Key data
| Regulation | Order TED/1179/2026, of November 5 |
|---|---|
| BOE Publication | November 7, 2026 |
| Entry into force | November 11, 2026 (strike day) |
| Affected parties | Companies and workers in the hydrocarbon sector, gas stations and gas distribution |
| Category | Energy |
| Minimum service at gas stations | 20% of operating stations per region |
| BOE Reference | BOE-A-2026-23370 |
On November 11, 2026 there is a general strike in Spain. The Order TED/1179/2026 sets the rules for the energy sector: which facilities must remain open, which personnel cannot join the strike and which companies have specific obligations that day. If you manage a gas station, operate gas infrastructure or work in a refinery, this regulation directly affects you.
What does this regulation establish?
Order TED/1179/2026 responds to the call for a general strike on November 11, 2026 by Spain's main unions. Its objective is to guarantee minimum energy supply during the strike. It establishes differentiated obligations depending on the type of facility:
| Type of facility | Minimum service obligation |
|---|---|
| Service stations (gas stations) | Minimum 20% operating per region, according to the Fuel Supply Facilities Census |
| Natural gas transport and distribution | Complete maintenance of operability |
| Regasification plants | Complete maintenance of operability |
| Underground gas storage | Complete maintenance of operability |
| International gas connections | Complete maintenance of operability |
| Refineries | Guarantee the safety of people and the environment |
| Operators in ports and airports | Minimum fuel supply service |
The criterion for determining which gas stations open is based on the Fuel Supply Facilities Census, applying the 20% threshold at the regional level. This means that territorial distribution matters: it is not a 20% national figure, but 20% in each region.
Personnel designated to cover minimum services who decide to join the strike incur illegality under Royal Decree-Law 17/1977. The regulation does not set specific economic sanctions in its text, but the classification of illegality has direct disciplinary and labor consequences.
Economic and operational impact
For gas station operators, the main impact is organizational: they must identify which stations in their network must open and designate the personnel who will cover them. An operator with 10 gas stations in a region must ensure that at least 2 remain operational that day.
For large energy infrastructures, the impact is greater: the obligation of total maintenance means that practically all critical technical personnel are excluded from exercising the right to strike. Companies such as Enagás (natural gas transport and regasification) and Repsol Butano (distribution) have total continuity obligations in their critical facilities.
In refineries, the obligation to "guarantee the safety of people and the environment" implies keeping control, emergency and waste management systems operational, regardless of the level of strike participation.
Fuel operators in ports and airports are also subject to minimum services, which affects the supply of fuel for aviation and maritime transport during the day.
Who does it affect?
- Service station operators (gas stations): required to keep at least 20% of their facilities open per region.
- Enagás: as operator of the natural gas transport system, regasification plants, underground storage and international connections, must maintain complete operability.
- Repsol Butano: affected in its gas distribution activity.
- Fuel operators in ports and airports: must guarantee minimum fuel supply at these strategic infrastructures.
- Refineries: required to maintain safety systems for people and the environment.
- Workers designated for minimum services: cannot join the strike without incurring illegality under RDL 17/1977.
- Companies with vehicle fleets or fuel supply dependency: must plan refueling before or after 11-N.
Practical example
Imagine a distribution company that operates 15 gas stations spread across 3 regions (5 per region). Order TED/1179/2026 requires it to have at least 1 station per region operational (20% of 5 is 1). It must:
- Identify, before 11-N, which of the 5 gas stations in each region will cover the minimum service.
- Formally designate the personnel who will attend those 3 stations.
- Communicate to that personnel that their designation is binding: if they join the strike, they incur illegality under RDL 17/1977.
- Inform workers at the remaining stations that they can freely exercise their right to strike.
In the case of Enagás, as operator of critical infrastructure (transport, regasification, underground storage and international connections), the obligation is total maintenance: practically all operational technical personnel are designated for minimum services that day.
What should companies do now?
- Review the Fuel Supply Facilities Census to calculate how many stations in your region must remain open (minimum 20% per region).
- Formally designate the personnel who will cover minimum services before November 11. The designation must be communicated in writing.
- Inform designated personnel that their participation in the strike that day constitutes illegality under RDL 17/1977, with the disciplinary consequences that entails.
- If you operate critical gas infrastructure (transport, distribution, regasification, underground storage, international connections): plan total operability for 11-N, without exceptions.
- If you manage a refinery: ensure that safety systems for people and the environment are covered with designated personnel.
- If you operate in ports or airports: coordinate with the port or airport authority the level of minimum service required for fuel supply.
- Communicate with your labor advisor the situation to properly manage payroll, strike records and possible incidents on the day.
Frequently asked questions
What percentage of gas stations must open during the general strike on November 11, 2026?
Order TED/1179/2026 sets a minimum of 20% of operating service stations per region, calculated based on the Fuel Supply Facilities Census. It is not a national percentage: it applies region by region.
What happens if personnel designated for minimum services strike on 11-N?
Personnel designated for minimum services who join the strike incur illegality under Royal Decree-Law 17/1977. This can result in disciplinary and labor consequences for the affected worker.
Do Enagás and Repsol Butano have to maintain service on strike day?
Yes. Order TED/1179/2026 expressly mentions Enagás and Repsol Butano among the affected companies. Natural gas transport and distribution facilities, regasification plants, underground storage and international connections must remain fully operational.
Can refineries completely stop on November 11?
Not completely. Refineries must guarantee the safety of people and the environment, which requires keeping control, emergency and waste management systems operational, regardless of the level of strike participation.
Do fuel operators at airports and ports also have minimum services?
Yes. Order TED/1179/2026 expressly includes fuel operators at ports and airports among those required to maintain minimum services during the general strike on November 11, 2026.
Official source
Consult complete regulation at 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-2026-23370