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Chapter 1 · Part I: Framework

The legal framework: from the GDEW to today's MsbG

GDEW 2016, the failed market declaration, the GNDEW and the quotas under section 45 MsbG: how the legal framework of the smart meter rollout came about.

Status: 22 min readDigitalising the Energy Transition
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Summary

No authority gets to decide any more whether Germany's smart meter rollout may begin. That changed on 27 May 2023, and the dates have sat in the statute ever since. Before, everything hinged on one determination by the BSI, the Federal Office for Information Security. In March 2021 the Higher Administrative Court of North Rhine-Westphalia found that very determination manifestly unlawful, in interim proceedings.

What's left is a law of deadlines, the Metering Point Operation Act. Who installs: section 29. At what price: section 30. How much by when: section 45, and most of its quotas count periods rather than the installed base.

And the first of those period quotas? It closes on 31 December 2026.

Dates instead of a determination

"zu den in § 45 genannten Zeitpunkten": at the dates set out in section 45. That short German phrase has stood in section 29(1) of the Metering Point Operation Act, the MsbG, since 27 May 2023. In the same stroke the words "technically possible and under section 31" disappeared1.

Drafting housekeeping, you'd think. In fact it rebuilt the rollout.

Until then, the duty to install intelligent metering systems (iMSys) waited for the BSI. Only when the agency declared, by administrative act, that installation was technically possible did the duty start, and with it a ban on installing metering systems that fell short of the new requirements2. Time frames existed in 2016 too. "From 2017 within eight years", for instance. They just didn't bind anyone before the BSI had made its finding3. Since 2023 the statute's own dates are all it takes.

A whole way of working follows from that. The deadline decides which systems a company needs and which processes it sets up. Also who answers for what. Date first, architecture second: this book calls it deadlines as the sector's operating system. You'll find the ones running now at the end of the chapter, pulled live from the deadline calendar.

2016: a law with a built-in condition

It began with the Act on the Digitalisation of the Energy Transition, the GDEW: signed on 29 August 2016, in force on 2 September 2016. Its first article created the MsbG. The most recent amendment dates from 18 December 20254.

Two steps, then. On paper the default metering point operator had to fit an iMSys for final consumers above 6,000 kilowatt hours a year, for consumers with a §14a agreement and for generation plants above 7 kilowatts. But only "where this is technically possible under section 30 and economically justifiable under section 31". At 95 percent of the affected metering points, the duty counted as met3.

Technically possible meant this: three independent companies offer suitable systems, and the BSI confirms it. The agency's own name for that finding is the market declaration5.

A small edit in the legislative process turned out to matter. The government bill asked for systems meeting the "requirements in protection profiles and technical guidelines". In June 2016 the Bundestag's committee for economic affairs and energy replaced that with a reference to "section 24(1)", the provision on gateway certification6. Just a cross-reference. Five years later a court order turned on it.

The market declaration in court

Three dates for one decision. The BSI took it on 31 January 2020, signed it on 7 February and deemed it notified on 24 February 2020; it is cited as the general ruling "of 7 February 2020"72. The finding: three manufacturers offered suitable gateways. Its scope was narrow, low-voltage final consumers up to 100,000 kilowatt hours, no interval metering, no §14a agreement. Immediate enforcement was ordered, and the mandatory rollout was on.

Pragmatic, from the BSI's point of view. Each of the three gateways had its Common Criteria security certificate. Interoperability was another matter. It rested on the manufacturers' own declarations for the "Basis" device profile2. Enough to start with, the agency thought.

Around 50 metering point operators and private companies disagreed, according to the BSI. They objected and applied for interim relief8. One case went through two instances. The Administrative Court of Cologne describes the applicant as a full-service smart metering provider with its own gateways, a competitive metering business and a gateway administrator certificate. In Cologne it lost, on 21 July 20209. On appeal it won.

The 21st Senate of the Higher Administrative Court of North Rhine-Westphalia ruled on 4 March 2021, case 21 B 1162/20, and restored the suspensive effect of the applicant's action. Manifestly unlawful ("offensichtlich rechtswidrig"), the court called the general ruling, and it gave two grounds, each sufficient on its own2:

  • No three gateways met section 24(1). A manufacturer's declaration, the senate wrote, was "not comparable" to certification by the BSI. Annex VII to the technical guideline, where the "Basis" profile came from, it held unlawful in form and substance, because the Gateway Standardisation Committee that must be heard before such changes had never been set up. The BSI itself had pressed the ministry to set it up back in January 2019.
  • Section 30 gave the agency no power to limit its finding to selected case groups. Leaving out plant operators because generation plants lacked functions? A reason the BSI had "created itself".

Then came paragraph 124. "Should the minimum requirements in fact be impossible to meet, it is, where appropriate, for the legislature to change them."2 No appeal was possible.

It took the BSI a little over a year. On 20 May 2022 it withdrew the ruling, with retroactive effect. The committee existed by then, the guideline had been revised, and by 31 January 2022 the BSI had managed to certify gateways from three manufacturers under the new procedure8. A second ruling issued the same day rested on section 19(6): four gateway types could stay in use and could still be newly installed10. That provision was fairly new itself. The legislature had added it in summer 2021, after the court order, for exactly this case of a determination that later turns out unlawful118. It had been in force since 27 July 202112.

A new market declaration never came. The legislature answered in two steps, roughly as paragraph 124 had suggested. 2021 brought grandfathering and the basis for a staged rollout. 2023 did away with the determination altogether, and since then the agile rollout has let operators start with devices that still lack some functions.

Not firmly established

What the order was not

The court restored the suspensive effect of one single action, case 9 K 3784/20 before the Administrative Court of Cologne2. A nationwide stop on installations? It never ordered one. The legal basis for devices already installed only fell away with the withdrawal in May 2022, and then retroactively, as the BSI itself puts it10. No decision in the main proceedings could be found in public sources.

Who was right? Measured against the statute as it stood, the court. Still, the BSI had found a real problem. In 2020 there simply weren't three devices with certified interoperability.

The lesson of 2021

A rollout that hangs on an agency's determination is only as stable as that determination in court. Since 2023 it hangs on statutory deadlines instead, and there's no general ruling left that a company could attack in interim proceedings.

2023 and 2025: restart, then retune

On 20 April 2023 the Bundestag passed the Act on Restarting the Digitalisation of the Energy Transition, the GNDEW13. Signed on 22 May, promulgated in Federal Law Gazette 2023 Part I No. 133, in force since 27 May 2023141. And 12 May 2023, the date printed on the Bundesrat paper? That's the Bundesrat's deadline. Not the date of entry into force.

Four changes defined the restart. Gone was the market declaration; section 29 has pointed to section 45 ever since. Section 30 took over the price caps and split them between grid operator and connection user, at first 80 and 20 euros a year for 6,000 to 10,000 kilowatt hours. Section 31 brought the agile rollout: devices could go in with functions missing, to follow by update "from 2025 at the latest". Last, section 45 set pure installed-base quotas, 20 percent, then 50, then 951.

How long did that last? Less than two years.

Next came the act of 21 February 2025 on avoiding temporary generation surpluses, in force since 25 February 2025. It rewrote section 45, raised several price caps and gave section 31 an end date, 31 December 202515. That's where the "25 February 2025" in the current statutory text comes from. And the 95 percent by 2030 that still gets quoted? It belongs to the 2023 version.

Politically, though, 2030 is back on the table. On 2 July 2026 the coalition committee resolved to complete the rollout "for all relevant metering points" to more than 90 percent by the end of 2030, and announced a "Smart Meter Light" for customers outside the mandatory rollout16. No bill putting that into law could be found by mid-October 2026.

December 2025 brought the next change: one article with 39 numbered amendments, in the act of 18 December 2025 on strengthening consumer protection in the energy sector. For the quota arithmetic in chapter 8, one of them matters most. Optional installations, it's now clear, also reduce the number of metering points to be equipped17. Others added new market roles in section 2, an exemption from the control unit for plants that feed in nothing (section 29(5)) and a power to regulate the wide area connections of plants by ordinance (section 19(2)).

On the timeline, the 2023 break is hard to miss.

Timeline of the legal framework, 2016 to 2032 Timeline in two phases. Until May 2023 the rollout hinges on a BSI determination: on 2 September 2016 the GDEW of 29 August 2016 enters into force and creates the Metering Point Operation Act; the installation duty depends on a BSI determination under the old section 30. 7 February 2020 BSI general ruling, the market declaration, mandatory rollout starts for consumers above 6,000 and up to 100,000 kilowatt hours. 4 March 2021 interim order of the Higher Administrative Court of North Rhine-Westphalia, case 21 B 1162/20: the ruling is manifestly unlawful. 27 July 2021 the act of 16 July 2021 enters into force and adds section 19(6), grandfathering for the case that a BSI determination falls away. 20 May 2022 the BSI withdraws the market declaration with retroactive effect; under section 19(6) installed devices may stay in use and four gateway types may still be installed. Since 27 May 2023 the rollout follows statutory dates: 27 May 2023 GNDEW in force, the duty follows the dates in section 45. 25 February 2025 act of 21 February 2025 in force, section 45 rewritten with period quotas of 90 percent, several price caps raised. 31 December 2025 first installed-base quota: 20 percent of all metering points to be equipped; since March 2026 the Federal Network Agency has opened supervisory proceedings against 434 companies. 1 July 2026 the form under section 54 becomes binding, Federal Network Agency determination BK6-24-125. 31 December 2026 first period quota: 90 percent of metering points due since 25 February 2025. 1 January 2027, dashed as a draft: the government's EEG 2027 bill would amend the MsbG, with a duty for plants above 2 kilowatts and plant quotas counted in metering points instead of capacity; nothing has been passed. 31 December 2028 next period quotas for 2027 to 2028, large installation cases start in 2028 at the latest. Then 31 December 2030 with the period quota for 2029 to 2030, and 31 December 2032 with 90 percent of all metering points to be equipped. UNTIL MAY 2023: THE ROLLOUT HINGES ON A BSI DETERMINATION SINCE 27 MAY 2023: THE ROLLOUT FOLLOWS STATUTORY DATES 2 Sep 2016 GDEW of 29 Aug 2016 enters into force creates the MsbG, installation duty hinges on a BSI determination (old s. 30) 7 Feb 2020 BSI general ruling: the market declaration Mandatory rollout starts for consumers above 6,000 up to 100,000 kWh 4 Mar 2021 Higher Administrative Court NRW, 21 B 1162/20 Interim order: ruling “manifestly unlawful” 27 Jul 2021 Act of 16 Jul 2021 adds s. 19(6) grandfathering if a BSI determination falls away 20 May 2022 BSI withdraws the market declaration with retroactive effect; continued use and new installs via s. 19(6) 27 May 2023 GNDEW enters into force Duty follows the dates in s. 45, the market declaration is gone 25 Feb 2025 Act of 21 Feb 2025: s. 45 rewritten Period quotas of 90 percent, several price caps raised 31 Dec 2025 First installed-base quota due: 20 percent of all metering points to be equipped; proceedings against 434 companies 1 Jul 2026 Form under s. 54 becomes binding Federal Network Agency determination BK6-24-125 of 20 Nov 2025 31 Dec 2026 First period quota due 90 percent of metering points due since 25 Feb 2025 1 Jan 2027 Planned: MsbG changes in the EEG 2027 bill duty for plants above 2 kW, plant quotas by metering points 31 Dec 2028 Next period quotas due Period 2027 to 2028; large cases start in 2028 at the latest then period quota 31 Dec 2030, installed-base quota 31 Dec 2032 (90 percent) Legislator BSI Court BNetzA (regulator) Deadline, s. 45 Draft

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Figure 1: From the GDEW to the next quota. Until May 2023 the rollout legally hinged on a BSI determination, which no longer existed after the 2022 withdrawal. Since 27 May 2023 it has followed the dates in section 45 MsbG: first an installed-base quota of 20 percent on 31 December 2025, then three period quotas of 90 percent up to 2030, and an installed-base quota of 90 percent at the end of 2032.
Conflicting sources

May 2023 or May 2024?

According to the BSI's archive page on the market analysis, the determination requirement went with the "Gesetz zum Neustart der Digitalisierung der Energiewende (GNDEW) vom Mai 2024"5. The Federal Law Gazette says 22 May 2023 for the signing, the MsbG itself 27 May 2023 for entry into force141. 2023 is right. The practical rule: for dates in the legal framework, trust the gazette over the agency's website.

The MsbG today: who must install and what it may cost

Section 29 now sorts the cases like this18. Above 6,000 kilowatt hours, a final consumer gets an iMSys. With a §14a agreement, a final consumer gets an iMSys plus a control unit, whatever the consumption. Plants above 7 kilowatts get the same, but only as far as needed to reach the capacity shares in section 45; an operator who permanently feeds in nothing and declares so needs no control unit. Everything else is an optional installation case. Where no iMSys is planned, at least a modern metering device has to go in: where economically justifiable by the end of 2032, in new buildings and major renovations by completion.

The cost side sits in section 30. Not 31. Easy to mix up, since before 2023 it was the other way round.

Case under section 30Annual gross capof which grid operatorof which connection user
above 100,000 kWh or above 100 kWreasonable chargeat most 80 eurosremainder
50,000 to 100,000 kWh or 25 to 100 kW220 euros80 euros140 euros
20,000 to 50,000 kWh or 15 to 25 kW190 euros80 euros110 euros
10,000 to 20,000 kWh, §14a case or 7 to 15 kW130 euros80 euros50 euros
6,000 to 10,000 kWh120 euros80 euros40 euros
optional installation60 euros30 euros30 euros

These caps apply "for the period from 1 January 2025" and came with the act of 21 February 20251915. Forget the 20 euro user share from 2023. For 6,000 to 10,000 kilowatt hours it's 40 now. Twice as much for the customer, the same for the grid operator.

A control unit adds up to 50 euros a year, charged once to the connection owner and once to the grid operator. The Federal Network Agency may change the caps by determination. The user share, though, it may raise no more than once every four years20.

And section 31? Still in the statute. With a date that has passed.

Not firmly established

An expired date

Section 31(1) allows the rollout to start, in the low-voltage grid up to 100,000 kilowatt hours and for plants up to 25 kilowatts, with systems whose logging, remote controllability or master data transmission can be delivered by an application update "by the end of 31 December 2025 at the latest"21. That date has passed. The provision hasn't changed. How the Federal Network Agency treats devices that got no update by then isn't publicly documented.

Next, transparency. Under section 54, any contract that triggers data communication through the gateway needs an "easily understandable form": who receives which data from whom, how often, for what purpose22. The word "standardised" used to be in that provision too. The GNDEW struck it1.

Standardised it is anyway. Since 1 July 2026 the Federal Network Agency has prescribed the form nationwide, through determination BK6-24-125 of 20 November 2025. The same decision covers the metering point operator framework contract and two new metering contracts, one for connection users and one for suppliers; chapter 7 takes a closer look23.

How the section 45 quotas work

In 2026 every default metering point operator is measured against one sentence. It demands at least 90 percent of the metering points newly due for equipment in the period from 25 February 2025 to the end of 202624. The installed base plays no part. Only what fell due inside the window.

Period quota is this book's term for a quota under section 45 MsbG that only counts the metering points falling due for equipment within a given period. The installed-base quota counts all of them.

For final consumers between 6,000 and 100,000 kilowatt hours and for the §14a cases, number 4 applies, with letters a to e:

LetterDeadlineBasisType
a31 Dec 202520 percent of all metering points to be equippedinstalled base
b31 Dec 202690 percent of those falling due from 25 Feb 2025 to 31 Dec 2026period
c31 Dec 202890 percent of those falling due in 2027 and 2028period
d31 Dec 203090 percent of those falling due in 2029 and 2030period
e31 Dec 203290 percent of all metering points to be equippedinstalled base

Two installed-base quotas, three period quotas in between. That has an awkward consequence. A company with a high overall equipment rate can still miss letter b, if it lets the cases due since February 2025 pile up. And one with a weak base can make it.

Plants are counted in kilowatts. The yardstick is the installed capacity behind equipped metering points. Periods close on 30 September and measurement follows on 31 December, a three-month lag. Only one quota looks backwards, for plants up to 100 kilowatts: by the end of 2028 another 50 percent of the capacity commissioned between 1 January 2018 and 25 February 2025 has to be covered. Plants above 100 kilowatts and consumers above 100,000 kilowatt hours start in 2028 at the latest24.

Forecast

What may come in 2027

The government's EEG 2027 bill also amends the MsbG, in its Article 3. The duty to fit an iMSys with a control unit would cover every plant above 2 kilowatts instead of above 7, without the current proviso about capacity shares, and the 130 euro price cap would start at 2 kilowatts accordingly. The plant quotas in section 45 would no longer count kilowatts but metering points to be equipped; for the quota due on 31 December 2026 the default operator could choose. Planned entry into force: 1 January 202725. On 25 September 2026 the Bundesrat asked for the new 2 kilowatt threshold to be dropped. The government refused26. First reading was on 24 September, the hearing on 5 October 202627. Nothing has been passed.

So who decides which street comes first? The statute sets no order. It does require the default operator to coordinate with the grid operators and to take due account of their operational needs. And it offers a route.

Legally binding

The underrated provision: section 45(3)

Default metering point operators must coordinate the rollout regularly with the distribution and transmission system operators in their area. They may also sign binding agreements with them, on which installations come first in time or place and on duties beyond section 29. If a Federal Network Agency determination under section 33 allows it, such agreements may even set different metering charges and higher total price caps24.

That gives both sides a lever to steer the rollout to where the grid needs readings.

Not that the result could be hidden. Paragraph 4 has the Federal Network Agency publish progress figures, company by company too. Chapter 8 goes through them.

Who works with whom: the market roles

Default metering point operator (gMSB) is, under section 2 no. 4 MsbG, the operator of the energy supply grid, a fallback metering point operator, or a third party to which basic responsibility was transferred in a procedure under sections 41 and 4328.

Gateway administration belongs, by law, to the metering point operator. It can run it in-house or contract it out2928.

RoleTaskLegal basis
gMSB, default metering point operatormetering in the grid area, equipment duties and quotasss. 3, 29, 45 MsbG
wMSB, competitive metering point operator (in the act: a third party)takes over metering at the connection user's request (s. 5; after the gMSB has installed an iMSys, no earlier than two years on) or at the connection owner's choice for the whole property (s. 6)ss. 5, 6 MsbG30
GWA, gateway administratorruns the gateway, as the metering point operator or on its behalf; certified security managements. 2 no. 20, s. 25 MsbG31
VNB (DSO), distribution system operatorreceives load and meter reading profiles; by law the gMSB unless it transfers basic responsibilitys. 2 no. 4, s. 60 MsbG32
ÜNB (TSO), transmission system operatorreceives readings, also as balancing coordinators. 60 MsbG
LF, supplierreceives its customers' readings for billings. 60 MsbG
aEMT, active external market participantmay communicate with and act on devices at the customer's premises through the gateway's TLS proxy (CLS channel); a passive EMT only receives dataTR-03109-1, section 2.2.433
Meter value processor (Messwertweiterverarbeiter)processes billing-relevant readings once a Federal Network Agency determination assigns this task to a market player; receives load and meter reading profiles for its. 2 no. 14a, s. 60(3) no. 4 MsbG32
Party responsible for aggregation (Aggregationsverantwortlicher)aggregates quarter-hourly or profile values into summed time series once a Federal Network Agency determination assigns this task to a market players. 2 no. 1, s. 60(3) no. 5 MsbG

The last two roles have only been in the act since 23 December 202517. Who fills them is up to the Federal Network Agency.

Market roles under the Metering Point Operation Act Structure diagram of the market roles. The connection user and the connection owner may choose a third party as metering point operator. At the centre is the metering point operator: by default the distribution system operator holds the basic responsibility, a competitive operator takes over on request under sections 5 and 6. Gateway administration is a function of the metering point operator, not a market role of its own: the operator assigns the gateway administrator or acts as one; the gateway administrator runs the smart meter gateway at the customer's meter. The metering point operator delivers readings under section 60 to the distribution system operator, the transmission system operator and the supplier. An active external market participant talks to the gateway and the devices behind it over the CLS channel. The Federal Network Agency supervises the metering point operator and issues determinations. The BSI certifies the smart meter gateway. The gateway administrator proves its security management with a certificate from the BSI or an accredited body and has it audited regularly by BSI-certified auditors; the BSI receives the audit report for information. The BSI also sets protection profiles and technical guidelines. RECEIVE READINGS (S. 60) Connection user or owner may choose a third-party MSB BNetzA supervises, sets rules BSI certifies, sets TRs Metering point operator (MSB) gMSB: by default the DSO wMSB on request (s. 5, 6) GWA gateway administrator a function of the MSB SMGW at the customer meter BSI-certified aEMT active external market participant DSO distribution operator TSO transmission operator Supplier LF (Lieferant) supervises certificate, audit report assigns administers certifies via CLS assigns or chooses delivers readings via the CLS channel supervises, certifies or receives evidence

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Figure 2: Who works with whom in metering. Gateway administration is a function of the metering point operator, which assigns the gateway administrator or acts as one. It delivers readings to grid operators and suppliers. The Federal Network Agency supervises, the BSI certifies.

And the authorities? Supervision, standard contracts, market processes and enforcement sit with the Federal Network Agency. The BSI certifies gateways under section 24 and specifies what they must be able to do34. Configuring a gateway is for the gateway administrator alone. Its service technician on site works within narrow limits, and only those the administrator has enabled3533. Certification is chapter 3, the metering functions are chapter 4.

When a quota is missed

A default metering point operator that fails its duties faces measures under section 76; section 45(2) opens that door for the Federal Network Agency24. The agency can order conduct to stop. It can prescribe remedies. It can even declare an infringement after it has ended. For procedure, section 76(4) points to the Energy Industry Act, the EnWG36. That's where the penalty payment lives: at least 1,000 euros, at most ten million37.

Section 12(2g) EnWG goes further. Added in February 2025, it lets the agency strip a default metering point operator of its basic responsibility and put in a fallback operator. Two routes lead there. In one, the equipment duty for cases with a control unit is undershot by at least 25 percent, and this could "contribute materially to a not insignificant threat to or disruption of the security or reliability of the electricity system in at least one control area". In the other, nobody can tell, because the operator has failed its annual review and reporting duty or its duty to contribute to the overall report. The transmission system operators file that report every year by 30 November, the first one in 202538.

The bar is high.

But it's there. Since 2025, badly missing the quota for controllable cases puts basic responsibility at risk. And one section 45 quota is already history: the 20 percent due on 31 December 2025. Since March 2026 the Federal Network Agency has opened supervisory proceedings against 434 companies that missed it. At 77 of them the quota stood at zero percent. 150 proceedings have since been closed39. Chapter 8 has the details.

The EU level: plenty of strategy, few obligations

Brussels started 2026 with strategy. The Commission's Strategic Roadmap for Digitalisation and AI in the Energy Sector, COM(2026) 501, reached the Council on 3 June 2026: a communication, not legislation. Its third flagship action promised a legislative proposal for 2026 to speed up the smart meter rollout, with minimum coverage for each member state40.

Six weeks later the proposal was on the table. COM(2026) 600 of 17 July 2026 would add an Article 18b to the Electricity Market Regulation (EU) 2019/943. Smart metering systems would have to cover at least 50 percent of all final customers by the end of 2030 and at least 75 percent by the end of 2033. A member state below 30 percent at entry into force gets one extra year for each step. A cost-benefit assessment would only apply to deployment above 75 percent41. That's a proposal in the legislative process. Not law.

Binding EU law does exist, in cybersecurity. The Network Code on Cybersecurity, Delegated Regulation (EU) 2024/1366, has been in force since 13 June 2024. Member states were to designate a competent authority by 13 December 2024. ACER's count on 14 October 2025: ten notifications out of 27, none from Germany42. German law has caught up since. Under section 54c EnWG, in force since 28 November 2025, the Federal Ministry for Economic Affairs and Energy is the competent authority, with individual tasks assigned to the Federal Network Agency and the BSI43. Whether the notification to ACER has followed could not be verified.

Negative finding

CEEDS and the demand response code: not law yet

The roadmap never mentions a "Common European Energy Data Space" or "CEEDS". What it talks about is simplified cross-border energy data exchange40. A Network Code on Demand Response doesn't exist yet either. ACER recommended a draft on 7 March 2025, and the Commission still describes the code as under development4445. For German grid operators, neither creates deadlines so far.

For the German rollout, then, the MsbG is what counts for now. How an EU quota over all final customers would relate to a German quota over mandatory cases is an open question. One number for scale: on 30 June 2026, 5.9 percent of reported metering locations had an iMSys39. Four checks follow. They differ in length because the deadlines differ in distance:

  1. Calculate your own period quota

    Count the mandatory cases that have newly fallen due since 25 February 2025, and keep them apart from the installed base. On 31 December 2026, letter b depends on that number and nothing else. A good overall equipment rate won't help.

  2. Keep plants in kilowatts and in metering points

    For generation plants, section 45 currently counts installed capacity per commissioning period, with 30 September as the cut-off. The government's EEG 2027 bill would switch to counting metering points from 2027. Track both until the bill is passed.

  3. Consider an agreement under section 45(3)

    Metering point and grid operators can bindingly agree which feeders get equipped first. The statute prescribes no form. Put it in writing anyway.

  4. Check contracts against BK6-24-125

    Mandatory since 1 July 2026.

See it in the model

The interactive model shows where in the metering chain this chapter sits.

The model: from the meter to the billing system

Open deadlines for this chapter

Live from the deadline calendar, data as of 14 October 2026. When a deadline changes, this list changes with it.

All deadlines in the deadline calendar →

Sources

Primary sources first. Uncertain statements are marked as uncertain in the text rather than left out.

  1. Act on Restarting the Digitalisation of the Energy Transition (GNDEW), Article 2 (amendments to the MsbG), nos. 20, 21, 30 and 37, Bundestag enactment as Bundesrat printed paper 161/23; entry into force on 27 May 2023 per the footnote to sections 31 to 34 MsbG (German). bundesrat.de and gesetze-im-internet.de, retrieved 14 October 2026.
  2. Higher Administrative Court of North Rhine-Westphalia, order of 4 March 2021, case 21 B 1162/20, operative part and paragraphs 2, 3, 5, 8, 10, 23, 34, 121, 124 and 126 (German). nrwe.justiz.nrw.de, retrieved 14 October 2026.
  3. German Bundestag, printed paper 18/7555, government bill on the digitalisation of the energy transition, Article 1, section 29(1) and (5) and section 31(1) of the draft MsbG; section 29(5) and the time frames in section 31(1) were left unchanged by the committee (printed paper 18/8919, letter l) (German). dserver.bundestag.de, retrieved 14 October 2026.
  4. Metering Point Operation Act (MsbG), header data: signed 29 August 2016, BGBl. Part I p. 2034, in force under Article 16 GDEW on 2 September 2016, last amended by Article 17 of the act of 18 December 2025 (BGBl. 2025 Part I No. 347) (German). gesetze-im-internet.de, retrieved 14 October 2026.
  5. BSI: market analysis, archive page (according to the page last updated until 20 May 2022) (German). bsi.bund.de, retrieved 14 October 2026.
  6. German Bundestag, printed paper 18/8919 of 22 June 2016, recommendation and report of the Committee on Economic Affairs and Energy, amendment to section 30 sentence 1 of the draft MsbG (German). dserver.bundestag.de, retrieved 14 October 2026.
  7. Federal Office for Information Security (BSI): general ruling on the technical possibility of installing intelligent metering systems, ref. 610 01 04/2019_001, decided 31 January 2020, signed 7 February 2020, deemed notified 24 February 2020 (German). bsi.bund.de, retrieved 14 October 2026.
  8. BSI: general ruling withdrawing the general ruling on technical possibility, ref. 610 01 04/2022_01, of 20 May 2022, with reasons (German). bsi.bund.de, retrieved 14 October 2026.
  9. Administrative Court of Cologne, order of 21 July 2020, case 9 L 663/20, paragraph 3 (German). nrwe.justiz.nrw.de, retrieved 14 October 2026.
  10. BSI: general ruling under section 19(6) MsbG, ref. 610 01 04/2022_02, of 20 May 2022, operative part nos. 1 and 2 and first part of the reasons (German). bsi.bund.de, retrieved 14 October 2026.
  11. German Bundestag, printed paper 19/30899 of 22 June 2021, recommendation of the Committee on Economic Affairs and Energy on the bill implementing EU requirements and regulating pure hydrogen networks in energy law, amendment of the MsbG, no. 1a (section 19(6)), p. 25; promulgated as Article 10 of the act of 16 July 2021 (BGBl. I p. 3026) (German). dserver.bundestag.de, retrieved 14 October 2026.
  12. Federal Law Gazette 2021 Part I No. 47, issued 26 July 2021, act of 16 July 2021 implementing EU requirements and regulating pure hydrogen networks in energy law, Article 10 no. 1a (section 19(6) MsbG), p. 3059; in force the day after promulgation under Article 15(1), as Article 10 is not among the exceptions in paragraphs 2 to 6, p. 3078 (German). bgbl.de, retrieved 14 October 2026.
  13. Bundesrat, printed paper 161/23 of 21 April 2023, enactment by the German Bundestag (97th sitting on 20 April 2023), Bundesrat deadline 12 May 2023 (German). bundesrat.de, retrieved 14 October 2026.
  14. Federal Law Gazette 2023 Part I No. 133 of 26 May 2023, Act on Restarting the Digitalisation of the Energy Transition of 22 May 2023 (German). recht.bund.de, retrieved 14 October 2026.
  15. Federal Law Gazette 2025 Part I No. 51 of 24 February 2025, Act amending energy law to avoid temporary generation surpluses of 21 February 2025, Article 1 no. 2, Article 2 nos. 8, 9 and 14, Article 9 (German). recht.bund.de, retrieved 14 October 2026.
  16. Federal Government: Ein Programm für Aufschwung und Beschäftigung, results of the coalition committee of 2 July 2026, p. 7 (German). bundesregierung.de, retrieved 14 October 2026.
  17. Federal Law Gazette 2025 Part I No. 347 of 22 December 2025, act of 18 December 2025 on strengthening consumer protection in the energy sector and amending further energy law provisions, Article 17 nos. 2, 7, 14 and 22 (section 2 nos. 1 and 14a, section 19(2), section 29(3) and (5), section 45(1) sentences 3 and 4 MsbG); in force the day after promulgation under Article 29 (German). recht.bund.de, retrieved 14 October 2026.
  18. Section 29 MsbG, equipping metering points with intelligent metering systems, control units and modern metering devices, paragraphs 1 to 3 and 5 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  19. Section 30 MsbG, economic justifiability, price caps, paragraphs 1 to 3 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  20. Section 30(2) and (6) and section 33(1) and (3) MsbG (German). gesetze-im-internet.de, retrieved 14 October 2026.
  21. Section 31 MsbG, agile rollout, application update (German). gesetze-im-internet.de, retrieved 14 October 2026.
  22. Section 54 MsbG, transparency requirements for contracts (German). gesetze-im-internet.de, retrieved 14 October 2026.
  23. Federal Network Agency, Ruling Chamber 6: determination procedure adapting the metering point operator framework contract and setting the metering contracts, ref. BK6-24-125, decision of 20 November 2025, applicable from 1 July 2026, with the form under section 54 MsbG (German). bundesnetzagentur.de, retrieved 14 October 2026.
  24. Section 45 MsbG, equipment duties of the default metering point operator, paragraphs 1 to 4 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  25. German Bundestag, printed paper 21/7867 of 7 September 2026, government bill on a plannable, cost-efficient, grid-compatible and market-oriented expansion of renewable energy in the power sector, Article 3 (amendment of the MsbG), p. 77, Article 7 (entry into force), p. 87, and reasons for Article 3 (German). dserver.bundestag.de, retrieved 14 October 2026.
  26. German Bundestag, printed paper 21/8298 of 30 September 2026, Bundesrat opinion (1068th sitting on 25 September 2026) and government reply, no. 54 each, pp. 38 and 66 (German). dserver.bundestag.de, retrieved 14 October 2026.
  27. German Bundestag: text archive 2026, hearing of the Committee on Economic Affairs and Energy on 5 October 2026 on printed paper 21/7867, noting the first reading on 24 September 2026 (German). bundestag.de, retrieved 14 October 2026.
  28. Section 2 MsbG, definitions, nos. 1, 4, 14a and 20 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  29. Section 3(1) MsbG, metering point operation (German). gesetze-im-internet.de, retrieved 14 October 2026.
  30. Sections 5 and 6 MsbG, right of the connection user and the connection owner to choose; two-year period in section 5(1) sentence 2, whole property and bundled offer in section 6(1) (German). gesetze-im-internet.de, retrieved 14 October 2026.
  31. Section 25 MsbG, smart meter gateway administrator, certification (German). gesetze-im-internet.de, retrieved 14 October 2026.
  32. Section 60(3) sentence 1 nos. 1 to 5 MsbG, data transmission to distribution system operators, transmission system operators and balancing coordinator, energy suppliers, meter value processors and parties responsible for aggregation (German). gesetze-im-internet.de, retrieved 14 October 2026.
  33. Federal Office for Information Security (BSI): BSI TR-03109-1, interoperability requirements for the communication unit of an intelligent metering system, version 2.0 of 13 December 2024, sections 2.2.3, 2.2.4, 2.2.7 and 3.8.1 (German). bsi.bund.de, retrieved 14 October 2026.
  34. Section 24 MsbG, certification of the smart meter gateway (German). gesetze-im-internet.de, retrieved 14 October 2026.
  35. Section 21 MsbG, minimum requirements for intelligent metering systems, paragraph 1 no. 4 letter b (German). gesetze-im-internet.de, retrieved 14 October 2026.
  36. Section 76 MsbG, supervisory measures of the Federal Network Agency, paragraphs 1 to 4 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  37. Section 94 Energy Industry Act (EnWG), penalty payment, with the note on its application via section 76(4) MsbG (German). gesetze-im-internet.de, retrieved 14 October 2026.
  38. Section 12(2b) sentence 2, (2c) sentences 1 and 3 and (2g) nos. 1 and 2 EnWG, inserted by the act of 21 February 2025 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  39. Federal Network Agency (BNetzA): press release on its half-yearly metering survey, 21 September 2026, reference date 30 June 2026, sections on the data correction and on supervisory proceedings (German). bundesnetzagentur.de, retrieved 14 October 2026.
  40. European Commission: Strategic Roadmap for Digitalisation and AI in the Energy Sector, COM(2026) 501 final, Council document ST 10101/26, received 3 June 2026, flagship action 3. data.consilium.europa.eu, retrieved 14 October 2026.
  41. European Commission: Proposal for a Regulation amending Regulation (EU) 2019/943 as regards future-proofing electricity bills in the Union, through reducing system costs and fostering electrification and digitalisation, COM(2026) 600 final, procedure 2026/0203(COD), Council document ST 12071/26 of 17 July 2026, Article 1 point 2 (Article 18b), p. 33. data.consilium.europa.eu, retrieved 14 October 2026.
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  44. ACER: Recommendation No 01/2025 of 7 March 2025 on the reasoned proposal for the establishment of the Network Code on Demand Response. acer.europa.eu, retrieved 14 October 2026.
  45. European Commission: Electricity network codes and guidelines, section on the Network Code on Demand Response. energy.ec.europa.eu, retrieved 14 October 2026.

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Contents of the handbook

  1. 1The legal framework: from the GDEW to today's MsbG
  2. 2Devices and architecture: what an intelligent metering system is
  3. 3BSI standards, certification and the smart metering PKI
  4. 4Tariff use cases: TAF 1 to 16 and version 2.0
  5. 5Grid-oriented control under §14a EnWG
  6. 6Dynamic tariffs and grid charges in transition
  7. 7Market communication: how meter readings become processes
  8. 8Rollout practice: figures, supervision and what nobody measures
  9. +The model: from the meter to the billing system
  10. +Reading paths through ten topic fields
  11. +Open questions and negative findings

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