EEG and EnFG settlement 2027: ten deadlines from the switch notice to the funding requirement

Ten deadlines from November 2026 to September 2027

Settling one EEG year takes ten months and involves four roles. Plant operators and their direct marketers deliver in winter, suppliers and other grid users in March; the distribution system operator sends its final settlement to the transmission system operator in May, and at the end of August both settle the year for good. First comes a date that strictly belongs to the next year: anyone switching the sales form on 1 January has to say so by the end of November.

All ten deadlines are current law; none comes from a draft. Three of them fall on a weekend in 2027: 31 January, 28 February and 31 July. Anyone delivering through a portal or market communication should plan for the Friday before rather than rely on the date moving to Monday.

Change of sales form by 30 November

For a switch on 1 January 2027, the notification period ends on Monday, 30 November 2026. Section 21c(1) EEG requires notice to the grid operator "before the start of the preceding calendar month" (our translation), and that applies to every first of the month: anyone moving into direct marketing on 1 February notifies by 31 December. It covers the first assignment to a sales form and every switch between forms, for example from the feed-in tariff to the market premium, or from supported to other direct marketing.

A notice names the new sales form, for direct marketing the balancing group the electricity is assigned to, and for a percentage split the percentages (Section 21c(2)). For a switch into or out of the fallback tariff, the fifth-last working day of the preceding month is enough. Installations below 200 kilowatts with no other assignment are deemed assigned to the feed-in tariff in its unpaid-offtake variant; installations at the end of their support period default to the variant for post-support installations. Where the Federal Network Agency has set a procedure and format, grid operators, direct marketers and plant operators must use it (Section 21c(3) with Section 85(2) no. 3).

A forgotten notice gets expensive through Section 52 EEG. Anyone who fails to notify an assignment or switch under Section 21c pays the grid operator €10 per kilowatt of installed capacity and calendar month, plus the following month (Section 52(1) no. 9, (2), (4) no. 2); for a 3-megawatt installation that is €30,000 a month. Grid operators may offset the payment against the support claim and the instalments (Section 52(6)), and the plant operator loses its claim to the payment for decentralised feed-in for the whole calendar year (Section 52(7)). Measured by what one missed notice costs, we see 30 November as the most expensive deadline in the calendar, so a direct marketer taking on many installations at the turn of the year should not hold the notices until the last day.

If the EEG 2027 enters into force on 1 January as planned, the monthly rule stays. The bill replaces the feed-in tariff as a sales form with "grid operator offtake", drops the special deadline for the fallback tariff and lowers the threshold for automatic assignment to 100 kilowatts. How assignment works technically for remotely controlled installations is covered in the article on direct marketing with remote control via the smart meter gateway.

Zero-value periods for 2026 by 31 January

By Sunday, 31 January 2027, the transmission system operators publish on their joint website how many quarter-hours and hours in 2026 saw the applicable value fall to zero because of negative prices (Section 51a(4) EEG). They receive the figures from the power exchanges by 15 January (subsection 3). There are three series, since older versions of Section 51 apply to older installations: quarter-hours under today's rule, hours under the version of 24 February 2025 and hours under the version of 31 December 2022.

For 2025 the TSOs published 199 quarter-hours, 557 hours under the 2025 version and 518 hours under the 2022 version. In the middle series the figure rose from 260 hours in 2023 to 425 in 2024 and 557 in 2025. For installations whose applicable value drops to zero at negative prices, Section 51a(1) extends the support period by the number of those quarter-hours, rounded up to full calendar days. Solar installations count only half under subsection 2; the result is converted into full-load quarter-hours, and the law sets for each month how many of them it uses up, from 73 in December to 508 in June. How the rule works for new PV installations is explained in the article on the Solar Peak Act.

For plant operators the publication creates no duty, but it does create a data need: the figures are needed to recalculate the end of support and to plan the extended period in financing and marketing. There is a second link to the final settlement. Anyone who sold electricity under the fallback tariff in a month with negative prices must report, along with the Section 71 data, the volume fed in during the negative-price period; otherwise the claim for that month drops by 5 percent per affected calendar day (Section 51(3) EEG).

Settlement data and biomass proof by 28 February

By Sunday, 28 February 2027, plant operators provide the grid operator, per installation, with all data it needs for the 2026 final settlement (Section 71(1) no. 1 EEG). That expressly includes data for commercial offtake. Numbers 2 and 3 also require information on electricity tax exemptions, regional guarantees of origin and, for biomass plants, the type and quantity of feedstock; in the current text, the 28 February date only appears in number 1.

Money depends on this date. The plant operator's payment claim only falls due "once and insofar as" the data obligations under Section 71(1) have been met (Section 26(2) EEG, our translation); for the monthly instalments this applies from March of the year after commissioning. Late data mean the operator pre-finances its own claim. For installations in direct marketing, the direct marketer often supplies the data in practice, but the duty stays with the plant operator.

Operators of biomass plants have to submit their proof for 2026 on the same day. Anyone using liquid biomass for start-up, ignition and support firing proves the share of electricity from it with a copy of the feedstock logbook (Section 44c(2) EEG, for installations under Sections 42 to 44). Where the claim depends on the conditions in Section 44b(2) or Section 44c(4) or (5), such as high-efficiency cogeneration, a report by an accredited environmental verifier is required (Section 44c(6)). For series-produced CHP units up to 2 megawatts, manufacturer documents on output and power-to-heat ratio are enough (subsection 7). Both proofs apply from the first calendar year after the claim was first made, and personal data in the logbook that the proof does not need are blacked out by the operator (subsection 9).

A missing biomass proof hurts more than late settlement data: the claim for biomass electricity falls to the market value for the whole calendar year (Section 44c(8)). All biomass plants share the same cut-off date, so the reports fall into the same weeks, and in 2027 that date is a Sunday. Commissioning the verifier only in February puts a whole year of support above the market value at stake.

Reduced levies by 31 March, storage and charging points by 31 May

Anyone who claimed reduced levies on grid withdrawals in 2026 tells the grid operator that collects the levies four things by Wednesday, 31 March 2027: the withdrawal points with reduced levies, the final consumers who benefit, the reason for the reduction and the volumes withdrawn, broken down by those three features (Section 52(2) EnFG). This duty lies with the grid user. For supply under the supplier framework contract that is usually the supplier, who then has to collect the information from its customers. Where the transmission system operator collects the levies (Section 12(2) or (3)), the privileged company reports itself and the deadline moves to 31 May (Section 52(2a)).

If the report is missing or late, the reduced levy claim rises to 100 percent (Section 53(1) no. 3 EnFG), and the receiving grid operator charges the full levy. What the levies cost in 2027 is covered in the article on the 2027 levies published on 25 October.

Storage and charging points have a rule of their own. Electricity withdrawn for intermediate storage and later fed back is exempt from the levies, and so are storage losses; charging points for electric vehicles count as storage to the extent that electricity flows from the vehicle back into the grid (Section 21(1) to (3) EnFG). Only if the grid user has met its reporting duties and the volumes are metered or separated per 15-minute interval in line with metrology law does the reduction apply (Section 21(4)). How the Federal Network Agency handles that separation is set out in the article on MiSpeL and bidirectional charging.

The notification under Section 52(1), whether and why levies drop at a withdrawal point, is required by law "without undue delay". For storage and charging points, Section 21(7) EnFG sets 31 May of the following year as the latest date, so Monday, 31 May 2027 for 2026. Missing it adds 20 percentage points to the levy for that year (Section 53(2)). The annual volume report under Section 52(2) by 31 March is unaffected, which leaves a storage operator that is itself the grid user with two dates.

Final settlement to the TSO by 31 May

By Monday, 31 May 2027, distribution system operators send their upstream transmission system operator the 2026 final settlements for all payments under the EEG and the KWKG, per installation and in aggregate (Section 50 no. 2(a) EnFG). For each installation that means the register number, the relevant volumes, certain avoided grid charges and, for KWKG payments, the full-load hours reached since continuous operation began. On top comes the aggregated levy settlement with total grid withdrawals and the categories for which a reduction or cap applied (point b).

An auditor must audit the aggregated final settlement, and each audit comes with a separate audit opinion (Section 55(1) and (2) EnFG). If the settlement changes afterwards, the same auditor re-audits and adds to the opinion. So an audited settlement has to be in place by 31 May, and the auditor can only start once the plant operators' February data are complete. If data are missing or late, the transmission system operator may estimate them, traceably and with safety margins in favour of the levy accounts; the duty to report remains (Section 61 EnFG).

We see the effort less in the number of installations than in the special cases that pile up during the year: a change of sales form mid-year, an installation registered late, a missing biomass proof that pushes the payment down to market value. Each of these has to be right in the per-installation settlement before the auditor signs.

Transparency data by 31 July

Plant operators that received more than €100,000 in total payments under Section 19(1) or Section 50 EEG for their installations in 2026 check by Saturday, 31 July 2027, whether their data in the market master data register are published and complete. If not, they send the data to the transmission system operator, together with their address and register number (Section 71(4) EEG). By 31 December the TSOs enter name, register number (or, failing that, the VAT identification number), total payments, company size, NUTS-2 region and economic sector into the European Commission's transparency database (Section 71(2)).

For most plant operators the register does the work, because the TSOs take the information from the final settlements and the published register data (Section 71(3)). Only those whose data are missing there, or are not published under Section 15 of the Market Master Data Register Ordinance, have to report. Where the TSOs provide form templates, the report must use them (subsection 6), and evidence must be provided on request (subsection 7). Municipal utilities with their own wind or solar parks should not check the threshold per installation: it applies to the sum of payments to one operator.

Year-end settlement and CHP forecast by 31 August

As of Tuesday, 31 August 2027, distribution and transmission system operators settle the year 2026 (Section 19(1) no. 2 EnFG), and by Wednesday, 15 September, they balance the resulting payments (subsection 2). Also by 15 September they balance the difference between the EEG volumes the DSO passed on to the TSO during the year and the volumes in the 31 May final settlement, separately per energy source and valued at its annual market value (subsection 3).

Together with the year-end settlement, the DSO delivers the forecast for the following year 2028: the expected CHP volumes, split into installations under Sections 6, 9 and 35 KWKG and tendered installations under Sections 8a and 8b with their award levels, the bonuses expected under Sections 7a to 7c KWKG, total grid withdrawals and the withdrawals subject to levies that it collects (Section 50 no. 3 EnFG). TSOs need these figures for the 2028 levies and instalments, which they publish in October.

Funding requirement for 2028 by 30 September

By Thursday, 30 September 2027, the transmission system operators determine the EEG and KWKG funding requirements for 2028 and report them (Section 4 EnFG): to the Federal Ministry for Economic Affairs and Energy the EEG requirement and the expected equalisation claim from the EEG account for the current year (Section 6 EnFG), to the Federal Office for Economic Affairs and Export Control (BAFA) the KWKG requirement, and to the Federal Network Agency both requirements and the offshore connection costs. In addition, the agriculture ministry receives the total follow-up support paid for small manure plants in the previous year. Publication follows by 25 October (Section 51(1) EnFG).

According to the TSOs' publication of 26 October 2026, the EEG funding requirement for 2027 is €17.524 billion; for 2026 it was €16.152 billion, excluding the account balance. Since 2023 the federal budget pays this amount rather than a surcharge on the electricity price. For the current year 2026 the same publication expects an equalisation claim under Section 6(1) sentence 2 EnFG of €2.000 billion; that is the federal government's claim against the TSOs, which arises when the EEG account ends the year in surplus.

What the EEG 2027 bill changes in these deadlines

The federal government introduced the EEG 2027 bill to the Bundestag on 7 September 2026 as printed paper 21/7867; it is meant to enter into force on 1 January 2027. As of mid-October, the second and third readings were planned for the sitting weeks of 9 to 20 November (topagrar, 14 Oct 2026). It leaves the EnFG dates alone and changes three things in the EEG deadlines.

Section 71(1) will name 28 February in its opening words, so the date will apply to all information under subsection 1, including electricity tax exemptions and biomass feedstock; regional guarantees of origin disappear. According to the explanatory memorandum, the reason is that the TSOs have to pass the information to the Federal Network Agency by 15 September. Section 44c(8) no longer cuts the claim to the market value when biomass proof is missing, but to zero; the memorandum speaks of a "stronger incentive" and refers to new biomass plants. In Section 21c the monthly rule stays, the special deadline for the fallback tariff goes, automatic assignment only applies below 100 kilowatts, and installations below 25 kilowatts state on first assignment to other direct marketing whether they claim the new bonus under Section 50c. What the bill means for small installations is explained in the article on the EEG 2027 and small PV systems.

The disputed point is how often installations under the new contracts for difference may still change their sales form. Exiting state support is allowed only once in the first ten years (Section 21e EEG 2027). The Bundesrat criticised this in its opinion, the federal government rejected the criticism; both texts are in printed paper 21/8298 of 30 September 2026 (quotes in our translation).

For the calendar this means the monthly rule in Section 21c stays in the bill, but an installation under a contract for difference could leave the hedge under Section 21e only once; according to the counter-statement it can still switch to other direct marketing as long as the clawback continues. Whether that holds is up to the Bundestag.

What happens if a deadline is missed

For the duties of plant operators and grid users, the EEG and EnFG provide no fine but financial consequences. Without the 28 February data the payment claim does not fall due (Section 26(2) EEG), missing biomass proof cuts it to the market value (Section 44c(8)), and a missing switch notice costs €10 per kilowatt and month (Section 52 EEG). Reduced levies rise to 100 percent without the 31 March report (Section 53(1) no. 3 EnFG), and for storage and charging points by 20 percentage points without the notice by 31 May (Section 53(2) with Section 21(7)).

Grid operators are subject to oversight. The Federal Network Agency monitors whether distribution and transmission system operators run the equalisation mechanism properly and determine the funding requirements correctly (Section 62(1) EnFG), and can issue orders under Section 65 EnWG for that purpose (Section 62(3)). Failing to comply with an enforceable order is an administrative offence with a fine of up to €200,000 (Section 63 EnFG). A receiving grid operator may estimate missing data without the reporting duty lapsing (Section 61 EnFG). For the publications under Section 51a and the transparency data under Section 71(4) EEG, the law sets no specific sanction; the Federal Network Agency can order remedies under Section 85(3) EEG with Section 65 EnWG. This is a general outline of the statutory consequences, not an assessment of your individual case.

What to do by late November and in spring

The next deadline is five weeks away and mainly concerns direct marketers and utilities' generation units. For distribution system operators, the real work starts in January when they request the data for the final settlement. All deadlines with roles and systems are also in the energy transition deadline calendar.

Next steps by role

1. Notify switches for 1 January

   Plant operators and direct marketers: send every assignment and switch as of 1 Jan 2027, with balancing group, to the grid operator by Monday, 30 November 2026; distribution system operators check receipt and reassign the installations on the first of the month.

2. Commission the environmental verifier now

   Biomass plant operators: plan the report and feedstock logbook for 2026 so that both reach the grid operator before Friday, 26 February 2027.

3. Send the data request in January

   Distribution system operators: write to plant operators and direct marketers with a 28 February deadline, track the year's special cases (switches, fallback tariff, negative prices, register gaps) separately and book the auditor for April and May.

4. Collect the levy reports

   Suppliers: ask customers with reduced levies by early March and file the Section 52(2) report by 31 March; storage and charging point operators agree with the supplier who makes the Section 52(1) notification by 31 May.

5. Check the €100,000 threshold

   Plant operators with several installations: add up the 2026 EEG payments and check the register data before 31 July.

Further reading

Frequently asked questions