Key data
| Regulation | Order HAC/976/2026, of 15 September |
|---|---|
| Publication | 18 September 2026 |
| Entry into force | 18 September 2026 |
| Affected parties | Companies and contractors with active contracts with Public Administrations |
| Category | Public Sector — Administrative Contracting |
| Period covered | First quarter of 2026 (January-March) |
| Legal basis | Article 103 of Law 9/2017 on Public Sector Contracts |
If your company executes contracts with the State, autonomous communities, municipalities or other public bodies, you have the right —and in some cases the obligation— to review the contract price based on the variation in costs. The Order HAC/976/2026 publishes the official indices that make this calculation possible for the first quarter of 2026. Ignoring them is equivalent to renouncing legitimate compensation.
What does this regulation establish?
Order HAC/976/2026 fulfills the periodic obligation of the Ministry of Finance to publish the price indices that serve as a reference for the review of public sector contracts, in accordance with article 103 of the Law 9/2017 on Public Sector Contracts (LCSP).
Indices are published for four major categories:
- Labour: cost of labour in works and services contracts.
- General materials: aluminium, cement, energy, copper, wood and bituminous materials, among others.
- Specific materials for armament and equipment: applicable to defence and security contracts.
- Components of regular road passenger transport: fuel, lubricants, tyres, spare parts and labour in the sector.
Below are the materials and components with highlighted data in the summary of the regulation:
| Material / Component | Observation Q1 2026 |
|---|---|
| Fuel (road transport) | Index of 151.622 in March (base December 2017) — notable increase |
| Bituminous materials | Highlighted increase in the quarter |
| Energy | Highlighted increase in the quarter |
| Aluminium | Included in general materials indices |
| Cement | Included in general materials indices |
| Copper | Included in general materials indices |
| Wood | Included in general materials indices |
| Labour (general) | Included in labour indices |
| Materials for armament and equipment | Specific indices for defence contracts |
Economic and operational impact
Price review in public contracts is not automatic: the contractor must request it, prove that their contract has a review clause and apply the corresponding polynomial formula using the published indices. An error in this process —or failing to initiate it— can mean absorbing cost variations that the regulation allows to be passed on to the Administration.
Q1 2026 data shows particularly intense pressure on three items:
- Fuel: with an index of 151.622 (base December 2017), the accumulated price increase since the base date exceeds 51%. For road passenger transport companies with public contracts, this component can represent a very significant part of the review.
- Energy and bituminous materials: both with highlighted increases in the quarter, which directly impacts infrastructure works contracts and road maintenance.
- General materials (aluminium, copper, cement, wood): relevant for construction, installation and industrial supply contracts.
For Public Administrations as the contracting party, these indices are also binding: they cannot apply reviews above or below the official published values.
Who does it affect?
- Construction and development companies with public works contracts being executed during Q1 2026.
- Regular road passenger transport companies with concessions or public service contracts.
- Industrial suppliers (aluminium, copper, cement, wood) that supply the Administration.
- Defence sector companies with armament and equipment manufacturing contracts.
- Services and maintenance companies with multi-year contracts that include a price review clause.
- CFOs and financial directors responsible for settling and invoicing public contracts.
- Legal advisors and public procurement consultants who manage reviews on behalf of their clients.
Practical example
Imagine a road passenger transport concessionaire company that operates an intercity line with a public contract. Its price review formula includes a fuel component with a weight of 30% on the total contract price.
With the fuel index in March 2026 at 151.622 (base December 2017), and assuming that in the contract reference period the index was 130, the applicable variation would be approximately 16.6% on that component. If the contract invoices €500,000 quarterly, the fuel component represents €150,000, and the applicable review would amount to approximately €24,900 additional to claim from the Administration for that quarter.
This calculation is indicative and depends on the specific polynomial formula of the contract, but it illustrates why not initiating the review process can mean a real and quantifiable economic loss.
What should companies do now?
- Identify your active public contracts with a price review clause. Not all contracts include it; check the particular conditions of each one.
- Locate the polynomial formula applicable to your contract. Each type of contract has an official formula that weights the different indices (labour, materials, energy, etc.).
- Download the official Q1 2026 indices published in Order HAC/976/2026 and apply them month by month (January, February and March).
- Calculate the corresponding review and prepare the supporting documentation to present it to the contracting body.
- Submit the review request within the deadline. Delays in the request can limit or prevent the right to compensation.
- If you manage defence or passenger transport contracts, pay special attention to the specific indices published in this Order, which differ from the general ones.
Frequently asked questions
What fuel index applies to road passenger transport contracts in Q1 2026?
The fuel index published in Order HAC/976/2026 for March 2026 is 151.622, taking December 2017 as the base month. This is the most highlighted value of the quarter and the one with the greatest impact on regular road passenger transport contracts with a price review clause.
Do all public contracts have the right to price review with these indices?
No. Only contracts that expressly include a price review clause and meet the requirements of article 103 of Law 9/2017 on Public Sector Contracts can apply these indices. It is essential to review the particular conditions of each contract before initiating any claim.
What materials record highlighted increases in the first quarter of 2026?
According to Order HAC/976/2026, the materials with the most notable increases in Q1 2026 are fuel (index 151.622 in March, base Dec-2017), bituminous materials and energy. Indices are also published for aluminium, cement, copper and wood, although without highlighting exceptional variations in the official summary.
When did Order HAC/976/2026 enter into force?
Order HAC/976/2026 was published and entered into force on 18 September 2026. The indices it publishes are applicable to contract reviews corresponding to the first quarter of 2026 (January, February and March).
What happens if I do not request a price review in my public contracts?
If you do not request the review within the deadline and in the proper form, you may lose the right to the economic compensation that corresponds to you for the variation in costs. The review is not applied automatically: the contractor must initiate the process, provide the documentation and present it to the corresponding contracting body.
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-2026-19466
