Spain sets a conditional 10% VAT rate on electricity and gas for November and December 2026

What changed in detail

Real Decreto-ley 25/2026 of 29 September 2026 (BOE no. 241, 30 September 2026, BOE-A-2026-20265) entered into force on 1 October 2026. It provides a conditional 10% VAT rate for November and December 2026.

Electricity trigger: if the September 2026 CPI for subclass 04.5.1.0 Electricity is more than 15% above September 2025, per INE’s October release, 10% applies in November 2026 to supplies, imports and intra-EU acquisitions of electricity. It covers holders of contracts with contracted power up to 10 kW and severely vulnerable bono social recipients.

The same test on subclass 04.5.2.1 Natural gas triggers 10% for natural gas, biomass briquettes and pellets, and firewood.

Article 19 repeats the mechanism for December 2026, based on October 2026 CPI.

The decree-law is subject to validation by the Congreso de los Diputados within 30 days of publication; no validation had been published as of 5 October 2026.

What it means

This depends on a number that has not been published yet. Whether November carries 10% turns on INE’s October release of the September CPI, so suppliers cannot fix their November rate until then.

The electricity relief covers only the stated customer groups, not all electricity supply. Billing systems need two rate paths for November and a second decision for December, and the decree-law’s validation by Congress adds further uncertainty.