Gas system charges 2026: new incentives and what gas storage facilities pay

Key data

The holders of underground gas storage facilities and gas system operators operate from October 1, 2026 under a new remuneration methodology. The Royal Decree 924/2026 modifies RD 1184/2020 and brings changes that directly affect the profitability of storage facilities and the cost structure borne by industrial gas consumers.

The regulation is not a minor adjustment: it advances the start of the regulatory period, creates two new incentive mechanisms, retroactively recognizes CO2 costs accumulated since 2021 and makes it easier to create extraordinary charges without needing to modify the decree.

What does this regulation establish?

RD 924/2026 introduces five structural changes to RD 1184/2020. Below is the specific comparison:

Economic and operational impact

For holders of underground storage facilities, the impact is mainly positive in terms of regulated income:

• The Incentive for efficient acquisition of supplies directly rewards purchasing management: if a company manages to buy below the average of the previous three years, it retains 50% of that saving as additional remuneration. This turns purchasing efficiency into a direct income lever.
• The Incentive for Reliability and Asset Valorization especially benefits facilities with highly depreciated assets, which until now had no specific mechanism to recognize their continued operational value.
• The recognition of 90% of CO2 emission allowance costs from 2021 represents a recovery of costs that until now were not covered by regulated remuneration. The retroactive effect from 2021 can generate significant positive settlements for affected companies.

For large industrial gas consumers, the creation of specific causality charges is key: until now, certain costs were distributed among all system users. With the new model, those costs fall on whoever generates them, which can reduce the bill for those not responsible for those costs, but also increase it for those who are.

The flexibility of extraordinary unit charges allows the regulator to act more quickly in unforeseen situations, without needing to process a complete regulatory modification. For companies, this implies greater exposure to tariff adjustments in shorter timeframes.

Who does it affect?

• Companies holding basic underground gas storage facilities: they are the main beneficiaries of the new remuneration incentives and CO2 cost recognition.
• Gas system operators: must adapt their remuneration models to the new regulatory period starting October 1, 2026.
• Organized gas market operator: its remuneration will be limited to guarantee management from September 30, 2027.
• Large industrial gas consumers: affected by the new causality charge structure and the possibility of extraordinary unit charges without prior regulatory modification.
• CFOs and energy directors of industrial companies: must review the impact of new causality charges on their energy cost forecasts.

Practical example

Suppose a company holding a basic underground gas storage facility that, in the previous three years, has acquired supplies at an average cost of 10 million euros per year. In the new regulatory period, thanks to more efficient purchasing management, it manages to reduce that cost to 8.5 million euros.

The savings compared to the average is 1.5 million euros. Applying the Incentive for efficient acquisition of supplies, the company would retain 50% of that saving: 750,000 euros as additional regulated remuneration.

Additionally, if that same company has borne CO2 emission allowance costs since 2021 without regulatory recognition, it can now claim 90% of those costs retroactively. Depending on the volume of emissions and the CO2 price in each fiscal year, the cumulative impact since 2021 can be very significant in the settlement of the new regulatory period.

What should companies do now?

1. Verify the impact of retroactive CO2 recognition from 2021: companies holding storage facilities must quantify the CO2 emission allowance costs borne since 2021 and evaluate what portion (up to 90%) can be recovered in the settlement of the new regulatory period.
2. Review the supply purchasing strategy: the new 50% incentive on savings compared to the average of the previous three years turns purchasing efficiency into direct regulated income. It is advisable to establish a baseline and define savings targets.
3. Evaluate if assets are highly depreciated: companies that may qualify for the Incentive for Reliability and Asset Valorization should identify which facilities meet the criteria and prepare the necessary documentation.
4. Analyze exposure to new causality charges: large industrial consumers should review whether their consumption patterns or connection to the system may generate costs that will now be assigned directly to them instead of being socialized.
5. Monitor extraordinary unit charges: since they can now be created without modifying the decree, it is advisable to establish a regulatory alert system to detect new charges quickly and adjust energy budgets.
6. Prepare for the transition of the organized gas market operator: if your company operates in that market, keep in mind that from September 30, 2027 the operator's remuneration will be limited to guarantee management.

Official source

Consult complete regulation in official source

Notice: This article is purely informational in nature 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-2026-22613