Until a few months ago the debate was focused on the need to develop a capacity market or accelerate renewable hybridization, now different regulatory signals are beginning to align that expand the role of batteries within the electricity system.
The new black start procedure, the release of capacity for new consumption, the future implementation of flexible access permits and the growth of storage associated with self-consumption make up a scenario that, although still incipient, is beginning to reinforce the bankability of projects.
"It can be another source of income. As with the other services that storage can provide, it will surely bring more legal certainty for banks," said Edixon León , Head of Regulation at APPA Almacenamiento , in conversation with Energía Estratégica .
The approval of the operating procedure that regulates the autonomous start-up service represents one of the most relevant regulatory advances for storage in recent months.
However, the participation of batteries will not be immediate.
The first phase will be supported mainly by conventional facilities already included in the Service Replacement Plans.
"The second phase is the one that really interests the sector, because that's where storage and other technologies that can provide this service could participate," León points out.
According to him, that timeframe places the possible incorporation of batteries around 2031 .
Meanwhile, developers will need to prepare their facilities to meet the technical requirements of the service. Today, virtually all manufacturers incorporate the necessary electronics for autonomous starting.
"Those who do not have it must adapt and comply with the technical requirements established by the procedure."
Demand is shaking things up again.
Added to that signal is the recent reconfiguration of the access map for new consumption.
The update published by Red Eléctrica on July 1 left an additional 20882 MW for non-CEP demand , within a broader process that also incorporated 12405 MW for CEP facilities and 32424 MW for storage .
Part of that capacity emerged after the review of the technical criteria applicable to installations connected by power electronics and after the repeal of article 13.6 of Royal Decree-Law 7/2026, which had allowed reserving released capacity at certain nodes.
The move reopened margins in points of the network that until then had no capacity for new consumption, but it does not imply that all those megawatts are immediately available or that they can be automatically allocated.
Red Eléctrica had already warned that only around 25% of the transmission network nodes had capacity for new demand. Furthermore, since 2022, 11.8 GW of access permits for consumption had been granted but had not yet become operational , a volume equivalent to approximately a quarter of the country's current demand.
In this context, APPA Storage sees a new window for industrial projects, data centers, hydrogen production, charging infrastructure and batteries when they act as consumers of the grid.
“Any firm demand can take advantage of that capacity. There may also be projects related to storage and flexible demand,” Edixon León points out.
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Flexibility is starting to become an asset.
The new scenario coincides with the public consultation opened by the CNMC to implement flexible access permits in transport and distribution.
The proposal will allow certain consumption to be connected even when there is no firm capacity, provided that they accept time limitations, power reductions or occasional disconnections.
Among the projects contemplated, storage is expressly mentioned when it acts as demand.
The regulatory evolution responds to a reality that the sector has been pointing out for months: the network needs resources capable of providing flexibility.
"Distribution and transport networks are overwhelmed. That's where storage plays a key role."
The next step in self-consumption
Storage behind the counter is also starting to gain prominence.
Unlike large plants connected to the transport network, this segment avoids much of the administrative complexity associated with access permits, connection and guarantees.
"Behind-the-meter storage has been simpler to implement. Although there are still some issues to regulate, it is much easier to deploy than a plant that requires all that paperwork."
The change comes at a time when Spain already exceeds 9.5 GW of installed self-consumption , a figure that, for APPA, marks the beginning of a new stage for the market.
"The next stage of self-consumption will be with storage, or it won't happen at all."
The sector agrees that none of these measures will, on its own, solve the economic challenge of the projects.
However, the accumulation of new opportunities is beginning to change the storage business model.
Network services, new access methods, flexible demand, self-consumption with batteries and future mechanisms such as black start are beginning to shape a scheme in which income no longer depends on a single source.
Photography also reflects the evolution described by other market players.
In recent weeks, UNEF warned that photovoltaic projects without storage are finding it increasingly difficult to close competitive PPAs, while hybrid solutions and batteries are beginning to capture more value.
At the same time, the release of capacity on the grid and the future regulation of flexible permits show that storage is no longer just a complement to renewable integration and is becoming a necessary resource for the operation of the electricity system.
In this context, the bankability of BESS no longer depends on a single major regulatory reform, but on the progressive accumulation of signals that expand their services, diversify their income and strengthen their role within the Spanish electricity market.