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Global Infrastructure Insights: Perspectives from WFW
Spotlight on Spain
 16 March 2026

INTRODUCTION

What constitutes ‘infrastructure’ is undergoing a clear and unmistakable shift. The sector is no longer limited to traditional transport and social assets. Rather, due to technological developments and changing social needs, it has evolved to include developing digital systems and data centres; electric mobility; the energy transition; civil and hydraulic engineering; and fibre optics and storage. These new assets both coexist and interact with traditional physical ones – roads, ports, airports, hospitals etc. – in ways that are essential for efficiency.

Take data centres, which rely on access to the energy grid and need a solid water supply to operate, or the production of renewable gases which call for electric charging and mobility systems and waste treatment plants.

This shift has been particularly evident in Spain in recent years, where there has been a drop in the number of public tenders for new ‘traditional’ infrastructure under classic concession structures (public-private partnerships for public works or service concessions) and an increase in private sector involvement in developing and financing ‘innovative’ infrastructure.

"This is a crucial time for Spain to reinforce its traditional infrastructure, which remains key for both economic competitiveness and the development of these innovative sectors such as data centres and renewable energy.."

In this article, we examine the key developments in the Spanish infrastructure market, focussing on challenges and opportunities within the sector and how sub-sectors may interact with each other.

TRADITIONAL INFRASTRUCTURE

This is a crucial time for Spain to reinforce its traditional infrastructure, which remains key for both economic competitiveness and the development of these innovative sectors such as data centres and renewable energy.

In December 2026, a significant part of Spain’s transport network – particularly its first-generation highways which total nearly 1,000 km – faces the end of its concession terms. This creates an opportunity for the government to redefine their approach to management and promote new investment. This comes, however, with added regulatory complexity and uncertainty for operators and financing players due to:

  • the need to adapt national legislation to Regulation (EU) 2024/1679 of the European Parliament and of the Council of 13 June 2024 on Union guidelines for the development of the trans‑European transport network; and
  • the allocation of responsibilities within the concessional agreement under the current model.

The government has intensified its commitment to improving essential infrastructure, particularly roads and ports. Minister for Ecological Transition Sara Aagesen recently announced a €2bn funding package to promote the energy transition and strengthen the industrial value chain. This includes €200m dedicated to adapt Spanish ports for the deployment of renewable technology such as offshore wind, resizing them to handle large‑scale components.

WATER

The EU and national regulatory frameworks require massive structural investments to comply with directives on water treatment, quality and purification, as well as the commitments set out in the 2022–2027 hydrological plans, which reportedly involve more than €37bn in necessary water infrastructure measures.

Spain faces a historic investment deficit in both its urban water cycle which requires reform and its desalination and reuse capacity which needs increasing, especially in the Mediterranean. As recently noted by Julián Núñez, president of SEOPAN (Spain’s association of construction companies), this deficit requires €100bn of investment over the next decade to address water scarcity and prevent flooding.

Reforming the urban water cycle is supported by an unprecedented digitalisation strategy. The PERTE for the Digitalisation of the Water Cycle, approved in 2022, has already launched three grant calls, proving €50m of direct investment in 2024-2025. These funds support projects using advanced monitoring, AI tools and predictive systems to detect leaks, improve operations and reduce energy consumption in water supply and treatment.

"Spain is moving towards a new regulatory stage for water reuse by implementing EU regulations on water regeneration and upcoming national regulations that will improve the traceability, quality and safety of reclaimed water."

Spain is moving towards a new regulatory stage for water reuse by implementing EU regulations on water regeneration and upcoming national regulations that will improve the traceability, quality and safety of reclaimed water. These are key to increasing the amount of reused water allocated to agriculture, industry and non-potable urban uses, as well as for reducing reliance on traditional sources in drought-affected regions.

An emerging area within water infrastructure is reversible pumping stations. Their relevance goes beyond water management, helping balance the electricity system by storing electricity on a large-scale and supporting the energy transition. These facilities, linked to both dams and former water concessions, are eligible for competitive grants under the PERTE for renewable energy, renewable hydrogen and storage (“PERTE ERHA”), with a cumulative budget of €370m. The latest of these calls, the Second Call for Aid for Innovative Reversible Pumped Storage Projects within the PERTE ERHA, was open for applications until 26 February 2026.

DIGITAL INFRASTRUCTURE

Spain’s electricity and data‑infrastructure sectors have undergone a period of intense regulatory activity, driven by an unprecedented surge in demand from large industrial consumers and data centres. This has prompted both national and regional authorities to introduce new planning instruments, accelerated administrative mechanisms and updated capacity‑allocation frameworks to ensure that the system can effectively accommodate the scale of upcoming projects.

Below are some of the most significant regulatory and policy developments regarding demand access, grid planning and data‑centre deployment across Spain.

Publication of demand capacity maps

The National Commission on Markets and Competition (“CNMC”) has set 20 February 2026 as the mandatory date for the publication of updated demand‑capacity maps by grid-operator Red Eléctrica de España (“REE”).

In short, REE must publish monthly capacity maps indicating the available capacity at each transmission grid node. The maps must also detail instances where it has not been possible to determine a reference value (i.e. the capacity allocated from the transmission grid to distribution) in instances where the node’s available capacity is zero.

The CNMC requires the maps to be updated monthly to reflect evolving technical agreements and regulatory changes.

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"Spain’s new 2025–2030 Transmission Grid Development Plan significantly increases available capacity in the transmission system"

2025–2030 Transmission grid planning

Spain’s new 2025–2030 Transmission Grid Development Plan significantly increases available capacity in the transmission system. It also multiplies grid capacity by fourteen to 27.7 GW to accommodate new demand.

This reflects the strong growth in electricity demand, with 41% of new access requests now originating from consumption points, including large industrial users and data centres, which are allocated 3.8 GW of new capacity. The plan includes €13.59bn in investment to reinforce and extend the grid, supporting new industrial and digital infrastructure.

Regional government initiatives to attract data centers

Spain’s Autonomous Communities have been adopting mechanisms to streamline, incentivise and accelerate the deployment of digital infrastructure and data centres.

Aragón has positioned itself as a leading hub through the PIGA mechanism (Plan de Interés General de Aragón), which reduces administrative times, simplifies procedures and ensures urban‑planning compatibility. This framework has enabled major investments from Microsoft, AWS and other hyperscale operators.

Many other regions, including Castilla-La Mancha, Cataluña, Extremadura and Galicia, are welcoming this type of industry and digital infrastructure, facilitating its implementation through various acceleration mechanisms, which, varying by each region, generally involve granting:

  • urgent processing and a 50% reduction in administrative deadlines;
  • compatibility with urban and territorial planning; and
  • public utility status for expropriation purposes.

"The Sustainable Mobility Law (Law 9/2025), passed at the end of 2025, introduces two important mechanisms affecting demand access and supply for large industrial or digital‑infrastructure projects."

The Sustainable Mobility Law

The Sustainable Mobility Law (Law 9/2025), passed at the end of 2025, introduces two important mechanisms affecting demand access and supply for large industrial or digital‑infrastructure projects:

  • requiring the government to approve a royal decree establishing a specific mechanism to supply firm‑demand projects that cannot be supplied due to non‑expandable substations or which require shared high‑voltage infrastructure by 5 June 2026; and
  • from 15 November 2025 onwards, REE must submit a quarterly report to the Secretary of State for Energy identifying transmission nodes where existing or planned infrastructures could be repurposed or where new ones could be added to supply additional demand. This measure seeks to overcome one of the existing limitations on access to the network for supply demand.

These two measures seek to address the lack of grid availability and supply capacity, which is crucial for the deployment of digital infrastructures.

ENERGY TRANSITION RELATED INFRASTRUCTURE

The infrastructure linked to Spain’s energy transition is at a turning point, as the country begins to implement regulatory frameworks and incentives needed to deploy critical electricity, hydrogen and renewable gas infrastructure.

Electricity networks

The EU has placed the modernisation of electricity networks at the heart of its energy agenda. The European Court of Auditors emphasises that EU initiatives seek to accelerate planning, permitting and financing to adapt to an increasingly renewable and electrified system.

The European Commission has proposed new ‘energy highways’ that directly affect Spain – priority electricity corridors through the Pyrenees to overcome the historic interconnection deficit with France. The latest lists of Projects of Common Interest (“PCI”) and Projects of Mutual Interest (“PMI”) include 113 projects relating to electricity, marine energy and smart electricity grids, including interconnection systems between Portugal and Spain that will be essential for integrating their growing share of renewable energy.

For its part, the Ministry for Ecological Transition and Demographic Challenge is currently planning the 2025-2030 transmission network, which will strengthen existing infrastructure and promote new facilities enabling Spain to advance its transition. Some of its main objectives include ensuring the security of electricity supply to distribution networks and industrial projects, and optimising and expanding the existing network, maximising its use through renovations, capacity increases, the incorporation of new technologies and the reuse of current infrastructure.

Hydrogen

The government has already started transposing Directive (EU) 2024/1788 on common rules for the internal markets in natural gas and renewable gases and hydrogen, which will be key for the renewable hydrogen market in Spain and Europe.

For the first time, PCI and PMI lists include hydrogen infrastructure as a strategic axis of the European energy network. This includes five large-scale electrolysis projects in Spain, as well as the Hydrogen Backbone Network itself, which is being planned by the Spanish hydrogen TSO Enagás Infraestructuras de Hidrógeno, S.L., and the Spain-France hydrogen interconnector ‘BarMar’, all of which support the Portugal-Spain-France-Germany hydrogen corridor.

The European Commission will invest nearly €650m, including over €176m specifically for hydrogen infrastructure, to support a flexible cross-border hydrogen market. This benefits Spain through a reinforced national strategy and upcoming royal decrees which will that mobilise €465m for industrial production and decarbonisation using renewable hydrogen.

"A regulation is expected to be approved for the deployment and implementation of hydrogen stations to help meet the target of a network of 100-150 publicly accessible hydrogen stations by 2030."

Outlined in the Hydrogen Roadmap published by the Ministry in October 2020, a regulation is expected to be approved for the deployment and implementation of hydrogen stations to help meet the target of a network of 100-150 publicly accessible hydrogen stations by 2030.

Natural gas network

Spain has taken the decisive step of integrating renewable gases into the existing natural gas network by approving Circular 2/2025 of 9 April of the National Commission for Markets and Competition, and the Resolution of 13 June 2025. These regulations govern, in a unified but separate manner, the procedures for access and connection of all renewable and low-carbon gases, distinguishing between those that need to be mixed with the gas circulating in the network (such as hydrogen) and those that do not need to be mixed with the gas circulating in the network (such as biomethane).

In addition, the natural gas network TSO, Enagás GTS, has recently confirmed that more than 285 applications for blending have already been received and that the first injections are planned for spring 2026.

In this process of integrating renewable gases into the natural gas network, and as the National Commission for Markets and Competition has already stated in its recent consultation, reverse flow infrastructure and metering or regulation and metering stations will play a crucial role in connection management, which is necessary to ensure that all new injection points – whether for hydrogen, biomethane or other renewable gases – meet strict standards of pressure, quality and flow.

"The Sustainable Mobility Act seeks to redefine the legal framework applicable to e-charging, focussing on more information, fewer permits, more coordination and greater consistency between planning and electrification."

charging station

SUSTAINABLE MOBILITY INFRASTRUCTURE

The Sustainable Mobility Act seeks to redefine the legal framework applicable to e-charging, focussing on more information, fewer permits, more coordination and greater consistency between planning and electrification:

  • transparency: law 9/2025 strengths public information and planning. Before 6 June 2026, distribution companies must submit information to the relevant ministry regarding the characteristics and capacities of the electrical grid in locations designated for charging points. The ministry will then publish a national map of electrical grid capacity that will include the location of power lines and transformer stations, and the areas with the highest power and capacity available for installing electric charging points;
  • fewer permits: the Sustainable Mobility Act eliminates the usual administrative authorisations for electrical infrastructure associated with charging points that do not require environmental assessment or a declaration of public utility – a responsible declaration will suffice – and declares electric vehicle charging infrastructure with a power rating of more than 3,000 kW to be of public utility;
  • gas stations forced to go electric: gas stations that sell 10 million liters or more of fuel per year –and that are part of concessions on state highway networks tendered after 5 December 2025 –must have a charging system of at least 400 kW (600 kW from 2027), including at least one charging point with an available power of at least 150 kW; and
  • State Plan for the deployment of charging areas: this plan will address the need to deploy this infrastructure. The administrative processing of concessions linked to projects to build service areas with ultra-fast electric charging on Spanish roads has begun, which will be advanced and enhanced with the plan’s approval.
Challenges and Opportunities
Challenges
  • investment deficits: Spain faces a significant investment deficit in its traditional and – particularly – water infrastructure, which requires €100bn over the next decade to sufficiently address water scarcity and prevent flooding. The government has taken steps to tackle the problem including its €2bn funding package and various PERTE initiatives support areas associated with the energy transition, including water infrastructure;
  • grid access: limited grid access due to the high saturation of nodes is creating bottlenecks in the development of renewables project, data centres and digital infrastructure. The introduction of the Sustainable Mobility Law attempts to tackle the issue by identifying nodes where existing or planned infrastructure can be repurposed; and
  • regulatory issues: the need to adapt existing national legislation to bring it in line with various EU regulations creates regulatory complexity and uncertainty for operators and financing players.
Opportunities
  • alternative fuel infrastructure: Spain is positioning itself as having the most advanced regulations and industrial capacity in renewable synthetic fuels (including sustainable aviation fuels and e-fuels) and biofuels in Europe. It is currently transposing the EU’s RED II and RED III Directives to promote the decarbonisation of the transport sector and the use of renewable fuels, as well as a series of related ministerial orders. This will facilitate the deployment of the infrastructure necessary for the production, synthesis, refining and supply of these types of fuels; and
  • cross-border initiatives: Spain’s geographic position means numerous cross-border opportunities are available for the energy transition. These include increased grid connections with neighbouring Portugal to help transform the Iberian Peninsula into a green energy hub, as well as the BarMar hydrogen corridor which connected the two countries to France and Germany.

"With a strong concession model, a clear strategy and effective use of its resources, Spain can strengthen its traditional infrastructure and remain an essential asset for long‑term competitiveness and development."

Conclusion

Although Spain’s challenges remain, recent initiatives show that Spain is well-positioned to modernise its existing infrastructure and act as a leader in the development of new, innovative infrastructures. With a strong concession model, a clear strategy and effective use of its resources, Spain can strengthen its traditional infrastructure and remain an essential asset for long‑term competitiveness and development.

We anticipate an increase in the development of new infrastructure in 2026, in line with other European markets. This will primarily focus on investment in and reinforcement of electricity grids, the takeoff of storage systems and further development of data centres. We are confident the Spanish market can overcome current bottlenecks that is limiting its development.

All these developments make it increasingly important to have both sector-specific and multidisciplinary legal advice. Given the close synergies between traditional and ‘new’ infrastructure, a cross-practice, market-focussed legal team with in-depth expertise is key. WFW offers precisely that, having advised on some of the most important transactions in the infrastructure, energy and transport sectors worldwide, and we remain actively involved in providing ongoing advice and leading landmark transactions across all the sub‑sectors covered in this article.

Trainee Fernanda Cifuentes also contributed to this article.

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