Key data
| Regulation | Royal Decree 845/2026, of 21 October |
|---|---|
| BOE Publication | 23 October 2026 |
| Entry into force | 23 October 2026 |
| Affected parties | Mining companies, clean technology manufacturers, waste managers and public administrations |
| Category | Business Regulation |
| Reference European regulations | CRMA — Regulation (EU) 2024/1252, of 11 April 2024; NZIA — Regulation (EU) 2024/1735, of 13 June 2024 |
| Year | 2026 |
If your company operates in mining, recycling of critical materials or manufactures net-zero emissions technologies, the Royal Decree 845/2026 directly changes how you process your projects in Spain. The regulation develops the European regulations CRMA (EU Regulation 2024/1252) and NZIA (EU Regulation 2024/1735), which establish the European framework to ensure secure supply of critical raw materials and strengthen clean technology manufacturing.
The decree does not create new general obligations for all companies: its impact is primarily a procedural streamlining opportunity for the affected sectors. Those who know how to activate the mechanisms it regulates will have a real competitive advantage over those who do not.
What does this regulation establish?
Royal Decree 845/2026 articulates in Spain the instruments provided for in the CRMA and NZIA regulations. These are the specific measures it introduces:
| Measure | Description |
|---|---|
| Single point of contact (SPC) | Each autonomous community designates an SPC that centralizes all authorizations needed for strategic projects, eliminating dispersion among bodies. |
| Urgent processing | Projects declared strategic obtain priority processing in all administrative procedures involved. |
| Superior public interest qualification | This qualification facilitates environmental approval of strategic projects, reducing obstacles in environmental impact assessment. |
| Inter-administrative coordination commission | New body with public, private and civil society participation to coordinate the application of the regulation among administrations. |
| National Mining Exploration Program | Regulated framework for planning and authorizing exploration activities for critical raw materials in Spanish territory. |
| Circularity Programs | Specific regulation for recycling and recovery projects of critical raw materials from waste. |
Economic and operational impact
The impact of this regulation is not measured in fees or sanctions: it is measured in time and administrative cost saved. In Spain, large-scale mining and industrial manufacturing projects have historically dragged out authorization processes that extend for years. The decree directly attacks that bottleneck.
The main operational consequences are:
- Reduction of administrative burdens: the single point of contact eliminates the need to manage authorizations with multiple bodies independently.
- Lower risk of environmental blockage: the superior public interest qualification does not exempt from environmental impact assessment, but grants specific weight that facilitates favorable resolutions.
- Access to European financing: projects declared strategic under CRMA and NZIA have preferential access to EU financing instruments linked to the green transition.
- Sectoral planning: the National Mining Exploration Program and Circularity Programs offer a predictable framework for long-term investments.
For companies not seeking the strategic project declaration, the decree generates no new direct costs or obligations. The impact is neutral or positive depending on the sector.
Who does it affect?
- Mining companies that extract or intend to extract critical raw materials in Spain (lithium, cobalt, rare earths and other minerals strategic for the energy transition).
- Manufacturers of net-zero emissions technologies: solar panel plants, wind turbines, batteries, hydrogen electrolyzers, heat pumps and similar technologies covered by NZIA.
- Waste managers and recycling companies that recover critical raw materials from industrial or consumer waste streams.
- Autonomous public administrations, which must designate and operationalize the single points of contact provided for in the decree.
- Investors and funds with positions in the above sectors, for whom procedural streamlining improves the risk profile of their investments in Spain.
Practical example
A company that has identified a lithium deposit in Extremadura and wants to begin exploitation previously needed to coordinate authorizations with the regional ministry of industry, the environment ministry, the river basin authority and other bodies, each with its own timelines and service windows.
With the Royal Decree 845/2026, if the project obtains the strategic declaration under CRMA, the company submits all documentation to the single point of contact of the corresponding autonomous community. That SPC coordinates internally with all the bodies involved. Additionally, the project receives urgent processing and superior public interest qualification, which strengthens its position in environmental impact assessment.
The practical result: fewer interlocutors, shorter timelines and less uncertainty about the outcome of the authorization process.
What should companies do now?
- Evaluate whether your project can apply for strategic declaration under CRMA or NZIA. The criteria are set by the European regulations: check whether your activity covers critical raw materials listed in CRMA or technologies included in NZIA.
- Identify the single point of contact in your autonomous community. The autonomous communities must have designated it; contact it before starting any processing to learn about the updated procedure.
- Review your exploration or expansion plans in light of the National Mining Exploration Program. If you have pending exploration projects, this program may offer a more agile channel.
- Analyze the Circularity Programs if you operate in recycling or material recovery. They can open new business lines or facilitate existing authorizations.
- Consult with specialized advisors in mining and environmental law to prepare the necessary documentation for the strategic declaration request with guarantees.
Frequently asked questions
What is the single point of contact of RD 845/2026 and how does it work?
It is a service window designated in each autonomous community that centralizes all authorizations needed for projects declared strategic. The company submits its application to that single interlocutor, who coordinates internally with the rest of the competent bodies, reducing administrative burden and processing times.
What does it mean for a project to have superior public interest qualification?
It is a qualification granted by the decree to strategic projects that facilitates their approval in environmental impact assessment. It does not exempt from the assessment process, but strengthens the weight of the project in the balancing of interests, reducing the risk of blockage for environmental reasons.
What European regulations does RD 845/2026 develop in Spain?
It develops two regulations: the CRMA (EU Regulation 2024/1252, of 11 April 2024), on secure and sustainable supply of critical raw materials, and the NZIA (EU Regulation 2024/1735, of 13 June 2024), on manufacturing of net-zero emissions technologies.
When did Royal Decree 845/2026 enter into force?
Royal Decree 845/2026 entered into force on the same day as its publication in the BOE: 23 October 2026. There is no transitional period: its mechanisms are applicable from that date.
What are the Circularity Programs regulated by the decree?
They are frameworks specifically regulated for recycling and recovery projects of critical raw materials from waste. They are aimed at waste management and recycling companies that want to obtain authorizations more agilely within the CRMA framework.
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-2026-22079
