Spain is taking another step towards ensuring that demand no longer plays an exclusively passive role within the electricity system and can participate more directly in the energy and flexibility services markets.
The State Secretariat for Energy submitted to a hearing a proposed resolution that develops the implementation of the independent aggregator , a figure capable of bringing together multiple consumption or generation from consumers and jointly managing that energy for its purchase or sale in the electricity market.
The difference is significant: the aggregator can provide these services without being linked to the energy supplier that provides electricity to the consumer . In this way, energy procurement and flexibility management can now be carried out by different entities.
The move completes part of the pending development following the approval of Royal Decree 88/2026, which already established the rights, obligations and requirements applicable to the independent aggregator, but left essential aspects for its effective participation undefined.
Among them are three central questions: how to determine what a customer would have consumed if the aggregator had not acted, how much should be compensated for the energy mobilized, and how to settle these operations economically .
The proposal now puts numbers and methodology to those variables.
The baseline reference program will be calculated using a declarative model, which will then be adjusted using the actual measurement. This value will serve as a reference to determine the effective change in consumption caused by the aggregator's actions.
But one of the elements with the greatest economic impact is the compensation price .
The State Secretariat proposes setting it at 100% of the daily market price , which is equivalent to establishing a compensation coefficient K=1 on the energy effectively mobilized by the independent aggregator.
The aim is to prevent the intervention of this new agent from generating economic distortions for marketers and direct consumers whose scheduled energy is subsequently modified.
The cost will not fall on all demand
The chosen economic design also defines who will assume the compensations.
The proposal establishes a centralized settlement system through the system operator between the independent aggregator and the marketer whose previously scheduled energy has been mobilized in the wholesale markets.
With this, the Government rules out for the time being a mutualized model that distributes that cost among other subjects of the system.
The argument presented in the document is that mutualization would eventually be passed on to the end consumer, even if the consumer did not participate in demand response mechanisms.
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According to the State Secretariat, this scheme could lead to an increase in the final price of energy for customers not involved in these operations , without necessarily resulting in an equivalent reduction in their energy costs.
Thus, the proposal seeks to economically isolate the aggregator's activity and prevent its entry from modifying the behavior of the other participants.
More than one supplier for the same location
The package also introduces another change that could expand electricity procurement strategies for large consumers.
The General Regulation on supply, marketing and aggregation recognizes the right to maintain more than one supply contract simultaneously on the same point , provided that there is a consumption record and the third-party access contract to the network is signed directly with the distributor.
However, each production market settlement period can only be associated with one marketer .
To realize this possibility, it will be necessary to adapt the operating procedures related to measures, aggregations and information exchange between distributors, system operator, marketers and other participants.
The combination of both reforms expands the number of actors that can intervene around a single consumer: a company will be able to separate who sells it electricity from who manages its capacity to modify consumption and participate in the markets .
This is especially relevant given the growth of resources capable of shifting demand between different times, from manageable industrial processes to behind-the-meter storage and new electrified consumption.
The proposal does not establish a specific regime for batteries nor does it guarantee new revenue for these assets, but the advance of the independent aggregator expands the architecture needed for different forms of distributed flexibility to compete in an aggregated manner.
The procedures that change
To make the new scheme operational, the State Secretariat proposes to approve modifications to Operating Procedures 10.4, 10.5, 10.6 and 10.11 , in addition to creating the new PO 16.1 for the calculation of the Base Reference Program of Independent Aggregators.
Progress is also being made in individualizing measures for certain consumers.
Specifically, the proposal envisions providing individualized metering for all type 4 customers , after analyses carried out by the system operator concluded that this modification could bring substantial improvements to the measurement system without a significant cost.
Red Eléctrica had already submitted the necessary modifications to adapt the balancing conditions and operating procedures to the new model in April 2026. Some of these changes fall under the jurisdiction of the CNMC (National Commission on Markets and Competition), while others remain under the purview of the State Secretariat itself.
The effective entry of the independent aggregator will thus depend on the various regulatory and operational pieces beginning to be applied in a coordinated manner.
The result points to an electricity market in which consuming, buying energy and providing flexibility are no longer necessarily activities managed by a single agent .