The generation rollout quota: why kilowatts count and meter numbers do not

Two ladders in one provision

Track a single rollout figure in the business and you are tracking the wrong one for the generation side.

The better known ladder sits in no. 4, explained in the article on the period quota under section 45 MsbG . Next to it sits no. 2, and it counts differently.

What 31 December 2026 requires

The requirement is 90 percent of the installed capacity commissioned between 25 February 2025 and the end of 30 September 2026. That capacity has to be equipped by the end of 31 December 2026.

Three details hide in that sentence, and all three are awkward. The yardstick is capacity. The window opens on a date in the middle of February. And it closes three months before the deadline.

The ladder then continues. By 31 December 2028 the provision asks for 90 percent of the capacity from the window between 1 October 2026 and 30 September 2028, plus at least 50 percent of the capacity installed between 1 January 2018 and 25 February 2025. The existing fleet follows, just later.

Plants above 100 kilowatts fall under no. 1, where equipping starts in 2028 at the earliest and the first deadline is 31 December 2028. The large ground-mounted arrays built in 2025 and 2026 therefore do not count towards this quota.

Capacity, not case count

Sort the plant list by kilowatts, descending. That is the whole insight, and it cuts across what field scheduling normally does.

A 90 kilowatt commercial roof delivers as much quota as eleven family homes at 8 kilowatts each. It costs one appointment instead of eleven, one journey instead of eleven, one scheduling call instead of eleven. Work through the list by date of receipt and you give that lever away.

The band between 25 and 100 kilowatts carries most of the load: halls, farms, municipal properties, commercial roofs. Section 30(1) MsbG already draws its own installation case group there, with a price cap of 220 euros gross per year. Below it sit 190 euros for 15 to 25 kilowatts and 130 euros for 7 to 15 kilowatts.

None of this means the small plants can wait. It means the order of work is different from what it used to be.

The quarter between window and deadline

From 1 October 2026 the denominator is fixed. It is the only phase in this quota cycle where the target stops moving while you walk towards it.

Until then the reference figure climbs with every commissioning. Each new roof array in September enlarges the base that you have to cover to 90 percent by year end. From October that stops.

Plants from the fourth quarter should of course still be equipped. They simply do not help the 2026 quota. They count towards the next window, which runs to 30 September 2028.

One detail can get expensive: what counts is the commissioning date, not the registration date. A plant that went live in August 2026 and only shows up in the Marktstammdatenregister in November lands in your denominator retroactively. Calculate in October, receive late registrations in December, and the sum was wrong.

More than a meter swap

For renewable plants above 7 kilowatts the appointment does not end with the smart metering system. A control box goes in as well.

What that means at volume is covered in the article on the control box rollout . In short: a second device, a second connection, and a commissioning step the grid operator has to carry too.

Which brings in the grid operator. Section 45(3) MsbG obliges default metering point operators to coordinate regularly with the distribution grid operators in their area and to take their operational requirements into account. That is the soft version.

The hard version sits in the same paragraph. Both sides may conclude binding agreements on implementation, and those agreements may expressly govern the timing and the geographic priority of installation cases. Where a Bundesnetzagentur determination under section 33(1) allows it, they may even set metering charges that depart from section 30, with correspondingly higher overall price caps. Almost nobody uses this instrument, and it sits exactly where quota logic and grid logic pull apart.

What can go wrong

The quota is not purely an installation problem. It rests on data, on hardware and on people, and it carries a sanction.

Both things are true at once. The hard part is not the volume, it is the change of steering: away from case counts, towards capacity.

What happens when the quota breaks is set out in section 45(2) MsbG. The Bundesnetzagentur can then order measures under section 76. How such a procedure runs is described in the article on the regulator's sanctions in the smart meter rollout .

What to do now

Two weeks remain until the measurement window closes, three months until the deadline. The first step is analysis.

Four steps before year end

1. Build the denominator in kilowatts

   Bring together every generation plant above 7 and up to 100 kilowatts commissioned between 25 February 2025 and 30 September 2026, from your own records and from the Marktstammdatenregister. Add up the installed capacity, not the rows. If your system does not carry capacity per plant cleanly, that is the real job of the next two weeks.

2. Sort by capacity and book the appointments accordingly

   Largest plants first. The fourth quarter belongs to the cohort from the measurement window, not to conveniently located new cases from October.

3. Check material for two devices, not one

   Control boxes are the bottleneck, not metering systems.

4. Consider an agreement under section 45(3) MsbG

   Where the distribution grid operator needs a different order for grid reasons than you need for quota reasons, the binding agreement is the instrument the law provides. It can fix priority in time and by location. Left unused it helps nobody.

And build the evidence trail as you go. The position on 31 December has to be documented, not reconstructed in February.

Further reading

Frequently asked questions