Dynamic tariffs and grid charges in transition

A duty for every supplier

"The obligation under sentence 1 applies to all electricity suppliers from 1 January 2025." One sentence in section 41a(2) EnWG. It disposed of the threshold in front of it without deleting a word¹.

Sentence 1 is still there, threshold and all: 100,000 final customers on 31 December of a given year. A second threshold of 50,000 final customers, also in paragraph 2, had already been struck out in 2023 by the Act on the Restart of the Digitalisation of the Energy Transition (GNDEW)².

Paperwork comes with the duty: explaining costs, benefits, drawbacks and risks, plus a contract summary. Since 2025 the tariff must also be available without grid use and metering if the customer wants it that way and has contracted grid use or metering directly¹.

Since the end of 2025 the same section has had a counterpart. Suppliers with more than 200,000 final customers must also offer a fixed-price contract, running for at least twelve months with the supplier's share of the price guaranteed for that term. Suppliers that sell only dynamic tariffs are exempt^1,4.

Many suppliers offered them before they had to. The Federal Network Agency counted 52 in 2022, 90 a year later and 412 in 2024⁵. How many households actually signed up, the report doesn't say.

Which leaves the condition in sentence 1. The offer is only mandatory for final customers "who have an intelligent metering system within the meaning of the Metering Point Operation Act"¹. On 30 June 2026 that was 3,172,579 out of 54,135,202 metering locations, or 5.9 percent⁶. For everybody else, the duty is an offer nobody can take up.

There is a lever. Since 1 January 2025, final customers, and energy suppliers acting for their customers, can ask the metering point operator to fit an intelligent metering system (iMSys) early, within four months. With the default metering point operator, a one-off charge of up to €100 gross is presumed reasonable, plus up to €30 a year in optional installation cases⁷. Same start date as the tariff duty, and for a supplier the shortest route to a metering system at the customer's premises.

With one catch. The default metering point operator may defer such orders for a while, as far and as long as that doesn't put its statutory installation duties at risk, and then has to give reasons in writing and a binding schedule. It may refuse, for instance, as long as installation isn't technically possible⁸.

The price comes in quarter hours

At 13:08 on 30 September 2025, EPEX Spot published the day-ahead auction results for 1 October. For the first time they covered 96 quarter hours⁹. Hourly contracts stayed available.

This is the series that counts. The regulator describes such a tariff as tying procurement costs to the EPEX Spot market and calculates its own model prices from day-ahead results⁵. The exchange offers suppliers a dedicated licence for this, valid per country where the customers are¹⁰. Passing exchange prices on means holding a data contract too.

What about hourly prices?

What metering the tariff needs

A price per quarter hour is useless while consumption only exists as a yearly total. Each price needs a quantity.

The Metering Point Operation Act is blunt about it. Once a final customer using up to 100,000 kWh a year has an iMSys, consumption is measured as a series of meter readings¹¹. As standard, the metering point operator sends that series to the supplier daily for the previous day, billing being one of the purposes¹². In the gateway the function is TAF 7 (Chapter 4): meter readings every 15 minutes, transmitted daily.

And TAF 2? Sounds like the tariff function. It's really a multi-rate meter gone digital: the gateway adds up consumption in tariff levels whose time windows are fixed in advance. For the three levels of module 3 that's an option, according to the BDEW application guide (Chapter 5)¹³. The exchange price, though, is only known the day before, and for each quarter hour separately. A window configured weeks ago knows nothing about it.

There's a wrinkle with TAF 7, though. In November 2023 ruling chamber 8 noted that TAF 7 "may not yet be used for billing", in the context of legal metrology rules¹⁴. Chapter 5 shows how metering point operators deal with that for module 3 today.

What billing has to cope with

Do the maths. 96 values a day make 35,040 quarter-hour values per market location per year, plus as many prices. A customer read once a year produces one reading.

The transport is settled. Quarter-hour values go from the metering point operator to the supplier as MSCONS messages, the "load profile for the previous day" in the application handbook's words¹⁵. Since 6 June 2025 these series have been transmitted under determination BK6-24-174¹⁶. Chapter 7 has the details.

What the systems behind it must do is spread across the statute. The supplier may process readings for billing, tariff calculation included, and normally has to delete them within three years after the end of the year of recording¹⁷. Where no true value is available, the metering point operator forms a substitute or provisional one¹¹. Time series are versioned for this¹⁵. A quarter hour can come back with a different value after the bill has gone out.

Pair a dynamic tariff with module 3 under §14a, and two time-variable prices end up on one bill: the exchange price in the energy component and a three-level grid charge. The supplier then has to show grid charges per tariff level separately¹⁴.

The real weak spot lies between installation and the first bill. In September 2026 the Federal Network Agency made clear that "mere installation" of a metering system isn't enough. Only once it reliably records and transmits quarter-hour values is the groundwork for time-variable tariffs laid, the agency said⁶. In July 2025 its ruling chamber 8 had described the same pattern for module 3: implementation appeared to be slow "even when the customer can show an intelligent metering system as the prerequisite"¹⁸.

Grid charges today: the §14a modules

Grid charges have acquired a clock too, at least for controllable consumption devices. On 23 November 2023 the agency's ruling chamber 8 set three modules, covered in depth in Chapter 5¹⁴.

Modules 1 and 2 have applied since 1 January 2024: either a flat €80 gross a year plus a stability bonus, or 40 percent of the energy rate for a separately metered device with no standing charge. Neither needs an iMSys¹⁴.

Module 3 is the time-variable grid charge: three tariff levels, first on the price sheet for 2025, billed since 1 April 2025, only on top of module 1 and only with an iMSys. Market communication release cycles were the chamber's reason for the later billing start¹⁴. Which level applies when, and in which quarters, is fixed in advance on the price sheet¹⁴. Grid operators have to publish it by 15 October for the following year, as expected charges if need be¹⁹. That's the difference from the exchange price.

Then, in 2026, enforcement started. As of 13 October 2026 the Federal Network Agency lists four distribution system operators over shortcomings "in particular in connection with module 3"²⁰. Three fixed levels, known long in advance. And even that stumbles.

The 2027 price sheets fall due one day after this chapter's status date. The transmission system operators published their provisional charges on 1 October 2026: 3.54 cents per kWh on average at extra-high voltage and its transformation level, up from 2.86 cents in 2026. That includes a federal subsidy of €5.525 billion, almost €1 billion less than for 2026. The law behind it, a new section 24d EnWG, hadn't been passed on that day. Without legal certainty by 7 December 2026, the TSOs expect higher final charges²¹.

AgNes: the framework from 2029

"The date of publication is set as 1 January 2027." That's how the operative part of the draft ends, at item 20, in the agency's own English version²².

AgNes stands for Allgemeine Netzentgeltsystematik Strom, the general structure of electricity grid charges. It sits with the agency's Grand Ruling Chamber Energy, file number GBK-25-01-1#3, not with ruling chamber 8 of the modules²³. The draft came out on 6 August 2026, with comments due by 18 September. A decision is planned for 2026, follow-up determinations for 2027²⁴.

There's a reason for the hurry. The Electricity Grid Charges Ordinance (StromNEV) lapses at the end of 31 December 2028, and from 1 January 2029 grid charges are to be set and billed under the new determination²². Around €37 billion a year is at stake, which the agency puts at roughly 30 percent of a household's electricity costs²⁴. No decision had been adopted by 14 October 2026, so what follows comes from the draft.

Households on low voltage using up to 100,000 kWh keep a standing charge plus an energy rate. New is a prosumer surcharge for withdrawal points with generation behind the same grid connection: 70 to 90 percent of the standing charge, plug-in solar exempt. From 1 April 2028 suppliers are to show prosumer status on the bill, and by then grid operators must identify the withdrawal points concerned and report them through market communication²².

For grid operators that means a new attribute in their master data, due in eighteen months.

Today, feeding in carries no grid charge at all²⁵. Under the draft, plants above 30 kW would pay a nationwide feed-in charge per kW; a worked example lands at roughly €5 per kW and year. Plants running before publication, or with a final investment decision by then and connection by 4 August 2029, would pay only once 20 years have passed since commissioning²².

Dynamic grid charges are coming, late and not for households. Storage at grid and transformation levels 1 to 5 would pay them from 2030 at the earliest and 2033 at the latest, generation between 2032 and 2035, each only if the chamber spells out the design two years ahead. For final customers the agency holds off "for the time being"²².

What becomes of the modules

The short answer is item 12.5 of the draft: "The levying and further development of time-of-use network tariffs pursuant to section 14a EnWG ('module 3') remain unaffected"²². So module 3 survives, and under the draft it's the only time-variable grid charge households will see for now.

Module 2 gets a side remark in the reasoning: where module 2 means no standing charge, there's no prosumer surcharge either²². Module 1 isn't expressly mentioned in the draft.

Chamber 8's own determination sets no end date for the modules in its operative part. A 2024 to 2028 time limit was still in the key points paper of the first consultation but didn't make it into the decision. Only the transition rules for older §14a arrangements run until 31 December 2028, night storage heaters excepted¹⁴.

How module 3 will develop is open. Many consultation submissions proposed exactly that instead of dynamic grid charges, some with five to six time windows²². The draft has no concrete proposals on it, the Federation of German Consumer Organisations (vzbv) complains²⁶.

MiSpeL: a year on consent

On 1 October 2026 the Federal Network Agency adopted its determination on the market integration of storage and charging points, MiSpeL for short, file number 618-25-02. It appeared in the agency's official gazette on 7 October²⁷. It sets out how green power and grid power in a storage unit or bidirectional charging point are told apart, so that EEG support and levy privileges land on the right quantities. There are two new routes, the delimitation option with formula sets and the flat-rate option with a single bidirectional meter. The second only applies where the solar systems behind the feed-in point add up to no more than 30 kWp²⁷.

Both work in quarter hours. The determination defines simultaneity explicitly as a 15-minute interval²⁷. No quarter-hour values, no MiSpeL. The AgNes draft builds on this: it treats MiSpeL's bidirectional charging points like co-located storage and exempts grid power fed back from energy rates, as far as metering can separate it²².

Then the sentence that matters, item 9 a): "Until 30 September 2027, the provisions of the determination are only applicable if the claims under items 1 to 4 and the allocation under item 5 are asserted with the consent of the respective grid operator and metering point operator"²⁷.

At the same time item 7 obliges exactly these grid and metering point operators to make the claims possible²⁷. They have to cooperate. Until then, though, only those with their consent can invoke the determination.

Why the transition period? The industry is meant to adapt its market communication processes, which, however, are "not part of the subject matter of this determination"²⁷. The question of suitable time series types, raised among others by the new-energy association bne (Bundesverband Neue Energiewirtschaft), the German Association of Energy and Water Industries (BDEW) and the storage association BVES, is explicitly left open. The agency itself calls the period of just under a year "tight"²⁷.

Counterpoint: prosumer surcharge, processes, pace

The AgNes draft drew around 1,000 submissions, according to the Federal Network Agency. Two points draw most of the criticism, the prosumer surcharge and the feed-in charge²⁹. For households, the first one matters.

The German Solar Association (BSW-Solar) puts it at up to €165 a year and considers it defensible to extend the feed-in charge to new plants of every size instead. The reform must not "slow down" people who invest in solar panels, batteries, electric cars or heat pumps, says its managing director Carsten Körnig. The German Renewable Energy Federation (BEE) wants the surcharge scrapped; its president Ursula Heinen-Esser calls it "neither cost-reflective nor good for the system"²⁹. The vzbv, in its submission of 16 September 2026, asks for the surcharge to be graded by plant size²⁶.

In the draft itself, the agency answers: "Lower, volume-based use of the grid does not mean that costs in the grid are saved as well"²². The lines are built. Their costs remain.

For digitalisation another objection weighs more. The bne misses a roadmap for data requirements and market processes: "New payment obligations must not take effect before prices and billing processes are firmly established." The draft offers "no reliable basis for implementation yet", says Kerstin Andreae, who chairs the BDEW executive board, and even the two years planned wouldn't be enough²⁹. Those two years are exactly what agency president Klaus Müller had named as the goal²⁴.

The argument isn't new. Even for module 3, as the draft itself records, several submissions said eighteen months of implementation time had fallen short²².

With MiSpeL the agency recorded the same split in the decision. bne and BVES wanted it applied at once, if need be before market communication was ready. BDEW and the municipal utilities' association VKU wanted to wait until the processes worked at mass-market scale. The agency went for what it calls a "middle way": the consent reservation²⁷.

Both camps have a point. The agency hasn't settled the dispute, though. It has postponed it by a year and pushed it down into every single grid area.

What grid and metering point operators should check now

Tariffs, module 3, AgNes and MiSpeL all hang on the same quarter-hour values. Four checks:

1. Measure delivery, not installation

   An installed metering system counts in the statistics. For tariffs and module 3, what counts is whether the series of register readings reaches the supplier complete every day. Track the share of metering locations with gap-free previous-day values as a KPI of its own.

2. Bill module 3 end to end

   Four distribution system operators are already on the agency's enforcement list²⁰.

3. Prepare the prosumer flag

   The draft requires identification by 1 April 2028. Check whether your master data shows today which grid connection has a generation plant behind it, tenant electricity and shared building supply included.

4. Don't sit on MiSpeL requests

   Until 30 September 2027 you have a say in whether the determination applies. Decide who in your organisation gives consent, and document how you exchange quantities without a defined format.