Editorial transparency and use of artificial intelligence
This article forms part of the CostaLuz Lawyers blog and is published for general informational and educational purposes only. It was prepared with the assistance of artificial intelligence tools and, before publication, was substantively reviewed and editorially approved by Maria de Castro, a Spanish-qualified lawyer registered with the Cádiz Bar Association under number 2745, founder of CostaLuz Lawyers and the person responsible for the editorial review of the published content.
This article does not constitute legal, tax, immigration, employment, estate-planning or investment advice and does not replace an individual assessment and the professional work of the appropriate CostaLuz Lawyers specialist. No action or omission should be based solely on this information.
Key takeaway (read this first)
From 12 August 2025, Spanish mortgage appraisals must include the property’s Energy Performance Certificate (CEE) under Order ECM/599/2025 (which amends Order ECO/805/2003). If the home has no CEE or it’s expired, the valuer cannot issue the report. Translation: don’t sign an arras contract until the CEE is ready, valid, and registered.
Quick context: CEE wasn’t “new”—the timing is
- Since 1 June 2013, a CEE has been required to sell or rent (with narrow exceptions).
- The 2025 change is procedural and earlier in the timeline: the CEE is now a pre-condition for the valuation used in a mortgage.
- Registry & cadastre data used in the valuation must also be ≤ 3 months old.
Why you care: The valuation drives financing, price negotiations, and deadlines. No CEE ⇒ No valuation ⇒ No mortgage (and your deal timetable slips).
What exactly is the CEE?
The Energy Performance Certificate (CEE) rates a dwelling from A (best) to G (worst) and includes technical recommendations to improve efficiency. It tells buyers and lenders about likely energy behavior and running costs—now explicitly factored into the market value assessment.
Appraisers must consider the building’s energy performance and its impact on value as an additional factor (Order ECM/599/2025).
Some analysts suggest that each letter of improvement could mean a non-trivial price impact. Regardless of the exact percentage, energy performance now moves the needle in appraisals.
Practical implications for each party
Sellers (vendors)
- Get the CEE early (valid and registered). Don’t list or negotiate arras without it.
- Expect buyers/lenders to scrutinise the rating; a poor grade can affect value or buyer appetite.
- Keep Nota Simple (Land Registry extract) and Cadastre details fresh (< 3 months) for the valuer.
Buyers
- Ask for the CEE before arras. Make it a condition precedent in your offer/arras draft.
- If you’ll need a mortgage, your bank’s valuer won’t proceed without a CEE.
- Use the CEE to budget upgrades (windows, insulation, HVAC) and negotiate.
Estate agents / brokers
- Build CEE-first into your onboarding.
- Educate clients on timelines to avoid fall-throughs tied to valuation delays.
Before you sign arras: a 7-point checklist
- CEE available, valid, and registered (attach copy to the arras).
- Registration/Cadastre info gathered and dated ≤ 3 months.
- Financing clause aligned with valuation timing (buffer days help).
- Condition precedent: appraisal may not start/complete without CEE.
- Penalty & refund terms if valuation cannot proceed due to missing CEE.
- Energy upgrades (if any) agreed (scope, who pays, timing).
- Delivery of documents (ID, title, plans) scheduled before valuation.
FAQ
Is the CEE only for listings?
No. It’s required for sale/rent, and now it’s mandatory information for the appraisal used in mortgages.
Can I sign arras and get the CEE later?
Risky. If the CEE is missing/expired, the valuer can’t issue the report. Your mortgage timeline and deposit could be at risk.
Does energy rating change the price?
It can. Order ECM/599/2025 pushes valuers to factor efficiency into market value. Expect pricing sensitivity to the rating.
Template clause for your arras (English)
“The Parties agree that the Seller shall deliver a valid and registered Energy Performance Certificate (CEE) prior to the appraisal. Buyer’s obligation to proceed is expressly conditional upon the availability of said CEE and the issuance of the appraisal within the lender’s required timeframe. Failing this, the deposit shall be returned to the Buyer without penalty.”
(We can localise this to Spanish and tailor to your case.)
Bottom line
If you remember one thing: no CEE, no valuation. And no valuation means your financing and pricing can’t lock in. Build the CEE into your pre-arras workflow to keep deals clean and timelines sane.
Need help?
We review arras, verify CEE and title/cadastre compliance, and align your valuation + mortgage timeline so you don’t lose momentum (or your deposit).
Mortgage holder in Spain? Your mortgage may contain abusive clauses (floor clause, IRPH, excessive expenses, early maturity). CostaLuz offers a free mortgage review to check if you are entitled to a refund.
Legal Notice: The content on this page is provided for general informational and educational purposes only. It does not constitute legal advice and should not be relied upon as such. No action should be taken based solely on this content without first seeking independent professional legal counsel. Each case requires individual assessment based on its specific circumstances. CostaLuz Lawyers accepts no liability for actions taken or not taken based on this content.
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