The National Commission for Markets and Competition (CNMC) approved Operation Procedure 7.6 , which establishes the basis for the provision of this non-frequency service in the Spanish peninsular electricity system.
The regulation defines who can provide the service, under what technical requirements, with what tests, what remuneration system applies, how it will be settled and what penalties there will be for non-compliance .
But the change won't be immediate for all technologies. The first phase of PO 7.6 maintains a continuity approach: the service will be assigned to facilities already listed in the Replacement Plans that can act as island initiators.
“ Right now, what is being done is to give a lot of legal solidity to the current framework: if Spain has a zero, the hydroelectric companies are going to rescue the system , ” explains Pablo Reinoso Lozano, Head of Regulatory Ops at Temos , in dialogue with Energía Estratégica .
Temos is a Spanish company that applies artificial intelligence to the development of energy projects, focusing on regulation, origination, and anticipation of grid connection opportunities. In this analysis, their contribution aims to clarify what truly changes with the new procedure and what remains to be seen regarding technologies such as batteries.
Spain and a service to restore the system after a power outage
The CNMC points out that this new procedure strengthens resilience to situations of zonal or total power outages and incorporates lessons learned from the system restoration after the blackout of April 2025.
The procedure applies to the system operator , distribution network managers and autonomous start providers that provide the service in the peninsular system.
Among the technical requirements, the installations must be able to start without external supply in less than 15 minutes , perform at least three consecutive starts , control frequency and voltage, respond to voltage dips, operate in island mode and guarantee primary energy reserves to operate at full load for a minimum of four hours .
They must also have critical communication systems with a minimum autonomy of 24 hours and pass qualification processes and periodic tests.
The CNMC also incorporates a system of remuneration, settlement, and penalties . Remuneration will be annual, although settlements to providers will be made monthly. The cost of the service will be distributed monthly in proportion to the demand at the central busbars.
Phase 1: Hydraulics, five years and continuity
The allocation of the service will be organized in two phases .
Phase 1 will have an initial minimum service period of five years and will maintain a continuity with respect to the current Replacement Plans.
“In the first phase, only those facilities that were already defined in the replacement plans will be able to participate, which are mainly hydroelectric facilities,” summarizes Xavier Riba Anglada, Co-Founder & CEO of Temos .
The Official State Gazette (BOE) establishes that the procedure will take effect the day after the publication of the technical note and the testing protocols, which must be available within a maximum of six months from the publication of the resolution. The provision, financing, and settlement of the service will become operational once the necessary modifications to the settlement procedures have been approved.
“It is now legally approved, but specifications are lacking to be able to use it and for the facilities to be remunerated for it,” Riba warns.
Phase 2: the door for storage and power electronics
Phase 2 is the one that opens the door to other technologies.
Continue reading
The CNMC proposes that, after the first stage, the service evolve towards a scheme with competitive criteria , open to all facilities that demonstrate technical capacity and meet the location criteria defined in the Replacement Plans.
This potentially includes storage facilities and power electronics- based assets, provided they can meet the technical requirements of the service.
“In four years there will be a major paradigm shift. Power electronics and energy storage facilities will be able to participate. And instead of these fixed costs being reimbursed, it will be through a competitive pricing mechanism,” Reinoso Lozano points out.
The BOE clarifies that Phase 2 will be activated based on periodic needs assessments by the system operator, at least every five years, or sooner if the current facilities refuse to participate and no viable alternatives are found within Phase 1.
“The jump-start service helps, obviously, but it’s not very relevant to the business case of any battery project currently under development in the market,” Riba argues.
For Temos, PO 7.6 adds a regulatory signal, but does not resolve the central debate on storage in Spain.
“The expectation that in four or five years you might have a small additional income can be an anecdote in a battery business plan,” Reinoso Lozano points out.
The signal that storage in Spain is still waiting for
The new autonomous boot procedure mandates a key service for system security, but it does not replace the signals that storage needs to accelerate investments.
Temos identifies three pending fronts: capacity market, participation in flexibility markets and flexible access permits .
“The next change, the closest and biggest that batteries can have, is the approval of flexible access permit types,” says Reinoso Lozano.
Today, one of the main bottlenecks for new BESS projects is the lack of firm demand capacity at many nodes.
“When flexible permits are approved, you will be able to put batteries almost anywhere, subject to the fact that they will not be able to consume power from the grid at any time, but only when it is possible,” he says.
Riba agrees that regulatory priority should not be absorbed by the black start.
“The most relevant aspects are the capacity market, some areas of market participation that also lack regulation, and flexibility markets. There is still regulatory uncertainty that makes projects less bankable,” he points out.
And when asked what he would propose to the Government, Red Eléctrica or the CNMC, he points to a specific line: flexible access .
“For me, it’s about focusing regulatory development efforts on flexible access. Given that one of the biggest problems we have in the grid today is firm capacity saturation, an instrument like granting flexible capacity helps a lot, not only for batteries, but also for the system itself and its robustness,” he concludes.