Operators’ estimates for the cost of enhanced power resilience at mobile sites dwarf the Government’s own calculations by a factor of five to one
The Spanish Government has proposed network resilience measures following the Iberian Peninsula blackout
On 2 December 2025, the Spanish Government, via the Ministry for Digital Transformation and Civil Service, opened a consultation on a draft Royal Decree on the security and resilience of telecoms networks and services. In a press release introducing its proposed measures, the Ministry cited the April 2025 electricity blackout that took down fixed and mobile networks across the Iberian Peninsula as well as flooding in the Valencia region in 2024 as evidence of the increasing threats to network resilience due to extreme weather. During the recent electricity blackout, the Spanish Government urged consumers to avoid using telecoms services as much as possible, with estimates of the drop in data traffic during the outage ranging between 75-90%. The consultation on the draft decree will remain open until 8 January 2026.
The draft Royal Decree outlines requirements for general preparedness planning, as well as specific incident mitigation plans
Similar to proposals from the Irish Government, the Spanish Government is recommending that operators should be required to conduct an audit of network assets and apply a prioritisation framework for allocating resilience resources. Beyond fixed and mobile network operators, this obligation would extend to firms operating subsea cables, data centres, content delivery networks (CDNs), satellite systems and internet exchange points. Any firm earning over €50m (£44m) in revenue, operating infrastructure that serves more than 500,000 users or involved in providing emergency calling services would be considered an essential facility or service in the event of a critical incident. These firms would be required to submit a general action plan on network security to the Ministry within six months of the adoption of the decree and update that plan every two years. Firms would need to classify their infrastructure on varying levels of priority and detail related mitigation measures aligned with those ratings. At the instruction of the Ministry, firms would also be expected to submit action plans for each type of infrastructure they operate, outlining specific mitigation measures for a variety of possible critical incidents (e.g. volcanic eruption, cyberattack) as determined by the Minister. The plans would include detail on traffic prioritisation in the event of an incident and estimates of the traffic capacity an operator believes it could guarantee under various circumstances. The decree also specifies stricter standards for incident reporting, including a requirement that firms submit to the Government a detailed after-incident report containing information on incident causes and impacts.
The Government estimates that ensuring four hours of continuous mobile service in a blackout to 85% of the population would cost £45-64m
The Ministry has proposed that any facility categorised at the highest level of priority should be able to operate for at least 24 hours in the event of a power outage, and any facility categorised at the second level of priority should be able to operate for 12 hours. A catalogue of these facilities would also need to be shared with electricity transmission and distribution network operators. All other network assets should be operational for at least four hours. Regarding mobile networks specifically, the Ministry proposes that operators should be required to maintain continuity of service for 85% of the population for four hours in the event of a power outage. Operators would have flexibility to determine how to achieve that coverage level and how to ensure power resilience at relevant base stations, such as through battery back-up or generators. According to the impact analysis conducted by the State Secretariat for Telecommunications and Digital Infrastructure, the estimated cost of securing this level of power resilience at mobile sites is between €51m and €73m (£45m and £64m). This analysis assumes that an additional 7,280 sites would require mitigation measures at an average, discounted cost of €7,000 (£6,116) per site. Operators have expressed scepticism at the Government’s analysis, suggesting they would likely need to spend around five to six times as much to achieve the service continuity desired. They’ve further suggested that public defence and national security funds, including through the EC’s proposed Military Schengen programme, should be allocated to help fund the obligation. Although some countries, including Australia and Norway, offer limited, site-specific public funding for power resilience, no government has completely funded compliance with power resilience mandates.
