Investment approach
Minimum energy rating for renting out: what the law requires
There is no minimum letter for letting; the certificate itself is mandatory. What goes with the contract, what fines apply and what changes when Spain transposes the EU directive.
As of 14 October 2026 there is no minimum energy rating for letting a home in Spain: what is mandatory is the energy performance certificate itself (certificado de eficiencia energética, CEE), not the letter on it. When letting to a new tenant, a copy of the energy label is attached to the contract, and the rating is stated in every advertisement (art. 17 of Real Decreto 390/2021). The certificate is valid for up to 10 years, and up to 5 years for rating G (art. 13).
The certificado de eficiencia energética is a document from an accredited technician with a calculated estimate of the home's energy consumption and emissions on a scale from A to G. It is needed on a sale and when letting to a new tenant (art. 3.1.b).
What the law requires of a landlord today
The requirements concern documents and information, not the quality of the home. The full set for a flat in Catalonia:
| Requirement | When | Rule |
|---|---|---|
| A certificate registered in Catalonia: without registration it is not valid | Before offering the flat to the market | art. 3 and 6.6 RD 390/2021 |
| The energy rating in the advertisement | In any advertising, on a portal and at an agency | art. 15.2 and 17.3 RD 390/2021 |
| A reference to the certificate and to the cédula (habitability certificate) in the rental offer | Before receiving any money from the tenant | art. 61.2.i Llei 18/2007 |
| A copy of the label as an annex to the contract | At signing | art. 17.2 RD 390/2021 |
| Recommendations for use for the tenant | At signing | art. 17.2 RD 390/2021 |
| Renewal of the certificate | No later than 10 years, for rating G 5 years | art. 13 RD 390/2021 |
Since 23 July 2026 there has been a new requirement for the technicians themselves: the technician who issues the certificate files a declaración responsable (a sworn declaration of compliance) in their autonomous community and must have suitable qualifications or complete a course (Real Decreto 659/2025, art. 4 bis and 4 ter of RD 390/2021). Before ordering a certificate it is worth asking the technician whether the declaration has been filed.
How the certificate works on a sale and why it is arranged before the listing is covered in the article on the energy certificate.
Where the myth of a minimum rating comes from
The myth comes from the European directive. Directive (EU) 2024/1275 on the energy performance of buildings (EPBD) set 29 May 2026 as the general deadline for transposing most of its rules into national law. According to an analysis by Green Building Council España, relayed by Tinsa in its blog of 9 July 2026, by that date Spain had transposed 60% of the 155 provisions, and the new Europe-wide certificate scale has not yet been introduced.
Two practical things follow for a flat owner. First, Spanish law today does not prohibit letting a home with a low rating. Second, the letter on the certificate may change without any refurbishment: according to the same Tinsa material, primary-energy factors will change along with the share of renewable energy in the grid, and some buildings will shift on the scale. Decisions on expensive refurbishment for the sake of a letter are better taken once the rules are published in the BOE (Spain's official gazette).
What the fines are for letting without a certificate
The fines are set by a national law and imposed by the autonomous community (disposiciones adicionales 12 and 13 of the TRLSRU, the consolidated urban land and rehabilitation law).
- Minor infringement, 300–600 €: an advertisement without the rating, no label, a lapsed renewal.
- Serious, 601–1,000 €: letting a flat without giving the tenant a valid registered certificate.
- Very serious, 1,001–6,000 €: stating in advertising a rating with no valid registered certificate behind it.
If the gain from the infringement exceeds the fine, the fine is set equal to the gain (DA 13.2).
Does improving the rating pay off: a worked example
Worked example, not a forecast. An owner lets the flat as the tenant's main home and replaces the windows. The work costs 12,000 € excluding IVA, materials make up 35% of the amount, and the building was completed more than two years ago.
| Option | IVA | Total |
|---|---|---|
| General rate 21% | 2,520 € | 14,520 € |
| Reduced rate 10% | 1,200 € | 13,200 € |
From 1 December 2026, Real Decreto-ley 29/2026 extends the 10% rate to refurbishment of homes let as the tenant's main home, whatever the landlord's status, if the building was completed at least two years before the works and the contractor's materials do not exceed 40% of the base (art. 7 of Real Decreto-ley 29/2026). The decree-law has been in force since 8 October 2026, but the Congress of Deputies has not yet validated it, so before ordering works check the current wording with an asesor fiscal (tax adviser). How IVA (VAT) on refurbishment works for an investor in general is described in the article on IVA in refurbishment and purchase.
The tax saving does not answer the main question: whether the refurbishment will pay back through rent or the sale price. The link between the rating and the price is covered in the piece on energy efficiency and price.
When a low rating does not suit letting
Legally, rating G prevents nothing. In practice it works against the owner in three cases. The first: the tenant is a company whose internal requirements for staff housing are higher than the law, in more detail in the article on letting a flat to a company. The second: the flat competes with similarly priced ones, and high heating bills decide the tenant's choice. The third: a rating G certificate is valid for only 5 years and will have to be renewed twice as often.
Questions and answers
Can a flat with rating G be let in Spain?
Yes. The law currently sets no minimum rating for letting; a valid registered certificate is mandatory. For rating G it is valid for up to 5 years.
Is a new certificate needed for every new tenant?
No, if the certificate has not expired and the flat has not changed substantially. A copy of the label is attached to each new contract.
What is the fine for letting without an energy certificate?
Letting a flat without giving the tenant a valid registered certificate is a serious infringement with a fine of 601–1,000 €. If the gain from the infringement is larger, the fine equals the gain.
Will letting flats with a poor rating be banned?
EU Directive 2024/1275 requires new rules from Spain, but current Spanish law has no ban on letting by rating. New rules should be checked in the BOE on the date of the transaction.
Who can issue an energy certificate in Catalonia?
A technician with suitable qualifications who, since 23 July 2026, has filed a declaración responsable in their autonomous community. The certificate is then registered in Catalonia.
