Section 14a EnWG: publishing control actions on VNBdigital and the end of the exemption for non-controllable devices

Two deadlines from BK6-22-300, both with the DSO

Most people know ruling BK6-22-300 for two dates: grid-oriented control started on 1 January 2024, and preventive control ends when 31 December 2028 runs out. Two dates in between hit a distribution system operator's daily work sooner. Since Saturday, 1 March 2025, it has had to publish, by the 15th of the following month, where and how hard it controlled devices in any month it did so. On Thursday, 31 December 2026, the transitional rule for devices that technically cannot be controlled comes to an end.

In both cases the obligated party is the operator of the electricity distribution network whose low-voltage grid the device is connected to (item 2.2); closed distribution systems under Section 110 EnWG are exempt (item 3.1 a). Controllable consumption devices are non-public charging points, heat pumps including auxiliary and emergency heaters, space cooling and battery storage when charging, each with more than 4.2 kW of connection capacity at grid level 6 or 7 (item 2.4.1). How a control command travels from the network operator via the metering point operator to the device, and why preventive control ends in 2028, is covered in our piece on the control box under Section 14a EnWG.

Since March 2025: every month by the 15th on VNBdigital

The duty only arises in months with control, and only for the network areas where it happened. In that case the network operator shows the network area on a joint web platform in a way that lets every device operator see which network area their device belongs to, and posts a machine-readable list (item 8.4). It gives the type of control, grid-oriented under item 4 or preventive under item 10.5, the number of controllable devices affected, the average power they were instructed to cut and the total duration of the measures, with the postcode of the network area based on the transformer station, in monthly resolution and "by the 15th calendar day of the following month". On top of that it states whether and which measures the operator is taking to reduce control, and when they will be complete.

The platform is VNBdigital, the joint portal of electricity distribution system operators under Section 14e EnWG, run by the BDEW, where network operators also publish their grid expansion plans under Section 14d EnWG. In its reasoning the ruling chamber had named exactly this portal as an example, since operators had to build a joint portal anyway. As for the format, it comes from the BDEW: its recommendation, version 1.0 of 30 January 2025, followed two BNetzA workshops and two consultations, and in notice no. 4 of 5 February 2025 the ruling chamber told all network operators to take the BDEW's format rules and guidance into account.

Intervention time and intensity are coarser than the decimal point suggests. Intervention time counts the hours in which any intervention ran in the network area; whether a given heat pump drew power at all during that time doesn't matter, which is why the BDEW calls the figure a maximum. Intensity is an average over every day of the month, including days without intervention, so three evenings of heavy capping show up as a small percentage. What the platform shows is an overview. Each individual case is documented under item 7.1, with grid state assessments, recipients, intensity and duration of each measure, which the operator keeps for at least two years (item 7.3) and hands to the BNetzA on request (item 7.4).

No map is required. At consultation stage the ruling chamber had proposed a mandatory map and then dropped it to protect critical infrastructure, after objections that it would reveal the grid structure. On VNBdigital, device operators therefore search by postcode or network operator, narrow down the period and download the result as a CSV or XLS file; the BDEW recommendation also provides for a complete file covering all distribution system operators.

Until 31 December 2026: the exemption for non-controllable devices

Item 10.6 is a hardship rule with three conditions that must all be met. The controllable consumption device demonstrably cannot be controlled, its controllability cannot be established at reasonable technical cost either, and it is commissioned by the end of 31 December 2026. Items 3 to 5 then do not apply to it: no participation duty, no grid-oriented control, and no guaranteed grid connection under item 5. This covers devices commissioned from 1 January 2024, which would otherwise fall under the ruling; older ones follow the transitional rules in items 10.1 to 10.3.

In its reasoning the chamber sets a high bar. It wanted to catch individual hardship cases in which a device could otherwise not be connected at all, and it puts the burden of setting out, and if necessary proving, impossibility on the device operator, vis-à-vis the network operator. A device without a digital interface is therefore not automatically uncontrollable. A large share of the heat pumps controlled under the old Section 14a are switched by a contactor in front of the unit, which cuts power during the blocking period on a command from, say, a ripple control receiver. For this kind of control the chamber presumes technical feasibility and considers it usable in principle for every device category covered. Nor does a device that can only be switched off entirely, rather than dimmed in steps, establish impossibility; item 4.6 sentence 2 then requires a cut to the next lower value that is technically possible.

For the device operator, the exemption comes at a price. They don't have to take part, but they also can't rely on any advantage that presupposes participation, item 5 in particular: a network operator may not delay or refuse the connection of a participating device by pointing to a lack of grid capacity, and that bar does not apply to an exempted device. Two things follow for the network operator. For every case it treats as exempt it needs the device operator's case and the date of commissioning, which it has to be notified of in advance anyway under Section 19(2) NAV and item 8.1. And its network planning should know each of these cases, because the device cannot be capped in a bottleneck.

From 1 January 2027: no more impossibility plea

Controllable consumption devices commissioned from Friday, 1 January 2027, can no longer be exempted on the grounds that control is technically impossible. They take part in grid-oriented control, their operator must fit them with the necessary technical equipment including a control unit and keep them controllable at all times (item 4.6), and the network operator must connect them without citing a lack of grid capacity under Section 17(2) or Section 18(1) no. 1 EnWG (item 5). How metering point operators install control units in volume is covered in our piece on the control box rollout in the mass market.

Not everything falls under control from 2027. What remains are the exemptions in item 3.1 b: charging points of institutions with special rights under Section 35(1) and (5a) of the German road traffic regulations (StVO), such as police, fire brigades and ambulance services, and heat pumps and air conditioning that do not heat or cool living, office or common rooms, in particular those used for commercial operations or critical infrastructure. These exemptions depend on the purpose and operator of the device, not on its technology and not on a date. Devices from before 2024 also continue to follow their own transitional rules.

According to the Bundesverband Wärmepumpe, the German heat pump association, 299,000 heating heat pumps were sold in Germany in 2025, about 55 percent more than in 2024. Not every one of them has more than 4.2 kW of connection capacity, and we have found no public figure on how many devices have claimed technical impossibility. What matters to the network operator is something else: from January 2027 the registration process has no route left by which a new device subject to participation gets through without a control unit.

What the EnWG provides if a deadline is missed

BK6-22-300 sets no sanction of its own for either duty. But the ruling was issued under Section 29(1) EnWG, so the general toolkit applies: the regulator can order the measures needed for compliance under Section 65(2) EnWG and enforce the order with coercive fines under Section 94 EnWG. For network operators, breaching the conditions set under Section 29(1) is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG); the authority can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)).

For distribution system operators with fewer than 100,000 connected customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) no. 4 and no. 3(b) EnWG provide for fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). This describes the framework the law provides; whether it applies in a particular case depends on the facts of that case.

Where transparency meets grid security

The publication duty is a compromise, and the reasoning of the ruling of 27 November 2023 shows which positions it sits between. For the exemption, one term stays open.

Part of the heat pump association's demand has made it onto VNBdigital: remedy and half-year are in the list, load data for the network area are not. From 2029 every reported hour of intervention has to come from a grid state assessment, because preventive control ends when 31 December 2028 runs out (item 10.5).

What to do now

The monthly routine has been running for a year and a half and should by now work without manual steps; for the exemption, just over nine weeks remain.

Every month by the 15th

1. Evaluate control actions per network area

   Pull the type, number of devices, duration and intensity per network area from the grid control system and control logs, with network area ID and postcode.

2. Check and upload

   Check the values with the BDEW Excel template, which sits under Support in the internal area of VNBdigital and is open only to the company's registered DSO admins, add the remedy and half-year, and post the list before the 15th.

3. Record months without control

   Without control there is nothing to publish. An internal note for each month shows, if anyone asks, that the missing list is not an omission.

By 31 December 2026

Log every registration in which a device operator claims technical impossibility, with the case made, evidence and commissioning date, and decide on each before the turn of the year; the contactor in front of the unit is the standard case against which every plea is measured. Accepted exemptions belong in the network planning of the relevant network area as non-controllable load.

From January 2027

The exemption route for new devices disappears from the grid connection portal and from the standard texts for device operators; the control unit becomes a condition before commissioning. Item 3.1 b exemptions stay as a separate check, with the purpose of the device as the criterion.

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