Benchmarking SME decarbonisation policies ‑ Country notes: Spain
Table of contents
Introduction
Copy link to IntroductionThis country note highlights recent decarbonisation trends in Spain, examines information on the environmental footprint of Spanish SMEs, and outlines main government policies for SME decarbonisation. Spanish SMEs are responsible for 39% of GHG emissions in the national business sector. Despite this, as of 2024, 59% of Spanish SMEs do not have a decarbonisation strategy in place or plans to adopt one. To support SME decarbonisation, the government provides a range of services, many of which are linked to measures under Spain’s National Recovery and Resilience Plan (RRP). These include green skills training programmes and Strategic Projects for Economic Recovery and Transformation (PERTEs), some of which support industrial SMEs in decarbonising and adopting circular economy production models. Spain also offers green loans via a dedicated green credit line, through which the national development bank (ICO) in collaboration with commercial banks channels green financing to SMEs. To encourage GHG emissions tracking and action, Spain provides SMEs with free carbon footprint measurement tools.
SMEs in the green transition
Copy link to SMEs in the green transitionSpain’s progress on the decarbonisation of the economy
Copy link to Spain’s progress on the decarbonisation of the economySpain has significantly decoupled GHG emissions from economic growth since the mid-2000s. By shifting to less carbon-intensive energy sources, Spain has successfully lowered CO2 emissions from energy use, bringing them increasingly below the level of total primary energy supply (Figure 1). This has been achieved through the development of the renewables sector, supported through feed-in tariffs and auctions (OECD, 2023[1]). Currently, renewables account for 42.7% of power generation, compared with 38.2% across Europe (IEA, 2023[2]). The largest sources of CO2 emissions in Spain in 2022 were the transport sector (43% of total energy-related CO2 emissions), followed by supply of electricity and heat (23%) (IEA, 2023[3]). Significant challenges remain, especially in addressing emissions from sectors outside the EU Emissions Trading System (ETS) regime, such as agriculture, transport, and buildings, which make up 60% of total GHG emissions. While efforts like the elimination of fossil fuel subsidies and the planned introduction of ETS21 aim to close these gaps, more robust carbon pricing and sector-specific measures are needed to align with EU targets (OECD, 2023[1]). A recent study by the Bank of Spain shows that if the ETS scheme covered the entire economy, Spain could achieve a 14.5% cut in total emissions. If, in addition, the rate increased from EUR 75 per tonne to EUR 100 per tonne, an estimated cut of 31.1% could be achieved (Aguilar, González and Hurtado, 2022[4]).
Figure 1. Decoupling of GHG emissions from economic growth, Spain
Copy link to Figure 1. Decoupling of GHG emissions from economic growth, SpainIndex 1990 = 100
Note: GHG emissions exclude emissions/removals from land use, land-use change and forestry.
Source: OECD Economic Surveys: Spain 2023 (OECD, 2023[1]).
The environmental footprint of SMEs
Copy link to The environmental footprint of SMEsBased on estimates from the OECD dashboard of SME greening and green entrepreneurship indicators (OECD, 2023[5])2, Spanish SMEs account for 39% of GHG emissions in the whole business economy3 and 36% in manufacturing, respectively, 2 and 6 percentage points above the EU average, which mostly reflects the larger size of the SME sector in Spain compared to the rest of the EU (Figure 2; Panel A).
Emission intensity, on the other hand, is affected by different factors such as the industry composition of the SME business segment (i.e. some sectors are more carbon-intensive than others), the average efficiency of production (i.e. outdated methods and equipment will result in higher emissions), as well as the national energy mix (i.e. at parity of energy consumption, a higher share of renewables will imply lower carbon intensity). In this case, SME carbon emission intensity, which is measured in terms of kilogrammes of CO2-equivalent per US dollar of value-added, is 10% lower in Spain than in the EU in the whole business economy, but 48% higher in Spain than in the EU in the case of manufacturing. As noted earlier, this may reflect a higher-than-average weight of energy-intensive manufacturing (e.g., cement, steelmaking, petroleum-related products) in Spain, but also production methods which need upgrading, especially in traditional sectors such as ceramics and textiles (Figure 2; Panel B).
Therefore, while the decarbonisation of manufacturing and construction has been an important driver of decarbonisation in the Spanish economy (-33% since 2005) (OECD, 2023[1]), there is still scope for efficiency improvements in the SME business segment to achieve the target of net zero emissions by 2050, as also illustrated in Figure 1.
Figure 2. SME share of GHG emissions in the business sector and manufacturing, Spain, 2018
Copy link to Figure 2. SME share of GHG emissions in the business sector and manufacturing, Spain, 2018
Note: Output weight is the SME share of value added at two-digit sector level. GHG emissions computed at two-digit sector level based on the application of an output weight corresponding to the SME share of value added. To calculate emission intensity, SMEs’ total GHG emissions are then divided by SMEs’ total value added.
Source: OECD calculations based on (OECD, 2023[5]).
SME actions towards the green transition
Copy link to SME actions towards the green transitionTurning the attention to greening actions by Spanish SMEs, based on 2024 data from the Eurobarometer Survey, the share of Spanish SMEs that have a climate-neutrality strategy is more or less on par with the EU average (21% vs. 22%). However, a higher proportion of Spanish businesses lack such a strategy and do not intend to implement one: 59% of Spanish SMEs neither have a strategy nor intend to adopt one, against 53% of EU respondents. Also, 14% of Spanish SMEs do not have a climate strategy in place but are planning to implement one, compared with 19% across the EU (Figure 3)
On the other hand, the share of Spanish SMEs adopting actions to become climate neutral is above the EU average. Interestingly, none of the surveyed Spanish SMEs reported taking no actions toward climate neutrality, compared with an average of 5% of SMEs across EU countries (Figure 4). Most Spanish SMEs (41%) reported "generally reducing company emissions", above the EU average (34%), followed by “investing in or developing new technologies to reduce emissions” (31%) and “developing new technological solutions to reduce emissions” (24%), on par with EU averages. Overall, together with little propensity to have a climate-neutrality strategy in place, this suggest that the greening actions of Spanish SMEs might mostly be driven by regulatory considerations and (public) financing opportunities, rather than as part of a coherent business strategy towards net-zero emissions.
Figure 3. SMEs with a strategy towards climate neutrality, Spain, 2024
Copy link to Figure 3. SMEs with a strategy towards climate neutrality, Spain, 2024
Note: Question: Does your company have a concrete strategy in place to reduce your carbon footprint and become climate neutral or negative? (Excluding the following answer options: Don’t Know / No response; Other). The sum of percentages may not add up to 100% due to rounding of numbers.
Source: (European Commission, 2024[6])
Figure 4. SME actions towards climate neutrality, Spain, 2024
Copy link to Figure 4. SME actions towards climate neutrality, Spain, 2024
Note: Question: What actions is your company undertaking to be become climate neutral? (Excluding the following answer options: Don’t Know / No response; Other). The sum of percentages may not add up to 100% due to rounding of numbers.
Source: (European Commission, 2024[6])
Spanish SMEs are also more likely than the EU average to implement resource efficiency measures. The most common action taken by Spanish SMEs is energy-saving, followed by waste minimisation and material efficiency (Figure 5; Panel A). For other key resource efficiency actions, such as recycling and water-saving measures, Spanish SMEs maintain a more pronounced lead over the EU average. For instance, 77% of Spanish SMEs engage in recycling compared with 48% in the EU, and 73% implement water-saving measures versus 49% at the EU level. These efforts reflect Spain's pressing challenges with water scarcity, which disproportionately impact SMEs in water-intensive sectors like textiles.
However, Spanish SMEs are also more likely than the EU average to report barriers to the implementation of resource efficiency actions. Key barriers include complex administrative requirements (53% in Spain; 35% EU average), high costs associated with environmental actions (47% and 28% respectively), and limited access to environmental expertise (46% and 24%) (Figure 5; Panel B). When asked about policies that could facilitate resource efficiency adoption, SMEs most often cited grants and subsidies (46%), consultancy services (38%), and better guidance on funding opportunities (33%) (Figure 5; Panel C), which reflects the cost and skills-related barriers identified as top concerns by the surveyed businesses.
Figure 5. Resource Efficiency Measures put in place by SMEs and barriers to implementation, Spain, 2024
Copy link to Figure 5. Resource Efficiency Measures put in place by SMEs and barriers to implementation, Spain, 2024As a percentage of surveyed SMEs
Note: Top 5 actions, barriers and policy drivers displayed in Panel A, B and C. Question for Panel A: What actions is your company undertaking to be more resource efficient? ; Question for Panel B: Did your company encounter any of the following difficulties when trying to set up resource efficiency actions?; Question for Panel C: Which of the following would help your company the most to be more resource efficient?; Some answer options have been rephrased to improve readability.
Source: (European Commission, 2024[6])
Government policies for SME carbon neutrality
Copy link to Government policies for SME carbon neutralityThe Spanish Plan for Recovery, Transformation, and Resilience
Copy link to The Spanish Plan for Recovery, Transformation, and ResilienceSpain’s efforts to support SME decarbonisation are mainly articulated within the framework of the national Recovery and Resilience Plan (RRP). Launched in 2021, the Plan outlines how Spain will use funds from the Next Generation EU programme to recover from the COVID-19 pandemic and address long-term challenges. The Plan focuses on four key areas: the green transition, digital transformation, social and territorial cohesion, and gender equality. At the end of 2024, the RRP had already disbursed EUR 42.6 billion and about 20% of Spanish SMEs had received support from the RRP between 2021 and 2024, corresponding to 39.5% of total RRP funding (EUR 16.2 billion).4
The national RRP includes specific components encompassing both investments, which come with a financial allocation, and legislative reforms. In 2023, an addendum to the RRP was published, which built on the results of the first phase of the Plan (2021-2023), with the objective of strengthening the strategic re-industrialisation of the country. The addendum mobilises an additional EUR 10 billion in transfers, EUR 7.7 billion from the Recovery and Resilience Fund and over EUR 2.7 billion from the RePowerEU programme5, as well as EUR 84 billion in additional loans. It identifies 42 new investment and reform measures in addition to strengthening 8 reforms from the initial Plan with a focus on energy, industry, water, and digitalisation (Gobierno de España, 2023[7]). Overall, this will allow the RRP to mobilise around EUR 160 billion in transfers and loans over the period 2021-2026, amounting to 12% of national GDP. To these, investments foreseen in the Multiannual Financial Framework 2021-2027, including EUR 36 billion from EU structural funds, need to be added (Gobierno de España, 2023[7]).
The RRP is structured around 10 strategic levers, which are overarching thematic areas guiding the allocation of resources. Examples include the “Urban and Rural Agendas for Sustainable Development” lever, the “Just and Inclusive Energy Transition” lever and the “Industry Modernisation” lever. It is within the latter that most support measures for SME greening are included, notably under Component 12 (industrial policy), Component 13 (SME resilience) and Component 14 (tourism modernisation) (Box 1).
Box 1. Main SME greening components in Spain’s RRP
Copy link to Box 1. Main SME greening components in Spain’s RRPComponent 12: Industrial Policy Spain 2030
Component 12 of Spain's RRP aims to bolster industrial competitiveness, sustainability, and digital transformation. With a EUR 8.36 billion budget, it aims to boost industrial productivity, enhancing sustainable resource management, and supporting strategic sectors such as automotive (especially electric vehicles), agri-food, and renewable energy.
Component 13: SME resilience measures
Component 13, with a EUR 87.6 billion budget, supports SME financing, digitalisation, innovation, and growth in green and strategic sectors. Key initiatives include simplified business regulations, financial support, including a green credit line and digitalisation support. It also promotes sustainable practices in transport, energy, and waste management for SME resilience.
Component 14: Plan for the modernisation and competitiveness of the tourism sector
Component 14 allocates EUR 3.9 billion to enhance tourism resilience and sustainability, focusing on non-mainland areas. It fosters competitiveness through innovation, energy efficiency, circular economy initiatives, heritage restoration, and improved tourist hubs.
The RRP also incorporates Strategic Projects for Economic Recovery and Transformation (PERTEs), which are large-scale projects in strategic industries that align with one or several components of the Plan. PERTEs involve multi-stakeholder collaborations, including public-private partnerships with specific funding and operational plans. Examples include the PERTE for the Agro-industrial Sector, the Circular Economy, Electric and Connected Vehicles, Industrial Decarbonisation or Renewable Energies, Hydrogen, and Carbon Capture and Storage. It is under these strategic projects that most SME greening investments have been funded since 2021.
The rest of this section presents key support mechanisms both within and outside the scope of the RRP that contribute to SME carbon neutrality, classified by type of support programme. They include: support for monitoring emissions; awareness raising and training programmes; investment support programmes, mainly under relevant PERTEs; green and sustainable financing, including incentives that encourage SME compliance with sustainability reporting requirements; measures favouring the integration of sustainability criteria and enhanced SME participation in public procurement; and the role of non-governmental stakeholders as supporting entities to facilitate SME decarbonisation.
Monitoring emissions
Copy link to Monitoring emissionsIn recent years there has been a proliferation of methods and tools to measure carbon emissions at firm level, as this is seen as a precondition to comply with new sustainability reporting requirements and access the opportunities offered by sustainable finance and green supply chains. Recent OECD works map the rapid proliferation of carbon measurement tools and frameworks for SMEs and propose a core set of indicators to meet both financial institutions and supply chain needs, while keeping requirements proportionate for SMEs (OECD, 2025[10]). Furthermore, monitoring emissions may be needed to access programmes that support industry decarbonisation and to show the impact of such programmes. The following initiatives seek to encourage SMEs to monitor their carbon emissions in Spain.
Carbon Footprint, Offset, and Absorption Project Registry
The Ministry for the Ecological Transition and the Demographic Challenge (MITERD) offers a free carbon footprint measurement tool to support public and private organisations, including SMEs, in monitoring and reporting emissions. By registering in the system, organisations can access incentives, such as the option to offset their emissions through Carbon Capture Projects.6 Certified carbon absorption projects focus on afforestation with changes in land use, and restoration efforts in burned forest areas to rehabilitate existing forest cover (MITERD, 2024[11]). So far, 13 170 entities are registered, 68% of which are SMEs (8 935 in total).
To encourage registration and promote emissions tracking, MITERD awards a certification stamp to businesses that at least calculate their Scope 1 and Scope 2 emissions7. In 2024, 81% of registered SMEs have been accredited for estimating and registering their carbon footprints, 14% have committed to reduction actions, 3% have taken compensation measures, and 2% have committed to all three (calculating, reducing and compensating). The accreditation system enhances their visibility as environmentally responsible entities. Additionally, all Scope 3 emissions – as well as Scope 1 and 2 emissions for large businesses and SMEs with industrial process emissions – are verified by an independent third party (MITERD, 2024[12]).
The Spanish Ecological Public Procurement Plan (2021–2025) further supports emissions reduction by incentivising contracts with suppliers registered in the official Carbon Footprint, Offset, and Absorption Project Registry (as established by Royal Decree 163/2014) or equivalent programmes. This registry ensures that suppliers not only calculate their emissions but also have actionable reduction plans. The implementation of these criteria is gradual: by 2020, 15% of contracts were required to meet this standard, increasing to 30% in 2022, and reaching 50% by 2025 (BOE, 2019[13]).
Sustainable SME Programme by the Spanish Chamber of Commerce
As part of the Sustainable SME programme launched in 2023 by the Spanish Chamber of Commerce and co-financed by the European Regional Development Fund (ERDF), SMEs can access free expert diagnostics to measure their carbon emissions, assess energy efficiency, explore options for adopting circular economy practices, and identify ways to contribute to the Sustainable Development Goals (SDGs).8 Alternatively, SMEs can carry out a self-assessment using a web tool by the Spanish Chamber of Commerce, providing insights into their current environmental and social impact, along with tailored recommendations for further action. The programme also offers straightforward templates to assist SMEs in creating their own Annual Sustainability Reports, allowing them to set new goals and monitor their progress.9
The second phase of the programme further subsidises costs for registration in the above-mentioned Carbon Footprint Register and supports the implementation of carbon footprint reduction plans, energy monitoring technologies, improvements in energy efficiency, waste management plans or sustainable mobility plans. Administered by autonomous communities at the regional level, covered costs range between 40% and 85%, capped at EUR 7 000.10
Awareness-raising and training programmes
Copy link to Awareness-raising and training programmesThe development of green skills is a key component of Spain's Recovery and Resilience Plan, alongside digital skills acquisition, with the overarching aim of fostering inclusive and resilient labour markets. Accordingly, the Spanish government provides support for the acquisition of green skills by SMEs through government-affiliated training agencies described below. In addition to this, the national association of employers (CEOE) and the National Association of SMEs (CEPYME) propose training programmes for the acquisition of green skills.
Training programmes by the School of Industrial Studies (EOI) and FUNDAE
The National Foundation for Employment Training (FUNDAE) provides subsidies of up to EUR 600 for SMEs engaging in training programmes focused on green and digital competencies.11 Additionally, the School of Industrial Studies offers free training for SMEs seeking to strengthen their competitive position in areas such as internationalisation, technological integration, and innovation in products, services, or business models, including sustainability-focused approaches. For instance, the SME Industrial Transition Online Training Course guides participants in creating a roadmap to transition toward connected, sustainable Industry 4.0.12
Furthermore, FUNDAE launched the "Specific Programme for SMEs on Climate Change and Energy Transition" in 2025, with a budget of EUR 13 million. The programme assists SMEs in adapting to climate change challenges and energy transition by providing training and support to develop tailored sustainability plans. In the first phase, the programme focuses on raising awareness among SMEs through a needs assessment and offering 25 general courses on topics such as measuring carbon footprints, sustainability reporting, and environmental impact assessment. These courses, accessible through an online platform, target SMEs with little or no prior engagement in sustainability.13
Investment support programmes
Copy link to Investment support programmesSpain’s RRP includes several investment support programmes, providing a range of financial instruments – including grants, subsidies, and loan guarantees – to assist businesses with their decarbonisation efforts. These are outlined within different components of the Plan or within specific Strategic Projects (PERTEs). Most programmes are targeted to specific sectors and are open to businesses of all sizes. However, greater support is generally provided to participating SMEs.
PERTE for Renewable Energies, Hydrogen, and Storage (EHRA)
This strategic project aims to support Spain's transition to a carbon-neutral economy by focusing on reducing energy dependence. Accordingly, measures within this project support the development of technologies, industrial capabilities, and new business models with a total budget of EUR 16.3 billion. Two programs under this strategic project – New Business Models for the Energy Transition and CE-IMPLEMENTA (Energy Communities) – are highlighted for their strong alignment with the needs of the largest number of SMEs across various sectors, focusing on lower-capital projects, innovation, and community-driven models, making them particularly accessible and relevant to SMEs.
New Business Models for the Energy Transition
The programme supports SME decarbonisation and innovation in the energy sector. Launched in 2023 and 2024, the programme allocates EUR 156 million annually which is managed by Spain’s Institute for Energy Diversification and Saving (IDAE) to incentivise transformative projects that align with Spain’s RRP. It focuses on three key areas: fostering innovation in energy transition, decarbonising and integrating renewable energies, as well as supporting startups (companies aged less than 5 years) related to these fields and technologies. Funding levels are calibrated to benefit smaller enterprises more significantly in the case of the first two funding lines, with additional support available for projects that demonstrate effective collaboration or have potential for broad impact.14
Energy Communities: the CE-IMPLEMENTA programme
The CE-IMPLEMENTA was first launched in 2021 and aims to support the development of energy communities through financial support for projects related to renewable energy generation, energy efficiency, and sustainable mobility. It offers grants to public and private entities that promote community involvement in energy projects, with an emphasis on areas with demographic challenges. Each edition of the programme included two calls, one for small projects under EUR 1 million and a second for larger projects (more than EUR 1 million). The latest edition of the programme in 2024 allocated EUR 30 million for smaller-scale projects and EUR 90 million for larger-scale projects.15
PERTE for Industrial Decarbonisation
This strategic project supports the decarbonisation of the industrial sector to contribute to Spain's goal of climate neutrality by 2050. The project involves a public investment of EUR 3.1 billion, and has several objectives, including the decarbonisation of industrial production, improving energy efficiency and enhancing energy security by reducing natural gas consumption, which is significant in manufacturing, including SME-driven sectors such as ceramics, glass and food and beverage. The initiative also emphasises the use of renewable energy to reduce emissions and dependency on fossil fuels, while fostering environmental sustainability through waste valorisation and byproduct re-use.
As part of this strategic project, the support programme for the Development of Highly Efficient and Decarbonised Manufacturing Facilities stands out due to its potential to advance decarbonisation in key energy-intensive sectors where SMEs play a critical role. While the programme encompasses industries where larger firms dominate, it is particularly relevant to energy-intensive sectors like ceramics, wood pulp/paper and cardboard production, which are also characterised by a strong SME presence.
Support for the Development of Highly Efficient and Decarbonised Manufacturing facilities
This programme provides targeted financial support to manufacturing industries with high thermal power use (over 20 MW) across several decarbonisation and innovation areas. The programme supports industrial research, development, and feasibility studies, as well as funding for innovation projects (organisational and process innovation), investment in decarbonisation technologies (including carbon capture), and energy savings or efficiency measures. In addition, the programme supports environmental studies, audits, and feasibility studies directly related to these investments, providing a well-rounded approach to encourage sustainable transformation in industry. This is done through a combination of grants for early-stage projects and subsidised repayable loans for capital-intensive investments – with a maximum budget of EUR 90 million and EUR 50 million, respectively.16
Agro-industrial PERTE
This project is a comprehensive initiative targeting the value chain of the agro-industrial sector, aimed at creating the necessary ecosystem to promote the development and modernisation of the agri-food industry in Spain. This project was budgeted with an initial public investment of EUR 1 billion until 2023, and an additional EUR 800 million as part of the 2023 addendum, for the transformation of the agri-food industry and the improvement of water management and modernisation of irrigation.
The PERTE targets agents involved in the agri-food value chain, including primary production, processing, marketing, and distribution. It is divided into three areas. The first aims to improve the food industry’s production process supporting its competitiveness, sustainability and traceability, with a budget of EUR 400 million. The second involves the digital adaptation of all the agents involved in the value chain with a budget of EUR 454.35 million. The third involves support for research, innovation, and technology transfer, with a budget of EUR 148.56 million (Gobierno de España, 2022[14]). Each of these pillars encompasses various programmes with different funding conditions depending on the type and the focus area of the project as well as the size of the beneficiary. For example, projects within the first pillar offer higher aid intensity for SMEs compared to large companies, and financial support can be provided through a combination of grants and repayable loans (BOE, 2022[15]). Below, a grant programme for industrial projects in the agrifood sector is described. Under the first pillar of the initiative, it stands out as it specifically supports sustainability investments by SMEs.
Grant programme for industrial projects in the agrifood sector
The first edition of the programme awarded EUR 161.6 million in the form of grants and EUR 19.9 million as loans to more than 286 primary projects of 224 companies, with actions in 14 autonomous communities (i.e., how regions are called in Spain).17 The 2024 edition offers EUR 100 million in the form of grants for projects in three areas: R&D and Innovation, Sustainability and Energy Efficiency and SME Investment for the modernisation and digitalisation of agri-food SMEs. Eligible projects must fall under one of the main thematic priorities, including: circular economy and eco-innovation, decarbonisation, energy efficiency, new renewable energy sources and reduction of polluting emissions, advanced materials and products, innovation in quality and safety processes (MINTUR, 2024[16]). In each area, the maximum level of financial support in the form of grants is always higher for SMEs compared to larger companies. For instance, in energy efficiency projects, micro-enterprises and small businesses can receive up to 50% of covered expenses, while medium-sized enterprises are eligible for 40%, and large enterprises can only receive up to 30%. However, the total grant amount for any company’s projects cannot exceed EUR 4 million or the company’s net turnover.18
Electric Vehicles PERTE
This strategic project was launched by the Spanish government in 2021 and focuses on strengthening Spain's automotive value chain for Electric and Connected Vehicles, a crucial sector for the economy. As of June 2023, EUR 2.87 billion had been allocated to the project under the RRP, with an additional EUR 250 million in grants and EUR 1 billion in loans, raising the total funding to EUR 4.12 billion (Gobierno de España, 2021[17]). The programme described below stands out within the project because of its strategic focus on SMEs, offering targeted financial support to enhance sustainability, innovation, and energy efficiency within the electric vehicle value chain.
Aid for investment plans within the electric and connected vehicle value chain
The most recent call for proposals under Electric Vehicles PERTE, the PERTE VEC III programme, developed by Spain's Ministry of Industry and Tourism, seeks to bolster the electric and connected vehicle sector by funding projects that enhance research, innovation, sustainability, and energy efficiency. Eligible activities for funding include the industrial production activities in the electric vehicles value chain, services directly supporting the industry or IT-related activities associated with electric and connected vehicles. Organised into four primary support lines – Research, Development, and Innovation; Innovation in Sustainability and Energy Efficiency; Regional Investment Aid; and a specific SME Investment Aid – the programme provides flexible financial support through grants, repayable loans – with a budget of EUR 200 million – or combined funding. Loans are available at a fixed interest rate of 3.058%, with a 10-year repayment term and a 3-year grace period. Aid covers up to 80% of eligible project costs, with a higher subsidy rate for SMEs. In fact, in the case of small and micro-enterprises, the support can be provided entirely in the form of grants. For sustainability-focused projects, including environmental protection and energy efficiency, SMEs can receive funding for 40% to 60% of project costs, promoting sustainable growth within the electric vehicle industry (MINTUR, 2024[18]).
Circular Economy PERTE
The Circular Economy PERTE aims to accelerate Spain's transition to a more sustainable and efficient production system by adopting a circular economy model. This approach moves away from the traditional linear model of extraction-production-consumption-disposal, promoting waste reduction, product reuse, and material recycling. The programme includes EUR 492 million in subsidies, focusing on SME-driven sectors like textiles and plastics as well as renewable energy equipment (wind turbines, photovoltaic panels and batteries) and eco-design19. The programme also supports digitalisation, waste management, and business innovation to reduce environmental impact. This initiative aligns with the Spain Circular 2030 Strategy and complements other recovery programmes (e.g., renewable energy, hydrogen, and electric vehicles). As part of this strategic project, a subsidy programme targeting the promotion of the circular economy practices in enterprises stands out due to its focus on sectors such as textiles and plastics, characterised by strong SME presence.
Subsidies to promote the circular economy in enterprises
This programme offers subsidies to finance projects that contribute significantly to the sustainability and circularity of industrial and business processes. Directed at businesses of all sizes, SMEs can apply for subsidies for actions contributing to the circular economy in one of the following categories: reduction of consumption of virgin raw materials; eco-design; improvement of waste management or digital transformation of processes through infrastructures and systems. In each case, the subsidy rate is higher for SMEs. The programme has a budget of EUR 192 million and finances projects with a cost comprised between EUR 150 000 and EUR 10 million (BOE, 2022[19]).20
This programme also includes a call that specifically targets businesses in the textile and fashion sector and in the plastics sector, for the adoption of circular economy practices. Eligible companies should aim to reduce the consumption of virgin raw materials, reduce the generation of new raw materials and/or improve waste management, thereby contributing to the transition to a circular economy in one of the following categories: Research and development; Process digitalisation and organisational innovation; Increasing the level of environmental protection of the beneficiary entity or Improvement of the management of waste by third parties21. The aid granted can range between EUR 100 000 and EUR 10 million per project or beneficiary entity, with stronger cost coverage for SMEs (BOE, 2024[20]).
Green entrepreneurship: ACTIVA Start-ups
ACTIVA Start-ups is an initiative of the Ministry of Industry and Tourism, managed through the School for Industrial Studies (EOI), which specifically funds open innovation projects in which SMEs collaborate directly with tech startups. The programme focuses on innovation projects in the field of digital transformation, development and incorporation of emerging technologies, transformation towards a low-carbon economy or incorporation of the circular economy in the business model of SMEs (EOI, 2024[21]).
This call for proposals has a specific budget allocation of EUR 6.98 million under the broader EUR 44 million budget dedicated to the entire ACTIVA programme and is part of the “Capacities for SME Growth” Programme of Component 13 of the national RRP. This initiative is articulated through different types of calls: a) one call offering grants to SMEs to cover the costs of hiring the startup with which the solution is developed; b) one call for start-ups to cover the direct costs of their work in solving the challenges; c) one call providing financial aid to already formed SME-Startup consortiums that will propose and solve the corresponding challenge. This allocation aims to support at least 735 SMEs through grants covering up to 100% of eligible project costs (Gobierno de España, 2024[22]).
Green and Sustainable Financing
The ICO Green Credit Line
The Official Credit Institute (ICO), Spain’s public development bank, operates a dedicated “green” credit line featuring mediation lines with financial institutions, with SMEs as main beneficiaries. The RRP has two types of funds, grants which were mostly executed during the first phase of the plan (2021-2023) and loans as part of the second phase of the RRP (until 2026). The ICO serves as an intermediary to channel these loans, including the green credit line, to commercial banks which then lend on to SMEs. The green credit line has a budget of EUR 22 billion from Component 13 of the RRP and features four primary financial instruments targeting SME development: mediation lines with financial institutions, direct loan financing, debt securities and venture capital investments for green and digital projects managed through AXIS, ICO’s venture capital arm22. This initiative supports projects focused on sustainable transportation, energy efficiency, renewable energy, industrial decarbonisation, water management, circular economy practices, and climate change adaptation23.
Mediation lines, mainly directed at SMEs, enable financial institutions to offer loans covering up to 100% of project financing needs, integrating financial advantages provided by European Commission funds. ICO loans, which usually are sought out by larger businesses, can cover up to 70% of a project’s cost in partnership with private financial institutions, with repayment terms that can extend up to 20 years, including possible grace periods to ease financial planning by borrowers (Gobierno de España, 2024[23]; ICO, 2024[24]). Furthermore, to streamline accessibility for smaller businesses and self-employed individuals, operations below EUR 10 million may be certified through a simplified declaration of compliance with the “Do No Significant Harm” (DNSH) principle, rather than through detailed formal accreditation to ensure compliance with climate objectives, which usually applies to projects over EUR 12.5 million carried out by large businesses receiving direct ICO loan financing (innóvate 4.0, 2024[25]).
While ICO credit lines do not usually have environmental requirements, lines funded by European funds (such as InvestEU) or mandated by ministries do usually include a focus on sustainability areas, for example on sustainable mobility, housing or agriculture. For example, the ICO has a credit line for sustainable and connected mobility implemented in partnership with the Ministry of Transport, Mobility and Urban Agenda, providing complementary financing to help execute projects subsidised by EU recovery funds.24 Similarly to the green credit line, projects under this credit line can access financing through intermediary banks or directly from ICO for larger amounts. Another example is the Rehabilitation of Residential Buildings programme, which has been developed in partnership with the Ministry for Housing and the Urban Agenda and provides financing for building rehabilitation to improve energy efficiency performance. This programme benefits SME property owners but also as tenants, allowing them to benefit from reduced energy consumption. The programme provides guaranteed loans, with amounts up to EUR 30 000 per project.25
Sustainability Line by CERSA and EIF
CERSA (Compañía Española de Reafianzamiento, S.A.) is a state-owned company in Spain, regulated by the Bank of Spain and affiliated with the Ministry of Industry and Tourism, which provides reinsurance services to banks, supporting SMEs by offering guarantees on their loans, helping to reduce the risk for lenders and improving SMEs' access to credit. 26
CERSA participates in four credit guarantee lines by the EIF, including the Sustainability Line 2024 aimed at supporting businesses that promote sustainability and ecological innovation within the EU. The programme targets self-employed individuals, SMEs, small mid-cap companies, and individuals with innovative, sustainable projects. Eligible investments include renewable energy, energy efficiency, and clean technologies, with projects requiring co-financing and matching funds. The financial assistance consists of debt financing backed by the InvestEU sustainability guarantee, with the amount and terms varying based on the type of project, its value, the sustainability assessment and firm size (CERSA, 2022[26]; EIF, 2024[27]).
Investment supports outside the scope of the RRP
While the RRP covers most greening initiatives, several complementary programmes outside its scope focus on specific SME decarbonisation challenges. These include support for energy audits, efficiency incentives, and carbon cost compensation. Incentives to carry out energy audits contribute to the identification of efficiency improvements by SMEs, while energy efficiency incentives and carbon cost compensation reduce financial barriers for SMEs, supporting energy savings.
The Energy Audit framework in Spain
In Spain, the energy audit framework is also shaped after European and national regulations designed to enhance energy efficiency. Importantly, the Energy Efficiency Directive 2012/27/EU is transposed into national law through the Royal Decree 56/2016, setting specific requirements for energy audits, the accreditation of energy auditors, and the promotion of energy efficiency. The decree requires large industrial companies to conduct energy audits every four years, covering at least 85% of their total final energy consumption (BOE, 2016[28]; ODISSEE-MURE, 2021[29]). While the directive primarily targets large companies, it also encourages SMEs to adopt energy-efficient practices by providing incentives and support, contributing to broader energy savings and climate goals (BOE, 2016[30]). This was the case of a programme for the adoption of energy-saving measures and energy management systems by SMEs and large enterprises in key industrial sectors, including some with significant SME presence (e.g., textiles, food and beverage, wood and furniture etc.). In place between 2019 and 2024 and administered by the Institute for Energy Diversification and Saving (IDAE), the programme was managed regionally by Spain’s autonomous communities, the support subsidised up to 50% of eligible investment costs for SMEs and up to 30% for large enterprises, with a project cap of EUR 4 million. Due to high demand, the budget was increased from EUR 308 million to EUR 626 million and was financed by the National Energy Efficiency Fund (FNEE) described below (BOE, 2019[31]).
The National Energy Efficiency Fund and the Energy Savings Certificates System
The FNEE, managed by the Ministry for the Ecological Transition and Demographic Challenge (MITERD) via the State Secretary of Energy, is dedicated to financing programmes and support mechanisms that promote energy efficiency. These efforts include financial assistance, technical support, training, information initiatives, and other measures aimed at reducing energy consumption across various sectors (IDAE, 2014[32]).27
The Energy Saving Certificates System (Sistema de Certificados de Ahorro Energético) (CAE), launched in 2023 in Spain, allows SMEs to earn and trade certificates by implementing energy-saving measures. Each certificate, representing 1 kWh saved, can be sold to larger companies needing credits to meet their energy efficiency targets, giving SMEs a revenue stream and helping offset investment costs (BOE, 2023[33]). Before Spain, other EU countries like France (Cértificats d'Économies d’Énergie) and Italy (Meccanismo dei certificati bianchi) had implemented similar energy savings certificate systems respectively since the early 2000s (Bertoldi, 2011[34]).
Compensatory Aid for CO2 emissions costs
Spain’s Indirect Carbon Cost Compensation Programme aims to shield energy-intensive industrial sectors from the risk of adopting “carbon leakage” practices, which refer to the situation that may occur if, due to the business-related costs of climate policies, businesses were to transfer production to other countries with laxer emission constraints, resulting in an increase of their total emissions and loss of domestic jobs.
Through this programme, the Spanish government offers preferential rates in the electricity and natural gas fares for companies which operate in sectors defined as “at risk of carbon leakage” by the European Commission. The list includes heavy industries such as the manufacture of petroleum products and cements, but also SME-driven industries such as the manufacture of ceramics, glass and leather products. With a total budget of EUR 300 million, the programme distributes the compensation equitably among all accepted applicants, with the aid intensity reflecting the company’s energy intensity so as to ensure equal support for all beneficiaries. 28
Compliance with sustainability reporting requirements (SRR)
Copy link to Compliance with sustainability reporting requirements (SRR)Sustainable reporting requirements are mostly set at the EU level, primarily through two directives: the Corporate Sustainability Reporting Directive (CSRD) and the Sustainable Finance Disclosure Regulation (SFDR). While these directives have not yet been transposed into national legislation and the Spanish government does not directly provide targeted compliance support for SMEs, the main employers confederation (CEOE) offers a number of courses for companies, including SMEs, to become acquainted with the EU CSRD requirements.
The European Financial Reporting Advisory Group (EFRAG) recently published a Voluntary Sustainability Reporting Standard for SMEs (VSME), a simplified, sector-agnostic framework designed for non-publicly traded SMEs. This initiative aims to help SMEs more easily meet data demands from key stakeholders, such as larger buyers, financial institutions, and investors, while also improving their access to sustainable finance opportunities (EFRAG, 2024[35]). It introduces a two-tiered structure with a Basic Module, required for all participating SMEs, and a Comprehensive Module, which is optional and tailored to address specific stakeholder demands. Unlike large company reporting standards, the VSME does not require a materiality assessment, instead using an “if applicable” approach for certain voluntary disclosures. The framework emphasises the importance of proportionality in compliance requirements, taking into account the specific characteristics and resources of these businesses.
Insights based on interviews with selected stakeholders
Copy link to Insights based on interviews with selected stakeholdersInterviews conducted with four key stakeholders29 involved in Spain’s SME greening policies provided some additional insights on challenges and opportunities affecting existing measures.
Analysis of the Spanish RRP reveals a comprehensive coverage of the main channels to achieve a low-carbon economy, with a strong focus on the development of renewable energy, energy efficiency, industry decarbonisation, sustainable mobility, and the circular economy. Subsidies under the different PERTE programmes tend to have a higher subsidy rate for SMEs than for larger companies, reflecting a deliberate strategy to empower smaller businesses in the green transition. As of October 2024, 528 798 SMEs had benefitted from RRP support, with 39.5% of the disbursed funds having SMEs as main beneficiaries – or EUR 16.8 billion30. This targeted approach takes the form of different policy instruments and support mechanisms, including targeted investment support, sector-specific training programmes, as well as innovative approaches encouraging collaboration between SMEs and tech startups.
Regarding challenges, as highlighted in this chapter, a lack of structured climate action plans by SMEs suggests that SMEs’ green actions are mostly driven by regulatory pressures and funding opportunities, rather than proactive forward planning. Addressing this issue requires a concerted effort to raise environmental awareness and strengthen the organisational capabilities of SMEs. In this context, FUNDAE has adapted its environmental training programs to better address the challenges faced by SMEs. The courses developed based on a needs assessment at sectoral level are accessible to all businesses via the FUNDAE platform since 2025, with a selected number of companies that will additionally benefit from consulting services to implement emission reduction plans. Raising awareness about the availability of these training programmes is essential to maximise their impact. Additionally, the scope of consulting services could be expanded based on their demonstrated success, enabling more SMEs to access tailored support.
Stakeholders have also expressed concerns about delays between policy design and policy implementation, highlighting the need for more agile mechanisms. A notable example is the development of green credit lines, designed to offer SMEs access to financing at preferential rates to support sustainability projects. While these instruments provide an important incentive for greening SME operations, their conditions need to be continuously assessed to better reflect the ongoing economic context. In fact, Spain’s retail bank rates are currently only marginally higher than the 6.43% maximum Annual Percentage Rate (APR) offered under the ICO green credit line31. Similarly, average borrowing rates as reported by the Bank of Spain, suggests that overall market rates have declined in recent months. 32 Policymakers should consider rethinking current preferential rates to ensure that they remain meaningful.
Efforts to streamline access to green credit for SMEs while ensuring that financed projects deliver environmental benefits or are at least respectful of the environment may prove to be a difficult balance to strike. ICO’s initiative to reduce administrative burdens for loans under EUR 10 million, which are more likely to be demanded by SMEs, is a noteworthy step, although the simple auto-declaration of compliance with the “Do No Significant Harm” (DNSH) principle may not be fit for purpose, especially compared to the detailed formal accreditation required for larger projects. A simplified accreditation system might strike a better balance between preserving the environment and protecting SMEs from undue regulatory burden.
Furthermore, ICO’s green credit lines are currently specifically mandated and sponsored by the government, whereas Spain’s public development bank could consider mainstreaming green considerations in all its financial operations, in line with the experience of other public financial institutions (OECD, 2025[36]). Bpifrance, for example, has developed a sustainable investment survey to monitor the environmental sustainability of its operations, as well as methodology to assess the financed emissions of its portfolio. In Germany, KfW applies ESG and DEI (diversity, equality and inclusion) indicators to the assessment of the VC funds in which it invests.
Finally, in Spain, as in other countries, there needs to be better coordination among initiatives that help SMEs calculate their carbon footprint, with a view to adopting a unified methodology that ensures consistency and comparability. In the context of Spain, to support SMEs in registering with the official carbon footprint registry, policymakers could also consider enhancing awareness-raising efforts about the benefits of registration (e.g., enhanced branding, improved supply chain integration, access to green financing) and offering targeted support for registration. Although the registration process is relatively straightforward, stakeholders highlight that many SMEs are unaware of how to register, which is why organisations like ECODES provide paid services to assist with the process.
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Notes
Copy link to Notes← 1. Introduced in 2023, ETS2 expands the ETS to cover CO2 emissions from buildings, road transport, and small industries, becoming fully operational by 2027 (European Commission, 2023[37]).
← 2. This project uses sector weights (SME shares of value-added and employment) at two-digit sector level to estimate five environmental indicators related to the SME sector: SME share of GHG emissions, SME share of energy consumption; SME GHG emission intensity (i.e., carbon intensity); SME energy intensity; SME energy price burden (i.e., the impact of the cost of electricity and natural gas on SME turnover).
← 3. This essentially includes NACE sector codes 05 to 82, including manufacturing, construction, mining and all private-sector services, but excluding agriculture, financial services and public administration activities.
← 4. For further information, see: https://planderecuperacion.gob.es/noticias/como-se-estan-transformando-las-pymes-con-el-plan-de-recuperacion-prtr .
← 5. RePowerEU is the plan of the European Commission to wean off EU member states from Russian gas, after the invasion of Ukraine by Russia, and to fight climate change.
← 6. For further information, see: https://www.miteco.gob.es/es/cambio-climatico/temas/registro-huella/inscripcion-registro.html#conocer-los-requisitos .
← 7. Scope 1 emissions correspond to emissions emitted directly by the company's activities through fossil fuels (oil, gas, coal, etc.). Scope 2 covers indirect GHG emissions associated with energy consumption, which occur outside the company's facilities. It includes indirect emissions resulting from the production of energy purchased and consumed by the organisation (electricity and heating/cooling networks). Scope 3 emissions include indirect emissions that are beyond the company's direct control, often encompassing activities up and down the value chain, such as purchased products and services, transport and logistics, waste, etc.
← 8. For further information on the Sustainable SME programme, see: https://www.camara.es/innovacion-y-competitividad/pyme-sostenible .
← 9. For further information on the self-assessemnt tools, see: https://www.camara.es/innovacion-y-competitividad/autodiagnostico-de-sostenibilidad-para-pymes .
← 10. For further information, see: https://empresasostenible.camara.es/programas/pyme-sostenible .
← 11. For further information, see: https://www.fundae.es/convocatorias/plazo-de-solicitud-abierto/microcreditos .
← 12. For further information, see: https://www.eoi.es/es/cursos/92655/curso-de-capacitacion-para-la-transicion-industrial-de-la-pyme-presencia-virtual-online .
← 13. For further information on the available courses, see: https://www.efundae.es/course/index.php?categoryid=258 .
← 14. For further information, see: https://sede.idae.gob.es/tramites-servicios/primera-convocatoria-nuevos-modelos-de-negocio-para-la-transicion-energetica .
← 15. For further information on single projects, see: https://www.idae.es/ayudas-y-financiacion/comunidades-energeticas/programa-de-incentivos-proyectos-piloto-singulares-de .
← 16. For further information, see: https://www.mintur.gob.es/PortalAyudas/PERTE-DI-L4/Paginas/Index.aspx ; https://www.mintur.gob.es/PortalAyudas/PERTE-DI-L4/descripcion/Paginas/Caracteristicas.aspx .
← 17. For further information, see: https://www.mintur.gob.es/en-us/gabineteprensa/notasprensa/2024/paginas/industria-consulta-perte-agroalimentario-ii.aspx .
← 18. For further information, see: https://www.mintur.gob.es/PortalAyudas/PERTE-AGRO2/descripcion/Paginas/Caracteristicas-importe-maximo-ayudas.aspx .
← 19. According to the European Environmental Agency (EEA) eco-design is “the integration of environmental aspects into the product development process, by balancing ecological and economic requirements”. More information here: https://www.eea.europa.eu/help/glossary/eea-glossary/eco-design .
← 20. For further information, see: https://fundacion-biodiversidad.es/convocatorias_del_pr/convocatoria-de-subvenciones-para-el-impulso-de-la-economia-circular-en-la-empresa-para-el-ano-2022/ .
← 21. Measures to increase environmental protection include reducing waste generation before products reach consumers, using recycled or by-product materials, improving material efficiency and recyclability, substituting hazardous substances, adopting eco-design principles (e.g., EU Ecolabel) or promoting durable, repairable products. Investments in waste management by third parties include systems and infrastructure to enhance waste sorting or optimise recycling processes for high-quality materials to be used as new raw inputs (Fundación Biodiversidad, 2024[38]).
← 22. AXIS offers venture capital investments in startups and scale-ups focusing on digital and green projects. These investments are made through regulated VC managers and funds, with AXIS taking a minority stake (up to 49%) in the companies it supports, either directly or through co-investments with other investors.
← 23. It is exclusively focused on activities aligned with the climate objectives defined in Annex 6 of the European Recovery Mechanism, which are evaluated and classified based on their levels of contribution to climate mitigation and adaptation (0%, 40%, or 100%). ICO funds only activities labelled as contributing 40% or 100% to climate mitigation and adaptation objectives with a goal to ensure that financed activities have an average impact of 80%.
← 24. For further information, see: https://www.ico.es/en/ico-mitma-movilidad-sostenible .
← 25. For further information, see: https://www.ico.es/web/ico_en/ico-mitma-rehabilitation-of-residential-buildings .
← 26. For further information on CERSA, see: https://www.cersa-sme.es/sobre-cersa/quienes-somos/ .
← 27. For further information, see the Spain energy efficiency summary on the Odyssee-Mure website: https://www.odyssee-mure.eu/publications/efficiency-trends-policies-profiles/spain.html .
← 28. For further information, see: https://www.mintur.gob.es/PortalAyudas/emisionesCO2/descripcion/Paginas/Descripcion.aspx .
← 29. For this country note, representatives from a state-owned promotional bank, a national training foundation, and a central government coordination unit were interviewed.
← 30. These figures cover all RRP measures, including those which do not concern the green transition.
← 31. For instance, BBVA offers small business loans over three years at 6.98% Annual Percentage Rate of charge (APR).
← 32. For more statistics, see: https://www.bde.es/webbe/es/estadisticas/temas/tipos-interes.html .