CNMC Circular 4/2026: new incentives and penalties for gas transport 2027-2032

Key data

Companies operating natural gas transport infrastructure and liquefied natural gas (LNG) plants in Spain face a significant regulatory change: the CNMC Circular 4/2026 establishes the remuneration rules for the six-year period 2027-2032, replacing Circulars 9/2019 and 8/2020. This is not a minor revision: it introduces new incentive mechanisms, eliminates an existing remuneration figure and tightens penalties for imprudent financial management.

The framework aligns with EU Directive 2024/1788 and EU Regulation 2024/1789, and with the European Fit for 55 objective, which means the regulation is designed to actively facilitate the penetration of renewable gases into the network.

What does this regulation establish?

Circular 4/2026 sets the methodology for calculating remuneration for natural gas transport installations and LNG plants during the 2027-2032 period. Below are the key elements of the new model:

What remains

• WACC model (Weighted Average Cost of Capital) to determine the financial remuneration rate.
• Unit reference values for operation and maintenance costs.

What changes: comparison with the previous framework

The three new incentives in detail

• IAE — Efficient Cost Acquisition Incentive: rewards companies that manage their costs more efficiently than the regulatory reference values.
• IFVA — Amortized Asset Reliability Incentive: compensates for maintaining in service and the reliability of assets that have already completed their regulatory useful life.
• Expanded IDS — Sustainable Development Incentive: extends the existing incentive to cover the integration of renewable gases with origin guarantees into the transport network.

Economic and operational impact

The new framework has direct consequences on the income statement and operational strategy of affected companies:

• Loss of income from RCS elimination: companies that received Supply Continuity Remuneration will need to recalculate their financial models for the 2027-2032 period without this component.
• Opportunity for additional income via IAE: companies that manage to reduce operating costs below the unit reference values will be able to capture additional economic incentive. Efficiency in purchasing and contracting now has direct remuneration value.
• Opportunity via IFVA: keeping already amortized assets operational — rather than retiring them — can generate additional remuneration if their reliability is demonstrated.
• Greater financial risk from 2030: the financial imprudence penalty increases from 1% to 1.5%, which increases the cost of inadequate financial management by 50% compared to the previous level.
• Alignment with renewable gases: the expansion of IDS opens a regulated income pathway for companies that facilitate the transport of renewable hydrogen, biomethane or other renewable gases with origin guarantees.

Who does it affect?

• Companies holding natural gas transport installations in Spain (primary and secondary transport pipelines).
• Companies holding liquefied natural gas (LNG) plants: regasification and liquefaction plants.
• Financial directors and CFOs of these companies, who must review regulated income models for 2027-2032.
• Operations and maintenance teams, who must adapt their management to maximize the new IAE and IFVA incentives.
• Sustainability and strategy managers, given the opportunity of the expanded IDS for renewable gases.
• Regulatory advisors and energy consultants serving these companies.

Practical example

Imagine a company holding a natural gas transport installation with partially amortized assets and annual operating costs above the CNMC unit reference values.

Under the previous framework (Circulars 9/2019 and 8/2020), this company received Supply Continuity Remuneration (RCS) as a fixed component of its regulated income. With Circular 4/2026, that item disappears from 2027.

However, if the company implements an efficiency plan in purchasing and contracting that places its costs below the unit reference value, it will be able to activate the IAE and partially offset the loss of RCS. Additionally, if it maintains already amortized assets in service with accredited reliability levels, the IFVA will generate additional regulated income that did not exist before.

On the other hand, if from 2030 onwards the company incurs financial management classified as imprudent by the CNMC, the applicable penalty will be 1.5% instead of the previous 1% — a 50% increase in the cost of that risk.

What should companies do now?

1. Review the regulated financial model for 2027-2032: remove RCS from the income plan and incorporate the new IAE, IFVA and expanded IDS incentives as potential line items.
2. Audit operating costs against CNMC unit reference values: identify where there is room for improvement to activate IAE.
3. Inventory amortized assets in service: evaluate which ones meet reliability conditions to access IFVA and document their technical status.
4. Evaluate renewable gases strategy: analyze whether existing infrastructure can facilitate the transport of biomethane, renewable hydrogen or other gases with origin guarantees to access the expanded IDS.
5. Strengthen financial management controls before 2030: the financial imprudence penalty increases to 1.5%, so it is advisable to review internal procedures for debt management and capital structure.
6. Follow regulatory developments: the Circular aligns with EU Directive 2024/1788 and EU Regulation 2024/1789; additional developments are likely to be published that will affect the practical application of incentives.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-19425