On August 12, 2025, updated regulations governing real estate appraisal for financial purposes came into effect in Spain. The new version of order ECM/599/2025, drafted by the Ministry of Economy, introduced changes to the rules in place since 2003. Now, a valid energy efficiency certificate is required for property appraisal and mortgage applications. In addition, simplified licenses have been introduced for developers, allowing construction to begin faster without waiting for traditional work permits.
During a discussion hosted by the Madrid College of Economists, representatives from banks, appraisal companies, and the construction sector reviewed the initial impact of the new requirements. In their view, energy efficiency does not currently have a noticeable effect on either property value or lending terms. However, market participants are confident that this factor will become crucial for pricing and financing accessibility in the future. Experts also emphasize the importance of unified approaches and transparency to ensure the successful implementation of the new regulations without slowing down the pace of housing supply.
Energy efficiency: currently no impact on prices
According to the new regulations, an energy efficiency certificate is now mandatory for all real estate transactions involving mortgages, sales, or refinancing. Despite this, representatives of appraisal companies and banks note that, under current conditions, the energy efficiency level does not affect market value and is not considered when issuing loans. The market continues to experience a shortage of supply, forcing buyers to choose from a limited selection without paying much attention to energy efficiency class. Experts believe the situation may change if supply increases and energy efficiency requirements start to play a more significant role.
Banks are also not reporting any changes in mortgage lending conditions since the new regulations took effect. According to representatives of major financial institutions, the innovations currently affect mainly large market players rather than individual buyers. However, as Spain progresses toward its goal of carbon neutrality by 2050, the impact of energy efficiency on the value and liquidity of housing is expected to grow.
Rising construction costs and impact on prices
The Spanish Association of Developers and Builders (APCE) points out that the implementation of sustainable construction standards leads to increased costs. According to the organization’s leadership, additional energy efficiency requirements are reflected in the final price of housing, which is especially noticeable given the already high market prices. Furthermore, industry representatives emphasize the need to consider the impact of new regulations not only on properties under construction but also on the existing housing stock. In regions with higher climate risks, such as fires or floods, this could affect demand, pricing, and insurance rates.
The need for unified standards and transparency
The banking community notes that increasing the supply of available housing requires not only financing but also reducing costs for urban development projects and speeding up the permitting process. Representatives of the financial sector stress the importance of standardization and reliable information for effective asset management and for assessing risks linked to investments in less sustainable properties or their operating expenses.
The Ministry of Economy believes that the process of implementing new requirements is just beginning, and there is still no unified methodology or sufficient volume of data. However, the ministry views the current stage as an opportunity to further advance energy efficiency in the housing sector. Climate risk experts also stress the importance of transparency and dialogue among all market participants to develop common standards and assess the long-term risks associated with climate change.
The Developers Association, together with the Spanish Federation of Municipalities and Provinces (FEMP), advocates for the unification of the simplified license framework to ensure equal conditions for all market participants across different regions of the country. According to industry organizations, this would provide greater legal certainty and accelerate the commissioning of new properties.
