El Thermal 3.0 Count has become one of the most discussed mechanisms in the field of incentives for energy efficiency and thermal renewables in Europe, especially for its potential as a benchmark for other countries, including Spain. It is a system of direct aid that reorganizes how energy efficiency improvements are financed in existing buildings, with a special focus on the tertiary sector and public administrations.
Unlike the classics tax deductionsThis scheme is based on a I contribute to a non-refundable fund managed by the state energy operator, the GSE, and paid in one or more installments directly to the beneficiary. With an allocation of 900 million euros per year With a very wide range of eligible interventions, the Conto Termico 3.0 reinforces the line set by European building regulations and the so-called "Case Green" Directive, and fits well with the debates taking place in Spain on how to design simpler and results-oriented aid.
A permanent incentive for existing buildings
The Thermal Control 3.0 is structured as a mechanism without an expiration date that supports projects in Existing buildings equipped with air conditioning systemsThe objective is twofold: on the one hand, to improve the energy efficiency of the building envelope and installationsOn the other hand, to promote the thermal energy production from renewable sources through solutions such as heat pumps, biomass or solar thermal.
The aid is calculated based on the investments actually made and are realized in a percentage of the investment considered eligible costGenerally speaking, the limit is located at 65% of eligible costs, although in the case of certain public buildings (especially in small municipalities and educational or health centers) the contribution can reach 100% of the investment accepted.
Another relevant difference compared to other European systems is that the Thermal Cont 3.0 It is not a tax relief in personal income tax or corporate taxbut rather a direct transfer from the GSE to the beneficiary, which makes it particularly interesting for entities with little or no fiscal capacityas the local administrations or part of the third sector.
This approach, although originating in Italy, offers a clear reference point for countries like Spain, where the advisability of reduce dependence on tax deductions and move towards more predictable direct subsidy schemes with less uncertainty for the end user.
Who can benefit: public administrations, companies, the third sector and energy communities
Reform 3.0 significantly expands the typology of beneficiariesThis is something that is being watched closely in the European Union because it opens the door to... more agents participate in the energy transition of the building park.
First, the Public Administrations They continue to be key players: city councils, regional bodies, ministries, universities, Educational centers, hospitals, and other healthcare infrastructure They can apply for grants for the renovation of schools, institutes, public offices, rehabilitation of residencesday centers, cultural facilities, or community spaces. For these cases, a particularly high level of support has been planned, with the real possibility of finance 100% of the eligible cost in specific cases.
Secondly, the mechanism is fully open to the private businesses, who can now qualify for incentives for efficiency improvements in their buildings for tertiary useOffices, commercial premises, hotels, sports facilities, production facilities, or logistics warehouses. In these cases, aid is usually below 65%, depending on the company category (small, medium, or large) and the type of intervention.
One noteworthy development is the equalization of certain third sector entities -such as non-profit associations or social cooperatives- to public administrations, provided that do not engage in economic activityThis allows them access to conditions similar to those in PA, a crucial aspect for rehabilitation. residences, day centers, cultural facilities or community spaces.
The scheme also includes the Renewable Energy Communities (RECs) or collective self-consumption configurations, who are considered eligible actors for actions linked both to efficiency in existing buildings and to the renewable thermal energy production in shared environments. This approach fits with the European strategy of promoting cooperative and local models in the deployment of renewables.
Types of actions: building efficiency and renewable heat
The regulation groups the eligible actions into three main blocks: energy efficiency in buildings, thermal energy production from renewables and high efficiency systems, and energy diagnosticsEach group has specific requirements and percentages of aid, designed to reward interventions with measurable impact in primary energy consumption.
In the section improved efficiency in the building envelope included insulation of facades and roofs (opaque surfaces) and the replacement of windows and glazing (transparent surfaces) with solutions offering improved thermal performance. Also considered are exterior sun protection elements -technical awnings, louvers, solar filters- when they reduce the thermal load in summer and are installed in specific orientations.
Another set of measures includes the modernization of lighting systems interiors and exterior areas associated with the building, with efficient lighting and building automation to automatically manage lighting, climate control, and other energy services. These technologies allow for monitoring consumption and activating time regulation and monitor energy usage in real time.
Within pure efficiency, a prominent place is reserved for the transformation of existing buildings into nearly zero-energy buildings (NZEB)In these cases, the actions combine extensive improvements to the building envelope, complete renovation of heating and cooling systems and, where appropriate, seismic retrofitting or demolition and reconstruction even with a certain increase in volume, always under strict conditions.
With regards to renewable heat productionThe aid covers the replacement of existing thermal systems with electric or gas heat pumps that use aerothermal, geothermal or hydrothermal energy, biomass-powered equipment for heating buildings or greenhouses and farms, solar thermal installations for hot water or air conditioning and connection to efficient district heating networksActions with micro-cogeneration powered by renewables.
Heat pumps: the core technology of scheme 3.0
Among the entire range of possible equipment, the heat pumps emerge as the key component of Conto Termico 3.0The mechanism explicitly prioritizes the replacement of traditional boilers replaced by full electric systems or by hybrid solutions in which the heat pump assumes a leading role, thus reinforcing the European strategy of electrifying thermal demand.
Subsidies for heat pumps fall under the chapter of renewable thermal energy production, with intensities that can reach 65% of the eligible cost in the case of small businesses and comparable entities, decreasing slightly for medium and large companies. When it comes to Public Buildings specifics, such as educational centers or hospitalsThe financing can cover virtually all accepted investment.
To be eligible for subsidies, these heat pumps must be installed as replacement of existing systemsnot as a first installation in buildings without pre-heating. Furthermore, they are required to comply minimum seasonal efficiency parameters (such as COP or SCOP) aligned with the European regulatory framework on ecodesign and energy labelling.
In the service sector, when projects are processed as business investments, an additional requirement is set: the works must contribute a reduction of primary energy demand of at least 10% for simple interventions, a percentage that rises to 20% when several measures are combined. This improvement must be demonstrated with Energy efficiency certificates before and after the intervention.
The scheme also supports “factory made” or bivalent hybrid systemswhich combine heat pumps and other generators, as well as renewable micro-cogeneration units. In the case of agricultural and forestry holdingsThe installation of biomass-fired equipment for air conditioning in buildings, greenhouses or for production processes is permitted, provided that it is accompanied by heat accounting when certain power thresholds are exceeded.
Photovoltaics and storage: permitted, but only as a complement
One of the new developments that has generated the most headlines is the Photovoltaic input with batteries in Thermal Conto 3.0However, the fit is very specific: This is not a general photovoltaic incentivebut rather limited support, conditional on the solar installation going directly linked to the replacement of the thermal system with electric heat pumps.
In practice, to receive help the photovoltaic system It must have a power that, in general terms, falls between 2 kW and 1 MW, operate in partial self-consumption scheme and be sized in such a way that its annual production does not exceed total energy consumption by more than 5%. (electrical and equivalent thermal) of the building. In addition, all components—modules, inverters, and storage systems—must be New, with CE marking and meet minimum warranty and performance requirements.
The level of support for this photovoltaic component is, as a guideline, around 20% of eligible costs, calculated based on maximum costs per kW or kWh established in official tablesThis grant is only awarded if the project includes the Simultaneous replacement of the winter heating system with electric heat pumps and cannot exceed the amount granted to the associated heat pump itself.
The mechanism also introduces additional bonuses if the photovoltaic modules are registered in a specific registry of high-efficiency technologiesDepending on the category in which the panels are classified, the level of assistance may increase in 5, 10 or 15 percentage points, with a maximum limit of 35% for the solar part, always respecting the global intensity limits set by European State aid regulations.
This treatment of photovoltaics, as a “technology dragged along” by the heat pump, fits with EU guidelines, which insist on prioritize reducing consumption and decarbonizing heat rather than the mere increase in distributed electricity generation.
Eligible costs and maximum aid percentages
One of the strengths of the Conto Termico 3.0 is the detailed definition of which items are considered eligible costsIn the case of work on the building envelope, this includes not only the insulating materials and their installation, but also auxiliary and temporary works necessary for proper execution: scaffolding, partial demolitions, reconstructions consistent with urban planning regulations or the mechanical ventilation installation when it is the appropriate technical solution to problems of humidity and condensation.
For replacement of carpentry and glazing The removal of old elements, the supply and installation of new windows, as well as possible specific improvements of existing components provided they result in a verifiable reduction in thermal transmittance.
In the chapter of equipment and facilitiesThe aid covers everything from the dismantling of the previous system to the purchase and installation of the new thermal generation, hydraulic and electrical works, adaptation of the distribution network, regulation and control systems, hydraulic balancing and, where applicable, the connection to district heating networksAlso included are the actions associated with geothermal exchange with the subsoil when opting for geothermal heat pumps.
The professional benefits Projects, construction management, energy efficiency certificates, and pre- and post-construction energy audits are also included in the calculation of eligible expenses. For small and medium-sized enterprises, the cost of energy performance certificates is explicitly included. before and after the intervention, a relevant aspect for structuring projects in the tertiary sector.
In the case of renewable thermal generation facilities, the eligible items include the partial or total removal of the old systemThe complete installation of all thermal, mechanical, electrical, and electronic equipment linked to the new system, and the connection works to external networks, both electrical and district heating, are included. The preparation of the new installation book, required by the technical regulations.
The specific percentages of aid vary depending on the type of intervention, the size of the company, and the location. For efficiency interventions (Title II), the base intensities are usually around 25-30%, with increases depending on the size of the company, its location in assisted areas and the level of energy improvement achievedup to a maximum of 65% in the case of small and medium-sized enterprises. For thermal renewables (Title III), the base percentages are around 45%, with additional increases for SMEs, always respecting the established limits.
Eligibility conditions, controls and maintenance of requirements
To be eligible for the incentives, applicants must demonstrate the availability of the building or property on which action is taken, either as owners or as holders of usage rights (for example, lease or usufruct). Interventions are only permitted in existing buildings with winter air conditioning systems installed before the entry into force of the decree, so the replacement of equipment and deep renovation is prioritized over new constructions.
The GSE states that subsidized systems must maintain the technical requirements that justified the concession throughout the incentive period and during five additional years to the last installment paid. Failure to comply with this commitment—for example, the removal of the equipment or its substantial modification without notice—is considered grounds for loss of the right to aid and reimbursement of amounts already received.
The controls are carried out both through documentation and, in certain cases, through on-site inspectionsThe GSE or designated entities may verify the correct execution of the works, the power and characteristics of the equipment, the existence of the required energy certificates or the veracity of the data declared in the application.
From a procedural point of view, the mechanism is mainly structured through a specific digital platform -PortalTermico-This is where applications are registered, technical and financial documents are uploaded, and the process is tracked. Digitization aims to reduce response times and standardize evaluation criteria.
Regarding deadlines, for actions processed in direct access The application must be submitted shortly after the completion of the work, and payment is made in a single installment for modest amounts or in two or five annual payments For larger investments, it depends on the installed power and the specific rules of the type of intervention.
Cumulability of aid and transitional regime with the previous scheme
Thermal Control 3.0 explicitly sets the rules for compatibility with other public incentivesIn general, actions can only receive this state aid when They have not been granted any other national subsidies for the same investment, unless it is financial instruments such as guarantee funds, revolving funds, or interest bonuseswhich can coexist since they are not considered aid in the strict sense regarding the cost of the action.
To publicly owned and publicly used buildings A relevant exception is introduced: the combination of the Thermal Contribution with other lines of support and financing is permitted, provided that the sum of all non-refundable contributions does not exceed 100% of eligible costsThis flexibility is especially useful for smaller municipalities, schools, and healthcare resources that need to coordinate funds from different administrative levels.
As regards the collective self-consumption configurations and renewable energy communitiesCompatibility is determined according to the specific regulations governing these schemes. The decree refers to the current rules regarding incentives for shared self-consumption, so the combination of aid must be analyzed on a case-by-case basis to avoid conflicts. double financing.
The approval of version 3.0 also entails a transitional regime to close the previous Conto Termico 2.0. Projects completed before the effective date of the new scheme may continue to be eligible for the antique frame if they submit the application within a limited period from the completion of the works. For those business activities initiated after the publication of the new decree but not completed at the time of the change of rules, a “preliminary request” which is sent to the GSE, initially even via certified email, until the new portal is fully operational.
This bridging phase, with very specific deadlines for send requests or prior communicationsIt underlines the importance of close monitoring by the agents involved - technicians, companies and administrations - in order not to lose the right to aid due to purely formal issues.
The Thermal Count 3.0 configures a robust and highly structured incentive framework which points in the same direction as European energy policy: prioritizing the rehabilitation of existing infrastructure, shifting thermal generation towards renewable and electrical technologies and to strengthen the participation of administrations, companies, the third sector and energy communities in the decarbonization of buildings, an approach that will foreseeably continue to influence how other European countries, including Spain, design their own programs to support efficiency and thermal renewables.
