On 1 July 2026, the deadline for transposing the Directive (EU) 2024/1785, of 24 April, which amends Directive 2010/75/EU on industrial emissions —the IED 2.0— and Directive 1999/31/EC on landfills, expired. In Spain, the Draft Law for the Prevention and Integrated Control of Pollution Derived from Industrial Emissions and Livestock Farming was subject to public information between 17 December 2025 and 30 January 2026, and will replace the consolidated text approved by Royal Legislative Decree 1/2016 and the Regulation of Royal Decree 815/2013. The MITECO has been working on it from the General Subdirectorate for Pollution Prevention, but the new law has not yet been approved.
It is worth reading the Directive carefully, because what changes is not the procedure: it is the content of the authorisation. The AAI ceases to be a snapshot of what you emit and becomes a dated commitment on how you will stop emitting it. For a plant management, this means that the next review is not prepared with a folder, but with a balance.
Six checks before the next review
1. The environmental management system required by the Directive is not a rebranded ISO 14001
It includes the inventory of hazardous substances present in the process, the risk assessment for human health and the analysis of substitution alternatives. The temporal reference set by the Directive for having it implemented and audited is 1 July 2027, with subsequent periodic audits.
Start with the inventory: it is the part that takes the longest and the one that no one has organised. Substances used, quantities, alternatives available on the market and technical justification for why they are not replaced. Without this, the rest of the system is left limping.
2. Position yourself within the BAT-AEL range, source by source
Being "within the range" of the BREF applicable is no longer a comfortable position: the criterion is oriented towards the strictest end of the range. Calculate, for each source, which percentile you occupy today with your self-monitoring data.
If you are in the upper third of the range, what you have ahead is an engineering project, not a plea. The review of the BREF for steelmaking and for the manufacture of cement, lime and magnesium oxide starts in 2026 — and will set the bar for the upcoming AAI review cycles.
3. The transformation plan is a technical document, not a communication one
For energy, metals, minerals and chemicals, the reference is the 30th of June 2030; for the rest of the activities, the renewal of the permit. A plan that holds up must have behind it a closed balance of energy and materials, dated alternatives, estimated CapEx and the cost per tonne avoided of each measure.
Without this, it is a statement of intent. And a statement of intent does not hold up either before the environmental authority or before a bank at the time of financing the investment.
4. Move from total consumption to specific consumption
Environmental behaviour levels —water, energy, materials, waste— gain weight, and with binding character for resources. The figure that will be requested is not the annual bill: it is the consumption per tonne of product, with series and with the production well referenced.
Who does not have the series, does not have the argument. And series are not built when the requirement arrives: they are built years in advance. Here is where the AAI converges with what we analysed this August about energy balance and submetering: the same measurement rigor applies to both obligations.
5. Check if you have changed regime without changing process
The scope of application has been expanded to activities that were previously excluded:
- Manufacture of batteries and accumulators above 15,000 t/year
- Hydrogen production by electrolysis above 50 t/day
- Extraction of certain minerals and industrial metals
- Intensive livestock farming of lower capacity than before
An investment approved in 2024 can enter the AAI today. And a company that until now was not an IPPC operator can discover itself as such without having changed anything in its process. It is worth reviewing the facilities throughout the portfolio to anticipate which will require authorisation.
6. Treat self-control records as evidence
The review strengthens access to information and environmental justice and introduces for the first time the right to claim compensation for health damages resulting from non-compliance. The logbooks, calibrations, and traceability of the measurement cease to be an administrative archive and become your technical defence.
Check the traceability of the entire measurement chain: who takes the sample, with what equipment, when it is calibrated, which laboratory analyses it, how the uncertainty is documented. A future requirement may ask for all of this in detail.
What lies behind it all
None of these six checks can be resolved with a form. They all require the same: own data, well measured, in a sufficiently long series, and someone with the judgement to interpret and defend them before the administration. This is exactly the work we have been doing for 33 years, without a matrix and without any product to sell: when we tell you that an alternative is not worthwhile, we have nothing to gain.
Regulatory requirements are not an inevitable cost. For those who anticipate and work on it rigorously, it ends up being an advantage: what they will ask of you in four years is what you need to know today about your own plant.
How we do it at AUMA
We support industrial operators in preparing for AAI reviews with a method that combines environmental engineering and regulatory knowledge: position diagnosis regarding BAT-AEL, data quantification and series construction, transformation plans with a schedule and defensible CapEx, and support in communication with the administration.
If you have an AAI review on the horizon, or want to know if the updates from DEI 2.0 affect any of your facilities, write to us. A two-hour working session is usually sufficient to clearly see what needs to be prepared and when.