects is the fragmentation of regulations and the lack of territorial planning. There is no unified national policy that includes detailed planning and coordinates territories and the different actors involved: energy, sustainability, and industrial land.

Situations arise where municipalities themselves support the installation of data centers, but cannot guarantee their electrical connection, let alone ensure it, a problem closely linked to the aforementioned issue of connection points.

The energy challenge is another matter. The country is in full transition, and it is now that data centers are being integrated into its planning. Energy transport and distribution networks are being adapted to meet the needs implied by the deployment of these infrastructures.

This is because, on occasion, the energy infrastructure is not prepared to meet the sustained demand of tens or hundreds of megawatts that a data center requires. Furthermore, the processing of new grid access points, both in transport and distribution, can take years, delaying deadlines and curtailing the ability to scale the project rapidly.

Spain plans its electricity transport grid in six-year cycles. Law 24/2013 of the Electricity Sector allows for specific modifications, always subject to exceptional conditions and requiring time, which limits flexibility in the face of emerging demands. The current National Integrated Energy and Climate Plan, which dates from 2023 and extends to 2030 (PNIEC 2023-2030), does not integrate the future needs of the data center sector.

The Government, aware of the window of opportunity, is working on several fronts to improve regulations. On the one hand, it is finalizing a Royal Decree to establish a specific framework for data centers. Last August, it released for public consultation and information the draft Royal Decree regulating energy efficiency and sustainability for data centers. On the other hand, the Electricity Transmission Network Development Plan (2021-2026) expires in 2026, and it is expected that this plan will integrate the industry's demands. Soon, the Ministry for Ecological Transition and the Demographic Challenge will have to submit the Initial Development Proposal prepared by Red Eléctrica for the period 2025-2030 to public information, which will serve as the basis for the Development Plan ultimately approved by the Council of Ministers.

Water stress and sustainability

Another of the challenges is associated with the water stress implied by data center infrastructure. Spain suffers from increasingly intense drought cycles due to climate change, so water use is a vital part of the political and social agenda. Projects that do not manage to position themselves as environmentally friendly and ensure a local economic return will face significant public rejection.

The EU intends for projects to be in line with the Green Agenda. To this end, the goal is for data centers to be climate-neutral by 2030, which will require them to reduce greenhouse gas (GHG) emissions as much as possible and offset any emissions by purchasing carbon credits.

In order to demonstrate that the sector respects Agenda 2030, it has promoted a self-regulation initiative through the Pact for Climate-Neutral Data Centers.

Spain's Artificial Intelligence Strategy (2024) already includes a specific line aimed at generating storage capabilities under sustainable conditions, betting on the development of more efficient and environmentally friendly data centers. It is also expected that the 2028-2030 hydrological planning will involve all hydrographic demarcations.

The Ebro Hydrographic Confederation is, for now, the only one that has incorporated this element into its planning, and maintains that the foreseen impact will be, in general terms, "close to imperceptible". This is not the case in other demarcations, such as the Tajo, where this aspect is not reflected despite the contemplation of large data processing center installations. This disparity may complicate the environmental processing of future projects, especially in cases where binding reports from the hydrographic confederations themselves are required.

Cybersecurity Delay

Data centers are considered critical infrastructures, and as such must be protected. The Government of Spain has a significant regulatory delay in terms of cybersecurity. It has been more than a year since the Draft Law on Cybersecurity Coordination and Governance passed the Council of Ministers in its first reading (specifically, on January 14, 2025).

It is in this legislation where the creation of the National Cybersecurity Center is foreseen, which will coordinate the protection, precisely, of data centers.

In short, the national territory brings together unique conditions that position it as one of the locations with the greatest potential, capable of competing with the most consolidated markets in Northern and Central Europe, the so-called FLAP-D (Frankfurt, London, Amsterdam, Paris, and Dublin); but there is work ahead. Thus, the national challenge is not only to attract projects, but to plan and guarantee the basic infrastructure that allows them to become a reality. Faced with this challenge, Madrid, Aragon, and other regions compete not only to attract investments, but to offer real network, power, and sustainability to these large facilities.

 

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What is the current status of the parliamentary processing of the Royal Decree that will regulate energy efficiency and sustainability of data centers in Spain?

At this moment, there is no record in the Cortes of the parliamentary processing of a specific and autonomous Royal Decree titled — or equivalent to — "Royal Decree that will regulate energy efficiency and sustainability of data centers in Spain." What does exist is a Royal Decree-law 7/2026 (processed as Bill 121/000091) that introduces for the first time sustainability criteria for data centers connected to the electrical system, currently in the amendment phase in the Congress. At the same time, there are several Non-Legislative Proposals and works in the Senate preparing the political ground for more detailed regulation on energy efficiency and sustainability of data centers. As of today, therefore, the regulation is being articulated in an indirect and partial manner through this RDL under processing as a law and through orientation initiatives, not through a closed and approved sectoral Royal Decree.

1. Core normative: Royal Decree-law 7/2026 and its parliamentary processing

The instrument closest to what you ask is the Royal Decree-law 7/2026, of March 20, whose content is being processed as Bill 121/000091 in the Congress of Deputies (initiative file, BOCG admission).

Status of processing:

● The RDL was ratified by the Congress and its processing as a bill was agreed.
● The amendment period is currently open and extended until 06-24-2026, so the regulation is in an initial phase of parliamentary processing.
● Meanwhile, the content of the ratified RDL is fully in force as a decree-law; the processing as a bill may modify, nuance, or expand its provisions.

Relevant content for data centers:

● The text starts from the fact that the strong deployment of renewables in Spain is attracting investments in data processing centers (data centers) and other intensive consumers, with a risk of stress on the electricity supply.
● In its first additional provision, it foresees the approval of sustainability criteria for data centers connected to the electrical system, including the obligation to balance new consumption with equivalent renewable generation.
● It introduces a milestone system for the expiration of access and connection permits for demand installations and a scheme of flexible network access, closely linked to the absorption capacity of new data centers.
● It modifies elements of Royal Decree 36/2023 (Energy Savings Certificate System), reinforcing instruments of energy saving and efficiency in general, which indirectly affects the data center industry.

This regulation is not a “Data Centers Royal Decree,” but today it is the central normative piece anchoring the future definition of sustainability (especially energy) requirements for these centers.

2. There is not yet a closed and ratified sectoral Royal Decree

With the available information, there is no autonomous Royal Decree with a specific title such as "establishing energy efficiency and sustainability requirements for data centers" that is:

Published in the BOE as an ordinary decree pending control.
● Or in the phase of ratification as a specific Royal Decree-law on data centers.
● Nor in the form of a draft Royal Decree formally submitted to the Cortes (ordinary royal decrees are not processed as laws, but references usually appear if there is specific parliamentary control).

What does exist is a normative mandate within RDL 7/2026 to develop those sustainability criteria, which will likely materialize in a future Royal Decree or technical regulatory norm, not yet identified in the consulted context. No further information is available in the consulted sources about the possible specific regulatory draft.

3. Parliamentary initiatives pushing efficiency and sustainability regulation

a) Non-Legislative Proposals in the Congress

Several PNLs directly address the energy and environmental framework of data centers, conditioning and guiding future regulatory development:

PNL for sustainable and transparent resource consumption planning in the data center industry (Plurinational Group SUMAR, no. 162/000593), published in the BOCG and pending debate.
– Invokes Directive (EU) 2023/1791 on energy efficiency and Delegated Regulation (EU) 2024/1364 on common assessment of data centers.
– Requests to oblige data center companies to report on their energy and water consumption and to condition project authorization on their sustainability, including efficient cooling techniques and advanced energy efficiency measures.

PNL to facilitate an adequate energy framework for Data Centers (GPP, no. 161/003047), published and pending debate in the Ecological Transition Commission. It explicitly raises the need for a specific energy framework for data centers, linked to decarbonization and ecological transition.

● Other PNLs from PP and PSOE on boosting the data center industry are collected in the same BOCG-D 169, connecting them with the Recovery Plan, digitalization, and cloud infrastructure expansion.

b) Control initiatives and studies on the electrical grid and resilience

● In the Congress, written question 184/003090 from the GPP on "measures planned for electrical infrastructures necessary for Data Centers in Castilla-La Mancha" received a government response on 03-11-2024 (BOCG-D 103), focused on the network capacity to absorb the consumption increase derived from these projects.

● In the Senate, the Study Committee on the Importance of Artificial Intelligence (543/000006), approved on 02-06-2026, dedicates part of its recommendations to data centers (approved report). It proposes, among other points:
– A clear and transparent regulatory framework for the creation and management of data centers.
Strict environmental policies that guarantee their sustainability and energy efficiency.
– Incentives and planning instruments for networks and energy.

● Also in the Senate, initiative 684/026683 from the GPP (file) raises energy resilience as a pillar of national security in a context of data center growth and network node saturation.

4. Conclusion on the state of regulation

In summary, today there is no sectoral Royal Decree already approved and under parliamentary control dedicated exclusively to energy efficiency and sustainability of data centers. The framework is being built through:

● The Royal Decree-law 7/2026, in force but still under processing as Bill 121/000091, which incorporates mandates on sustainability criteria for data centers connected to the electrical grid.
● A set of PNLs and committee works in Congress and Senate pushing for stricter regulation aligned with European energy efficiency and critical digital infrastructure regulations.

The next key step will be the evolution of the bill (amendments and, eventually, regulatory development) and the possible future approval of a technical Royal Decree detailing efficiency and sustainability standards, not yet identified in the current parliamentary process.

What specific changes could the amendments to Bill 121/000091 introduce regarding sustainability criteria for data centers? How will Spain transpose Article 12 of Directive (EU) 2023/1791 on energy efficiency of data centers? What positions are the different parliamentary groups (PSOE, PP, SUMAR, Vox, nationalists) defending regarding environmental requirements for the data center industry?

What are the main competencies of the Ministry for the Ecological Transition and the Demographic Challenge regarding energy planning?

The Ministry for the Ecological Transition and the Demographic Challenge (MITECO) concentrates the responsibility for state energy planning, both at the strategic level (energy-climate) and sectoral level (electricity and gas). Through the Secretary of State for Energy and, in particular, the Directorate General for Energy Planning and Coordination and the Directorate General for Energy Policy and Mines, it prepares the PNIEC, defines the energy strategy, and coordinates infrastructure planning. The Government formally approves electrical planning, but it is MITECO that drives, drafts, and processes the plans, in coordination with the CNMC, Red Eléctrica, and the autonomous communities. Additionally, it links this planning to the renewable, efficiency, and decarbonization objectives set in the EU energy and climate frameworks.

1. General framework and strategic energy-climate planning

At the strategic level, MITECO is responsible for preparing the National Integrated Energy and Climate Plan (PNIEC) and coordinating its coherence with long-term decarbonization strategies. The repealed Law 7/2021 on climate change and energy transition already configured the PNIEC and the 2050 Decarbonization Strategy as “the two main governance tools for climate and energy” of the State, in application of Regulation (EU) 2018/1999 (BOE-A-2021-8447). Today, MITECO remains the body that:

– Leads the preparation and update of the PNIEC 2023-2030, setting renewable, efficiency, and emission reduction targets, and submitting it to the European Commission (PNIEC 23-30).
– Integrates sectoral energy planning (electricity, gas, building efficiency, etc.) with 2050 decarbonization trajectories.
– Articulates other strategic frameworks (for example, energy planning on the normative strategy website: planning), ensuring consistency between sectoral policies and climate objectives.

2. Planning of the electrical system and networks

In the electrical field, Law 24/2013 of the Electrical Sector (cited in Order IET/2209/2015) establishes that the planning of the electricity transmission network is carried out by the Government, with participation of autonomous communities, CNMC report, and hearing procedure. Order IET/2209/2015, which publishes the “Energy Planning. Development Plan of the Electricity Transmission Network 2015-2020,” specifies that:

– Transmission planning has binding character for infrastructures essential for supply security (BOE-A-2015-11398).
– The process is initiated by ministerial order; the system operator (Red Eléctrica) formulates a technical proposal, and the competent energy ministry (today MITECO) drafts the plan considering regional allegations, CNMC report, and strategic environmental assessment.
– The Council of Ministers finally approves the planning.

Subsequently, orders such as TEC/748/2019 and TED/314/2021 show that MITECO has competence to introduce technical adaptations to the approved plan. Additionally, the ministry itself has articulated the 2025-2030 electrical planning process through public information and specific documentation (electrical planning, 2025-30 process).

3. Competencies in the gas system and efficiency

In natural gas, Order TED/181/2025, which approves the Technical Management Standards of the Gas System, emphasizes that it is a “ministerial competence” matter (BOE-A-2025-3873). Although the detailed competence is found in Law 34/1998 on Hydrocarbons and Royal Decree 984/2015 (BOE-A-2015-11725), the available information allows affirming that MITECO:

– Approves the technical standards governing the operation of the gas system.
– Promotes operational plans (for example, winter plans) and develops the state regulatory framework for gas access and market, in coordination with the CNMC.

In energy efficiency, the energy department has promoted specific plans such as the activation plan for efficiency in AGE buildings (Resolution of January 14, 2010, BOE-A-2010-1235). Today these policies are integrated into the PNIEC and sectoral plans (building renovation, rehabilitation, etc.), whose preparation is also coordinated by MITECO (energy planning).

4. Internal bodies exercising planning

Within MITECO, energy planning competencies are concentrated in the Secretary of State for Energy, which directs energy policy and transition strategy (Secretary of State for Energy, organizational chart). Under it stand out:

– The Directorate General for Energy Planning and Coordination, the technical core in charge of system planning (scenarios, PNIEC, electrical and gas planning, inter-administrative coordination).
– The Directorate General for Energy Policy and Mines, which defines the regulatory framework and energy and mining policy, conditioning planning through supply security, decarbonization, and market functioning criteria.
– Specialized bodies such as the Commissioner for Renewable Energies, Hydrogen, and Storage, which provide sectoral content to planning.

5. Coordination with EU, autonomous communities, and regulators

MITECO’s energy planning is exercised within a shared governance framework:

– With the EU, the ministry prepares and submits the PNIEC and other plans, negotiates their content, and ensures alignment with European objectives (renewables, efficiency, emissions) (energy portal).
– With the autonomous communities, it integrates their infrastructure proposals and territorial constraints into electrical and gas planning, following the procedure described, for example, in Order IET/2209/2015.
– With the CNMC and operators (Red Eléctrica, gas operators), it combines its planning and strategic orientation function with the regulatory and independent function of the CNMC, whose reports must be incorporated into the plans (electrical planning).

What legal requirements must data centers meet to obtain a connection point to the electrical grid in Spain?

In Spain, data centers do not yet have a specific electrical regime: to obtain a connection point to the grid (transmission or distribution), they are legally considered high-power demand installations (industrial/tertiary) and the general regime applies. This implies, on one hand, complying with access and connection rules (permission to connect to the grid) and, on the other, with safety and design regulations for low and high voltage installations. If the data center incorporates its own generation (for example, photovoltaic self-consumption), the self-consumption framework also applies. No explicit mentions to “data centers” have been found in the basic regulation: they are framed within the set of large consumers.

1. Access and connection permits to the grid

The “right” to connect a data center to the transmission or distribution grid is governed by Royal Decree 1183/2020, on access and connection to electricity transmission and distribution networks, and by its development for demand in CNMC Circular 1/2024.

Royal Decree 1183/2020 establishes that any demand installation exceeding certain thresholds or connected at certain voltage levels must obtain access permit (capacity in the grid) and connection permit (technical feasibility at the specific point). It does not create special categories for data centers; general rules for application, capacity evaluation, and resolution by the network manager (Red Eléctrica de España in transmission and distributors in distribution) apply.

CNMC Circular 1/2024 specifies the methodology for all demand installations:

  • Defines who is obliged to request permits (and who may be exempt according to art. 17 of RD 1183/2020).
  • Regulates capacity evaluation criteria, avoiding discrimination and favoring efficient use of networks.
  • Introduces the figure of flexible access, allowing certain demands to accept limitations/modulation in exchange for facilitating grid integration.
  • Obliges network managers to publish and keep updated the available capacity at each node.

For a data center, this means that before contracting supply, it must process and obtain these permits, providing technical information on requested power, voltage level, operation regime, etc. Order TED/1494/2021 guides this regulation seeking to prioritize demands that provide system flexibility, something especially relevant if the data center can modulate consumption.

2. Self-consumption associated with the data center

If the data center incorporates its own generation (for example, rooftop or on-site photovoltaic), Royal Decree 244/2019 on self-consumption applies.

RD 244/2019 sets administrative, technical, and economic conditions for self-consumption, both with and without surpluses. For a data center, this means:

  • Choosing the self-consumption modality (with/without surpluses, individual or collective).
  • Complying with technical connection requirements of the generation plant to its installations and the grid.
  • Adhering to the economic regime (simplified surplus compensation, if applicable).

The regulation is complemented by Resolution of December 11, 2019, which adapts operation procedures to self-consumption, and by Order TED/1247/2021, on variable coefficients in collective self-consumption. Here too, there is no specific regime for data centers: they are governed as any large consumer with associated generation.

3. Technical requirements of installations (low and high voltage)

Obtaining the connection point is not enough: for the distributor or REE to put the supply into service, the data center’s electrical installation must comply with safety technical regulations and be registered with the competent autonomous community.

In low voltage, the Low Voltage Electrotechnical Regulation (RD 842/2002) applies, which requires:

  • Project or technical report, depending on the power and characteristics of the installation.
  • Compliance with Complementary Technical Instructions (ITC-BT), related to cable sections, protections, grounding, fire safety, etc.
  • Registration of the installation in the autonomous community and documentation to the owner.

The list of applicable UNE standards is updated, for example, by Resolution of March 20, 2025 (ITC-BT-02).

If the data center is fed at medium or high voltage, the Regulation on technical conditions and safety guarantees in high voltage electrical installations (RD 337/2014, not linked in sources) and its ITC RAT/LAT, updated, among others, by Resolution of September 18, 2025 (ITC RAT-02) apply. They regulate design, construction, and commissioning of own transformation centers, internal lines, switching, and protection.

4. Network planning and closed networks

The real possibility of obtaining a powerful connection point depends on network planning and reinforcements. Order TED/314/2021 introduces technical adaptations in the 2015-2020 transmission network development plan; these plans determine where the network is reinforced and, therefore, in which areas there is more capacity available for large consumption.

Additionally, a campus integrating a data center can be structured as a closed distribution network, according to RD 314/2023. In that case, the closed network requires its own administrative authorization, but its connection to the general system is also governed by RD 1183/2020 and Circular 1/2024.

5. Conclusion: general regime, without specific treatment

With all the above, the current situation is clear: there is no state regulation that treats data centers differently for connection point purposes. They are considered large demand installations subject to RD 1183/2020, Circular 1/2024, and the low and high voltage technical regulations, with the possible addition of the self-consumption regime of RD 244/2019. The practical key for a developer is, therefore, to locate nodes with sufficient capacity, design the installation according to REBT and RAT, and properly process access and connection permits before the competent network manager.

What specific steps and deadlines does CNMC Circular 1/2024 establish for processing access and connection of a high-power data center? How does transmission network planning affect the location choice of new data centers in Spain? What role can self-consumption (e.g., photovoltaic) play in the electrical and economic viability of a data center in Spain?

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