Minimum natural gas reserves 2026: what changes for operators and suppliers

Key data

Companies in the gas sector in Spain face a new operational review obligation. Orden TED/306/2026, of 31 March, amends Orden TED/72/2023, of 26 January, which established the procedures for complying with minimum natural gas security stocks. The change is significant: it directly affects how mandatory stocks that companies must maintain to guarantee security of supply are calculated, reported and managed.

The regulation responds to the need to strengthen energy supply security in a context of persistent volatility in the gas market. Published on 2 April 2026 in the Boletín Oficial del Estado, its entry into force has not been specified in the available summary, so it is recommended to consult the full text to confirm the exact deadlines.

What does this regulation establish?

Orden TED/306/2026 specifically amends the 2023 regulation that developed the operational procedures for compliance with minimum natural gas security stocks. Based on the available information, the aspects that may be modified are as follows:

The reference regulation being amended is Orden TED/72/2023, of 26 January, which developed the procedures necessary for compliance with the obligation to maintain minimum natural gas security stocks. Companies that had already adapted their systems to that order must now identify which specific aspects are altered by this 2026 amendment.

Economic and operational impact

The impact of this amendment is not purely regulatory: it has direct consequences on the operations and costs of the affected companies.

• System adaptation costs: If calculation methods or reporting deadlines change, companies will need to update their stock management platforms and communication flows with the network manager.
• Risk of administrative penalties: Non-compliance with minimum stock obligations may result in significant administrative penalties, as expressly stated in the regulation. The energy sector has a serious penalty regime for this type of infringement.
• Impact on procurement planning: If mandatory storage thresholds are modified, companies will need to adjust their procurement planning and supply contracts to ensure compliance at all times.
• Coordination with the network manager: The regulation reinforces the need for operational coordination with the natural gas network manager, which may involve new communication or reporting protocols.

The context of gas market volatility makes compliance with these obligations particularly sensitive: the costs of maintaining additional stocks can be high during periods of elevated prices, but the risk of penalties for non-compliance adds additional pressure to management.

Who is affected?

This amendment directly affects companies in the gas sector that were already subject to Orden TED/72/2023. Specifically:

• Natural gas operators with an obligation to maintain minimum security stocks.
• Natural gas suppliers subject to the mandatory minimum stocks regime.
• Compliance and operations managers at companies in the gas energy sector.
• CFOs and financial directors of gas companies, due to the impact on procurement planning and the risk of penalties.
• Legal advisors and consultants in the energy sector who support these companies.

If your company does not operate or supply natural gas in Spain, this regulation does not directly affect you.

Practical example

A natural gas supplier operating in Spain that had its procedures adapted to Orden TED/72/2023 must now carry out the following review exercise:

Suppose the company reported its minimum stocks on a monthly basis and calculated the mandatory threshold according to the methodology established in 2023. If Orden TED/306/2026 changes the reporting frequency to fortnightly or modifies the threshold calculation method, the company will need to:

1. Update its internal stock management system to reflect the new calculation method.
2. Adjust communication flows with the gas network manager to comply with the new deadlines.
3. Review its procurement contracts to ensure it can maintain the new threshold at all times, especially during periods of high demand or elevated prices.

The cost of not carrying out this review in time is the risk of incurring significant administrative penalties for non-compliance with minimum stock obligations — a risk that the energy regulator treats with particular rigour given the impact on national supply security.

What should companies do now?

1. Obtain and read the full text of Orden TED/306/2026 in the BOE to identify exactly which articles of Orden TED/72/2023 are amended and in what way.
2. Compare the new requirements with current internal procedures: storage thresholds, calculation methods and reporting deadlines. Document the differences.
3. Update stock management systems to reflect the new calculation methods or thresholds if they have changed, ensuring traceability and auditability.
4. Review coordination protocols with the natural gas network manager to adapt them to the new operational requirements.
5. Adjust procurement planning if mandatory storage thresholds have changed, particularly ahead of periods of high demand.
6. Confirm the exact entry into force date in the full text of the regulation and establish an adaptation plan with clear milestones before that date.
7. Document the adaptation process to be able to demonstrate compliance to the regulator in the event of an inspection or request.

Official source

View the full regulation at the official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-7440