Iberdrola S.A.

Iberdrola welcomes the review of the Public Procurement Directives, which offers an opportunity to update the framework to both fulfil its original objectives and align it with the EUs current priorities (e.g., industrial competitiveness). Some of Iberdrolas operating subsidiaries in Spain are DSOs subject to Directive 2014/25/EU.

Iberdrola Response to EC proposal on Industrial Accelerator Act 18/June/2026 1. We welcome the proposal on accelerated permitting and industrial acceleration areas. However, A. It is essential to uphold the principles of better regulation, with particular emphasis on ensuring the coherence and consistency of the new framework with existing sectoral legislation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1.Strategic opportunity to scale clean technologies The IDAA can serve as a catalyst for the deployment of clean technologies, contribute to the decarbonisation of EU industrys competitiveness and meet the EUs climate neutrality objectives 2.Central role of renewable-based electrification Flexible direct electrification powered by renewable sources must be prioritised as the most efficient, effective and scalable…

IBERDROLA welcomes the revision of the Renewable Energy Directive (RED) IBERDROLA supports the following aspects of the proposal: • Increase of the RES target to 40%, in line with the highest ambition for 2030. • Introduction of an explicit supportive framework for renewable electricity Power Purchase Agreements, especially for dealing with credit risk.

Incept Impact Assessment: Revision of Directive 2018/2001 on the promotion of the use of Energy from renewable sources Renewables are the essential driver of decarbonisation. We have come a long way, with significant efforts to incorporate these energies in different sectors to achieve the EU’s 2020 objective of 20%.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable (RES) alternatives to enable decarbonisation and the achievement of EU climate objectives IBERDROLA welcomes the revision of the EPBD IBERDROLA fully supports the following aspects of the proposal: •…

IBERDROLA calls for and ambitious revision of the EPBD based on electrification Energy efficiency (EE) and direct electrification go hand in hand and offer the best possible benefits to achieve cost-effective decarbonisation. Any measure that boost electrification will automatically boost EE as well.

Iberdrola welcomes the proposed restructuring and rationalization of European funds in the context of MFF 2028-34 to support investment in climate neutrality as a path to competitiveness and industry renaissance. Iberdrola appreciates the allocation of a specific window for Clean Transition and Industrial Decarbonisation, as one of the four priorities of the new MFF.

• Iberdrola welcomes the Climate law proposed by the European Commission (EC) since it sets, in general, robust goals and guidelines to align EU and member state climate policies with both 2050 climate neutrality goal and Paris Agreement.

•Iberdrola welcomes the launching of the legislative process to pass a Climate Law that incorporates climate neutrality at the core of the EU policy developments that will take place within the implementation of the “European Green Deal”. •The achievement of the EU net-zero emissions target by 2050 is not only possible, but highly desirable both economically and environmentally.

Iberdrola welcomes the ECs initiative to review the ETS as a key pillar of the European climate end energy targets and the Clean Industrial Deal. The ETS Directive has been very efficient in achieving its objectives in a cost-effective manner. Similarly, the MSR Decision has been very effective in addressing the structural surplus of allowances and improving the systems resilience to major shocks.

IBERDROLA welcomes the Proposal for a Regulation on a Union certification for carbon removals as a unique opportunity to set a proper regulatory framework for an EU-wide robust system to complement mitigation efforts and reach the net-zero ambitions.

IBERDROLA welcomes the “Certification of carbon removals” initiative, as it will be key to set a proper regulatory framework to enable sustainable carbon removals that can be appropriately monitored, reported and verified to make an efficient contribution to achieving EU carbon neutrality objective in 2050 and negative emissions thereafter.

Iberdrola welcomes the European Commissions initiative to accelerate the uptake of zero-emission vehicles (ZEVs) in corporate fleets. This regulation is a strategic opportunity to decarbonise road transport, strengthen the second-hand EV market, and enhance the competitiveness of the European automotive industry.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola welcomes the EU initiative to assess the proposal of a Carbon Border Adjustment Mechanism (CBA) to enhance EU climate targets, reduce the risk of carbon leakage and avoid distortions on international trade ensuring that the price of imports reflect accurately their carbon content, preserving World Trade Organization-WTO rules and other international obligations of the EU.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

The 2030 energy efficiency (EE) objective was set at 32.5% based on a GHG emissions reduction target of 80-95% by 2050. Consequently, in order to reach carbon neutrality by 2050, the 2030 EE objective should be increased accordingly. Iberdrola strongly supports the proposal to increase this value to 36%.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Decarbonisation price signals and a level playing field for all the available energy supply options are essential to tackle emissions and increase efficiency, both for consumers and emitters. The price of products must internalise their total environmental cost so those with a lower carbon footprint become more competitive.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola shares with the Commission the views that energy taxation should be a tool for climate policy and preserving the internal EU market requires harmonised energy tax framework across the MSs as one of the keystones of the Green Deal to achieve climate neutrality in the EU by 2050. Decarbonisation is a must for the whole society involving all economic sectors.

Iberdrola welcomes the forthcoming revision of the Renewable Energy Directive (RED) for the 20312040 period. This revision takes place in a context marked by heightened geopolitical instability and renewed exposure of the EUs structural dependence on fossil fuels.

Iberdrola welcomes the ECs initiative to review the European Climate Law and its ambition to reduce emissions by 90%, which sets the EU on a clear trajectory to achieving net-zero emissions by 2050. However, the proposed target could be improved by distinguishing the contributions from gross emissions reductions, land-based sequestration and permanent removals to ensure full accountability of the target, and by…

Iberdrola welcomes this proposal as a means to enhance transparency and visibility in the implementation of the CBAM. This will support European industry in investing in its transformation, enabling it to reduce dependence on fossil fuels sourced from third countries, which are subject to volatile prices and geopolitical uncertainties that undermine competitiveness.

Iberdrola is glad to provide feedback to this consultation sharing with the Commission and views on the critical importance of setting a forward looking framework on sustainable batteries based on their exponential growth as a driver for climate neutrality (notably in electrification of transport as shown is chart attached).

Iberdrola welcomes the European Commissions Network Package and underlines the key role of strong electricity grids in enabling electrification based on indigenous, non fossil energy sources, boosting competitiveness and resilience.

Iberdrola welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Reinforcing reporting requirements will lead to more consistency and comparability in non-financial reporting, which is crucial for a level playing field.

Iberdrola is an international energy group with a generation portfolio of 60,800 MW, decarbonised over the last 20 years (over 70% of its generation mix is carbon free). It shows a world leading position both in renewable generation assets, with 40,000 MW and in energy innovation, investing 337.5 M in 2021, and 2,000 M in the last decade.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Electrification is the most effective, efficient and sustainable way to decarbonise the transport sector, achieve EU’s long-term climate objectives and reduce air pollution. The electric vehicle (EV) is the real, competitive and mature alternative to decarbonise road transport at least cost, contributing at the same time to ALL the energy and climate objectives: renewable, energy efficient (2-3 times more efficient…

• CROSS-SUBSIDIES BETWEEN DIFFERENT ENERGY CARRIERS. Cross-subsidies means deviating from the cost-reflective tariffs principle, thus distorting competition between different energy vectors, which is the essence of an efficient energy system integration according to Commission's Strategy itself.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

The EU must enable a stable, attractive and forward-looking framework to promote network investment to address the challenges of competitiveness and energy transition, which involve estimated investments of 730 billion in distribution grids and 477 billion in transmission grids before 2040.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Review of the “alternative fuel” definition Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport to achieve carbon neutral economy by 2050.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola welcomes the European Commissions initiative to develop the Electrification Action Plan and the Heating & Cooling Strategy as a key pillar of the CID. We believe this legislative effort presents a unique opportunity to accelerate the decarbonisation of Europe while enhancing its competitiveness, resilience, and technological leadership. We suggest the following evidences for the Commissions assessment.

Iberdrola supports the Industrial Carbon Management strategy, which establishes that (i) CCS must be deployed at large scale to complement other mitigation actions to address hard to abate emissions, in particular industrial process emissions, and to achieve climate neutrality by 2050, and (ii) To reach net-zero economy-wide GHG emissions by 2050, the EU could need carbon removals to balance out around 400 million…

Iberdrola is happy to provide feedback to support the development of a single, clear and enforceable EU Do No Significant Harm (DNSH) guidance applicable across all EU funds. The company stresses that current approaches differ widely across instruments (Taxonomy Regulation, RRF, SCF, Cohesion Policy rules, and environmental directives), creating inconsistencies and administrative burden.

Iberdrola welcomes the European Commissions initiative to develop the Electrification Action Plan and the Heating & Cooling Strategy as a key pillar of the CID. We believe this legislative effort presents a unique opportunity to accelerate the decarbonisation of Europe while enhancing its competitiveness, resilience, and technological leadership. We suggest the following evidences for the Commissions assessment.

IBERDROLA welcomes this proposal, that contributes to creating an energy infrastructure consistent with the Green Deal’s goals. The removal of the oil and gas categories, the mandatory sustainability criterion for eligibility or the increased oversight of the EC on the TYNDP are all very positive.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola welcomes the European Commissions initiative to revise Regulation (EU) 2019/631 and Directive 1999/94/EC. We believe this legislative effort presents a unique opportunity to accelerate the decarbonisation of road transport while enhancing its competitiveness, resilience, and technological leadership. We suggest the following considerations for the Commissions assessment: 1.

Iberdrola welcomes the European Commissions proposal to revise Annex V and Annex VI of the Renewable Energy Directive, recognising the importance of strengthening the EU framework for GHG accounting and ensuring consistency across bioenergy pathways.

Iberdrola welcomes the revision of the Energy Efficiency Directive (EED) for the 20312040 period. To this end, we suggest the following considerations: 1) The ultimate goal of the EED should be the reduction of emissions & fossil energy imports in an efficient manner The revision of the post-2030 framework is marked by the need to: (i) progress towards the decarbonisation goals; and (ii) make the EUs economy more…

IBERDROLA welcomes the revised Renewable Energy Directive (RED) in terms of permitting issues, and the EC initiative to provide practical guidance to Member States (MS) for the identification and designation of Renewables Acceleration Areas (RAA) for wind and solar onshore projects.

This reform must be approached not as a short-term emergency measure but under a long-term perspective that tackles both the lessons from the crisis and the acceleration of the decarbonisation. In this sense, Iberdrola welcomes this proposal as a good basis for a targeted market evolution. 1.Preserve and further develop the marginal short-term markets.

Iberdrola welcomes the ECs initiative to develop an impact assessment on the revision of the EU energy security framework, as a key pillar for a secure and resilient energy supply, providing the bases for a sustainable path towards climate neutrality and enable affordable and competitive energy prices. Among the objectives and the policy options arisen, we will refer to specific elements of 3 items.

Iberdrola welcomes the Commission's initiative to revise the Network Code on Requirements for Generators, recognising the challenge of adapting connection requirements to a system shaped by renewable generation, storage, electric vehicles and new stability needs.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola welcomes the Commissions initiative to revise national targets and flexibilities after 2030. Updating the Effort Sharing Regulation (ESR) is timely to ensure delivery of the EUs 2040 climate target ( 90% net emissions vs. 1990) and maintain a credible path to climate neutrality by 2050.

IBERDROLA welcomes the Fit for 55 Package The Green Deal though the Fit for 55 Package offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

IBERDROLA welcomes the Fit for 55 Package The Green Deal though the Fit for 55 Package offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient and non-polluting alternatives to enable decarbonisation and the achievement of EU climate objectives and solve EUs air pollution problem.

Air pollution is the biggest environmental risk to health in the European Unión According to the World Health Organization (WHO), air pollution is the biggest environmental risk to health in the EU. 96% of EU citizens living in urban areas were exposed to levels of air pollutants considered by the WHO as damaging to health.

Iberdrola welcomes the ECs initiative to establish an EUwide rating scheme for DCs. Iberdrola is involved in the development of DC infrastructure through electricity supply, grid access & integrated energy solutions, including a JV with Echelon Data Centres in Spain.

IBERDROLA calls for and ambitious revision of Regulation on Union Guidelines for the development of the Trans-European Transport Network (TEN-T) In order to promote the development of electric vehicles, we believe that the following are the main points that should be considered as part of the TEN-T Regulation: • Prioritise the infrastructure for zero tailpipe emission alternatives, taking into consideration that…

IBERDROLA welcomes the Fit for 55 Package The Green Deal though the Fit for 55 Package offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient and non-polluting alternatives to enable decarbonisation and the achievement of EU climate objectives and solve EUs air pollution problem.

• DEPENDENCY ON FOSSIL GAS. To reduce this dependency, fossil gas-based H2 should be excluded from the definition of low-carbon H2 (even when fitted with CCS/CCU). This is especially relevant as this Directive includes measures to promote low-carbon gases, thus risking increasing such dependency. • FOSSIL FUEL COMPARATOR. The renewable and low-carbon gases injected are intended to substitute fossil gas.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Iberdrola welcomes the Commission's initiative to improve the environmental sustainability of iron and steel products and to support the development of markets for low-carbon materials. However, the design of ecodesign requirements should carefully consider their broader implications on industrial competitiveness, electrification and the energy transition.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

We welcome the opportunity to comment on the draft REMIT II Implementing Act and support the aim of strengthening transparency and integrity. However, we would like to highlight that the proposal raises some concerns. Please find our detailed comments in the attached file.

The full internalisation of the environmental costs is required to give consumers a price signal to incentivise the purchase of products with the lower carbon footprint (cheaper) and reduce GHG emissions efficiently. To this end, it is also important that emitters receive correct price signals to reduce emissions and undertake effective measures to reduce emissions.

The EUs FDI screening framework has contributed, over the past couple of years, to identifying and addressing risks to security and public order related to FDIs, while ensuring that the EU remains open to foreign investment. A revised FDI screening framework should maintain this balance. Achieving the EUs ambitious decarbonization targets requires very significant investments.

IBERDROLA welcomes the revision of the Recovery and Resilience Facility (RRF) in terms of the revenues needed to finance the REPower EU Package The REPower EU package represents an ambitious step towards EU energy independence and resilience, while accelerating the energy transition.

Iberdrola welcomes the Commission proposal for Implementing Regulation on interoperability requirements and non-discriminatory and transparent procedures for access to data required for customer switching, as a necessary tool to promote competition and good functioning of the EU electricity supply market.

Iberdrola welcomes the opportunity to contribute to the European Commissions consultation on the draft Implementing Regulation on financial compensation for final consumers of fuels and on allowances surrendered for emissions not covered by Chapter IVa of Directive 2003/87/EC.