AgNes deadline calendar 2027 to 2035: eleven dates from the draft ruling for grid operators, suppliers and plant operators

Eleven dates from the AgNes draft at a glance

The draft sets eleven dates between 1 April 2028 and 1 January 2035, eight of them in 2028. Tenor item 1.2 explains why: network charges are calculated under AgNes from 1 January 2029, so prosumer flags, cost allocation data and feed-in data have to move in the year before the first price sheet. For every date the tenor says who carries it; it sets no legal consequence for any of them.

Several dates fall on a weekend, among them 1 April, 30 September and 1 and 15 October 2028, and the draft has no rule that moves a deadline to the next working day, so a sensible internal deadline is the working day before. Two earlier dates are not among the eleven but frame them: the draft names 1 January 2027 as the date of notification, and by 31 March 2027 operators of generation plants, storage and electrolysers that want grandfathering must prove their final investment decision to the grid operator. What that proof means for storage is covered in our article on the grid fee exemption for battery storage and its grandfathering.

The price system itself, with standing and energy charges, the capacity charge, cost allocation and the trade associations' objections, is explained in our article on the AgNes network tariff reform and the new pricing from 2029.

Status of the proceeding: a draft, not a ruling

Any date in this calendar can still move, because by 27 October 2026 BNetzA had not adopted the ruling. The Grand Ruling Chamber Energy opened the proceeding on 12 May 2025, presented an interim status on 27 May 2026 and published the full draft with an expert report on 6 August 2026. Comments were due by 18 September 2026. On the proceeding page, last updated on 21 September 2026, the agency says it still intends to adopt the ruling within calendar year 2026; it plans to publish the comments it received.

As the date of notification the draft fixes 1 January 2027 (tenor item 20 and recital 526). The ruling takes effect at the start of 2027, but the rules on charge calculation in tenor items 8 to 15 only bite later, on the dates listed here. For some building blocks the draft announces further rulings, the design of the dynamic network charge among them (tenor item 12.1).

Expect changes. On the day of publication the storage association BVES said the draft needed work; its managing director Urban Windelen said the association saw a need for improvement "in the grandfathering for existing storage projects and the planned prosumer surcharge" (our translation). Both points hang on dates in this calendar, 31 March 2027 and 1 April 2028. Our advice is to put the dates into your planning now and check them line by line once the ruling is adopted, rather than wait for the final text: between adoption at the end of 2026 and the first date on 1 April 2028 there are about 15 months, and changes to market communication, master data and billing all fall into that period.

1 April 2028: identify prosumers and show them on the bill

Two obligations start on 1 April 2028, one for the grid operator and one for the supplier. By that day, grid operators identify for the first time the withdrawal points in their grid that have prosumer status and give the relevant supplier that information through market communication (tenor item 17.8). From the same day, electricity suppliers must show prosumer status on the energy bill (tenor item 8.3).

The reason is the prosumer surcharge. From 1 January 2029, prosumer withdrawal points at low voltage with up to 100,000 kWh a year pay a surcharge of at least 70 and at most 90 percent of the standing charge (tenor item 8.2 sentence 3). A prosumer in the draft's sense is a low-voltage withdrawal point that draws power both from the grid and from a generation plant behind the same grid connection; plug-in solar devices don't count as generation plants. That definition sits in tenor item 2 no. 11. Tenor items 8.3 and 17.8 point to "item 2 no. 9", which in the draft is the grid node; we read that as a drafting error that the final ruling is likely to fix.

For the grid operator this is master data work with an open process. It has to establish for each withdrawal point whether a generation plant sits behind its connection, and also tell the supplier whether one or more such plants reduce the grid offtake (tenor item 17.8 sentence 2). Plant capacity is recorded in the market master data register (Marktstammdatenregister), which the draft itself refers to for the feed-in charge (tenor item 9.1); which market communication message carries the flag, and in what format, the draft doesn't say. How much effort the matching takes depends on how cleanly plants and metering points are linked today; how master data errors turn into exceptions in market communication is covered in our article on master data quality in market communication.

Suppliers need the flag in their customer master data, their bill layout and their customer communication, because a prosumer will see a higher network charge share from 2029 and ask why. Since the flag applies from 1 April 2028 but the surcharge only from 1 January 2029, bills will carry the flag without a surcharge for nine months.

30 June 2028: two data reports up the chain

Two reports are due on 30 June 2028 and every year after. Distribution system operators send the transmission system operator responsible for their control area the data for the feed-in charge (tenor item 9.5), and grid operators without downstream distributors send their upstream operator the grid-related final consumption (tenor item 5.8).

Feed-in data to the transmission system operator

On 30 June 2028 the report covers 2026, the year before last: contracted feed-in capacity in kW, installed gross capacity in kW and annual feed-in volume in kWh, as at 31 December, for every generation plant that pays the feed-in charge or falls under the grandfathering in tenor item 17.4. It is aggregated, as totals per grid and transformation level, with the grandfathered plants shown as a "thereof" line. From these totals the transmission system operators calculate the nationwide charge they publish in October. For plants without their own grid connection and without a contracted feed-in capacity, the draft falls back on the maximum feed-in capacity in the connection approval (tenor item 9.3 sentence 4); if you don't hold these values per plant in your systems today, they have to come out of the connection files before 2028.

Final consumption to the upstream operator

AgNes allocates grid costs by grid-related final consumption, based on actual values from the year before last (tenor item 5.7). So that the upstream operator can calculate its allocation key, grid operators without downstream distributors report the data for the reference year by 30 June of the year before, for 2029 by Friday, 30 June 2028. Operators with downstream distributors get two more weeks, until 14 July 2028, because they need their own downstream grids' figures first. If data are missing on the cut-off date, the operator makes the best possible estimate and submits the actual values without delay (tenor item 5.8 sentence 4); the recitals expect late submissions to be taken into account up to the date of the report to BNetzA.

This chain is new and tightly timed. A regional utility with many downstream grids waits two weeks for their numbers and then has to deliver itself. For small operators without downstream distributors, 30 June is the harder date, because they deliver first in the chain and get no two-week extension.

30 September 2028: final consumption to BNetzA

Distribution system operators send BNetzA the grid-related final consumption for the reference year electronically by 30 September of the year before (tenor item 5.9), for the first time on 30 September 2028 for 2029. Operators with physically separate sub-grids also show how their offtake splits across the upstream levels. BNetzA wants the data to check the cost allocation amounts, including those of distributors outside its own jurisdiction (recital 273).

October 2028: network charges and the feed-in charge for 2029

The first AgNes price sheets are drawn up in October 2028. Transmission system operators adjust their network charges for the following year by 1 October, distribution system operators by 15 October (tenor item 14.4 sentence 1). By 15 October the transmission system operators also publish the nationwide capacity-based feed-in charge as a separate item in their price sheet (tenor item 9.2).

For distribution system operators, 15 October isn't new. Under Section 20(1) EnWG they already publish their charges for the following year by 15 October at the latest; how that works under the current system is described in our article on publishing the 2027 network charges by 15 October. What changes is the sequence: the transmission system operators set their charges two weeks earlier, and cost allocation amounts have to reach downstream operators in good time before these dates (tenor item 14.4 sentence 4). The draft gives no date for that.

The feed-in charge applies to operators of generation plants with more than 30 kW installed gross capacity in the market master data register, unless they have grandfathering under tenor item 17.4; prosumers already paying the standing charge surcharge and plug-in solar devices are exempt (tenor item 9.1). The transmission system operators calculate it with a formula: a base component of EUR 0.50 per MWh fed in, plus half of their balancing energy and grid loss costs, divided by the total contracted feed-in capacity, using actual values from the year before last averaged over five years (tenor item 9.3). The draft's worked example for 2022 to 2026 comes to EUR 5.14 per kW and year. It is collected by the connecting grid operator, who passes it on to the transmission system operators (tenor item 9.4), so distribution system operators gain a new billing item towards plant operators.

December 2028: explaining a late adjustment for 1 January

Under the draft, a second adjustment of network charges for 1 January is only allowed if the calculation basis has changed materially after the fact, and the grid operator has to explain it to the regulator at least 10 working days before 1 January (tenor item 14.4 sentences 2 and 3). For 1 January 2029 the date depends on how you count. Without Saturdays and without the Christmas holidays it is Thursday, 14 December 2028; if Saturday counts as a working day (Werktag), it is Monday, 18 December. The draft doesn't define the term, and we would plan for the earlier date.

State regulators may set their own procedure for the explanation, since it is a procedural rule (tenor item 18 and recital 524). For grid operators under state jurisdiction the date can therefore differ. In practice: once you publish a price sheet in October, you have no room left after mid-December, and before that only for a material deviation you can justify.

15 September 2030: final settlement of the surcharge

By 15 September each year, the transmission system operators publish on their joint website the final settlements of the special network use surcharge and, summarised per distribution system operator, the payments and final settlements for the previous year (tenor item 15.6 sentence 1 no. 2). Since the system applies from 2029, 15 September 2030 is the first date, covering 2029; the draft doesn't name that first year explicitly.

Among other things, the surcharge funds the individual network charges under Section 19 StromNEV that continue until the end of 2031 for certain final consumers with an agreement in place on 31 December 2028 (tenor items 15.1 and 17.1 to 17.3); the transmission system operators reimburse these costs to distribution system operators. The publication has to let a knowledgeable third party follow the calculation, payments and volumes without further information (sentence 2). For distribution system operators the date is indirect: they supply the information the transmission system operators need in good time (tenor item 15.5).

2030 to 2035: dynamic network charges for storage and generation

For the dynamic network charge the draft sets windows, not cut-off dates. Grid operators bill it to operators of storage connected at grid and transformation levels 1 to 5 from 1 January 2033 at the latest, but not before 1 January 2030; to generation plants at the same levels from 1 January 2035 at the latest, not before 1 January 2032, with offshore wind excluded (tenor item 12.2 sentences 1 and 2).

Before the first price signals flow, the transmission system operators put a joint platform into operation in good time, through which price signals are published and which other grid operators can join (tenor item 12.2 sentence 4); grid operators also set up a medium for congestion transparency with BNetzA (tenor item 12.4). Levels 1 to 5 run from extra-high voltage to medium voltage; storage at the transformation to low voltage (level 6) or in the low-voltage grid is not covered. For distribution system operators that means large batteries at substations and in the medium-voltage grid, not the neighbourhood battery at the local substation. How much a storage plant gains depends on a design that only the follow-up ruling will bring. For storage operators without grandfathering we consider a business case that assumes the dynamic charge from 2033 and the capacity charge under tenor item 10.1 before it a more honest basis than one built on the earliest possible start in 2030.

What happens if a date is missed

The draft sets no specific sanction for any of the eleven dates. Once adopted, AgNes is a ruling under Section 29(1) EnWG; if a grid operator or supplier does not comply, the regulator can order compliance under Section 65 EnWG and enforce the order with coercive fines under Section 94 EnWG. The knock-on effects in the chain often weigh more: if final consumption data are missing, the upstream operator calculates with estimates, and without the prosumer flag the supplier can't bill the surcharge correctly. This is a general reading of the rules, not a review of any individual case.

Challenges and risks

The biggest risk is planning against a draft. If the ruling chamber moves a date, the groundwork isn't lost, but a project plan built to the day has to be redrawn. The draft itself announces further rulings, and the dynamic network charge depends entirely on one of them.

Data quality comes on top. Prosumer identification needs generation plants cleanly assigned to withdrawal points, and the feed-in report needs the contracted feed-in capacity per plant. In many utilities both are spread across grid connection processes, the market master data register and the billing system. And the second half of 2028 will be tight: cost allocation data, the transmission system operators' price sheet and your own price sheet fall between late June and mid-October, in the first year of a new system.

What grid operators and suppliers should plan now

The work for 2028 starts in 2027, and most of it can be prepared without the final ruling. We suggest an order that counts the installed base first and only rebuilds systems once the ruling is adopted.

The steps to the first AgNes price sheet

1. Dates into the regulatory calendar, with a caveat

   Enter all eleven dates with their tenor item and the note "draft of 6 August 2026", and check them once the ruling is adopted.

2. Rough count of prosumers

   Grid operators match low-voltage metering points against the generation plants in the market master data register, take out plug-in solar devices and see how many withdrawal points will carry the flag from April 2028 and how many cases are unclear.

3. Dry run of the reports in 2027

   Compile feed-in data and grid-related final consumption once with 2025 values, the way 2028 will require it with 2026 values, and settle who in the company supplies the figures and who signs them off.

4. Suppliers: bill and customer master data

   Add a field for prosumer status to the customer master data, adapt the bill layout for showing it from 1 April 2028 and prepare the explanation for customers who see the surcharge in January 2029.

5. Storage and plant operators: two business cases

   Budget the feed-in charge or capacity charge from 2029 unless grandfathering applies, and model the dynamic charge in the window 2030 to 2033 (storage) or 2032 to 2035 (generation).

Besides the eleven dates, the draft contains another annual duty that the calendar does not list yet: by 1 January, grid operators send the regulator the data for reviewing network charges together with a report on how they were calculated (tenor item 16). How renewable grid cost pass-through is reported today is covered in our article on renewables grid cost pass-through and the notification to the transmission system operator.

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