Navarra Biomethane Moratorium Until 2028: What It Means for Developers and the Agro-Livestock Sector

Key data

If you have a biomethane plant project in Navarra—or are considering one—you need to know that Foral Law 15/2026 closes the door to new processing until the end of 2028. It is not a minor restriction: it is a complete paralysis of the sector for facilities managing third-party waste in Navarrese territory.

The regulation extends and expands the moratorium that was already initiated in November 2025, and adds a specific precautionary suspension for large-capacity projects that were in active processing. The stated objective is to ensure equal requirements between projects and protect the population through rigorous regulation with citizen and institutional participation before any new facility is authorized.

What does this regulation establish?

Foral Law 15/2026 amends Foral Law 17/2020, of December 16, regulating Activities with Environmental Impact in Navarra. The specific changes are as follows:

In operational terms: any private developer who wants to build an anaerobic biomethane plant to manage organic, agro-food or livestock manure waste from third parties in Navarra cannot initiate processing until the moratorium expires or new foral regulation enters into force.

Economic and operational impact

The most direct impact is the paralysis of investments in a sector that in recent years has attracted significant private capital throughout Spain. For developers with ongoing projects, there are two differentiated scenarios:

• Projects with capacity exceeding 100,000 t/year in authorization phase as of July 15, 2026: are placed under immediate precautionary suspension. This implies that the administrative procedure stops, with the consequent opportunity cost, immobilized financing and possible contractual penalties with suppliers or partners.
• New projects (any capacity, third-party waste): cannot initiate processing until December 31, 2028 at the earliest. Any investment in engineering, licenses or prior agreements remains in abeyance.

For the Navarrese agro-livestock sector, the moratorium limits options for externalizing livestock manure management through private biomethane plants, which can increase costs or complicate organic waste management in medium and large operations.

The only operational relief is the exclusion of self-management plants with capacity below 25,000 t/year, which can continue to be processed. This opens a path for operations that manage their own waste without depending on third parties.

Who does it affect?

• Private developers of anaerobic biomethane plants in Navarra that manage third-party waste (organic, agro-food or livestock manure).
• Projects with capacity exceeding 100,000 t/year that were in authorization phase on July 15, 2026: affected by immediate precautionary suspension.
• Investors and funds with positions in biogas or biomethane projects in Navarra.
• Navarrese agro-livestock operations that depend on external plants for manure management.
• Navarrese agro-food companies that need to externalize the management of their organic waste.

Not affected:

• Self-management plants with capacity below 25,000 t/year.
• Public facilities for domestic waste management.
• Public facilities for wastewater management.

Practical example

Imagine a development company that in July 2026 had in processing an anaerobic biomethane plant in Navarra with a capacity of 120,000 t/year to manage livestock manure from pig farms in the area.

By exceeding the threshold of 100,000 t/year and being in authorization phase on July 15, 2026, the project is placed under immediate precautionary suspension from the entry into force of the law (October 7, 2026). The company cannot continue the administrative procedure until:

• The moratorium expires on December 31, 2028, or
• New specific foral regulation enters into force (date still undetermined).

In contrast, a Navarrese agricultural cooperative that wants to build a self-management plant of 20,000 t/year to manage its own organic waste without receiving it from third parties is not affected by the moratorium and can continue with its processing normally.

What should companies do now?

1. Verify if your project is under precautionary suspension: if you had a plant with capacity exceeding 100,000 t/year in authorization phase on July 15, 2026, the procedure is paralyzed. Communicate it to your legal and financial team immediately.
2. Review contracts with suppliers and partners: suspension can trigger force majeure clauses or penalties. Analyze the agreements signed before any contractual deadline expires.
3. Evaluate if your project can be converted to self-management: if capacity is below 25,000 t/year and you do not manage third-party waste, the moratorium does not apply. Assess whether the business model can be adapted.
4. Monitor the new specific foral regulation: the moratorium can cease before December 31, 2028 if the foral regulation being developed enters into force. Following its processing is key to anticipating market reopening.
5. Explore alternative waste management solutions: agro-livestock operations that depended on external plants should seek alternative solutions for manure management while the moratorium lasts.

Official source

Consult complete regulation in official source

Notice: 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-2026-20747