With effect from 12 August 2025 an important change comes into force that will affect anyone wishing to apply for a mortgage loan in Spain. From this date, obtaining a mortgage will be impossible without a valid energy performance certificate (EPC certificate), known in Spain as the Certificado de Eficiencia Energética (CEE).
From retrospective formality to pre-condition
In Spain, people treat the energy label casually. Until now, the energy label in Spain was often considered an administrative formality that was usually only arranged by the seller at a late stage of the sales process. Not infrequently, property advertisements mention that the label is "pending", after which the document is not handed over until the execution of the deed.
Those days are quietly over. In accordance with the ministerial decision ECM/599/2025 no property valuation can take place without an officially registered energy label. Since a valuation is essential for assessing a mortgage application, banks will not consider a loan if this document is missing.
Bank's role in mortgage application
In Spain, the property is valued as part of the final credit assessment. The bank bases the maximum loan amount on the lower of the appraised value or the agreed purchase price, usually up to a maximum of 60-70 per cent. Therefore, without an appraisal report, and therefore without an energy label, the mortgage application cannot proceed.
Read more about the Spanish mortgage application process.
What does this mean in practice?
The new rule makes a clear distinction:
- For existing homes it is essential that the seller can present an already registered and valid energy label.
- For new-build homes or projects in design phase a provisional label will suffice, provided that it seamlessly matches the final registration after completion.
If the energy label is missing, the process stops. As a result, the mortgage application may be significantly delayed or even denied altogether, with all the consequences for the purchase.
Recommendation for buyers when applying for a mortgage loan in Spain
In order to avoid unpleasant surprises, we advise buyers to make reservations already during the reservation period, or at the latest before signing the preliminary sales contract (contrato de arras), to require the selling party to provide a valid energy label. It is recommended that this obligation be explicitly included in the reservation contract to include, so that you as a buyer are assured of compliance.
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