Empty hearing room after a consultation: name cards turned over, half-full water glasses, submissions lying face down

Digitalising the Energy Transition

Open questions and negative findings

What this book could not settle: data nobody collects, contradictions between sources, and terms that circulate in the industry but cannot be verified.

Status: Digitalising the Energy Transition
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Some questions stayed open while the eight chapters were being written. Either nobody collects the data, or two sources disagree, sometimes two publications by the same authority. Then there are terms that turn up in slide decks and specifications with no source behind them at all. This appendix collects them, as of 14 October 2026. Each gets more room in the chapter named.

Data nobody collects

Negative finding

Which functions run in the field

The Federal Network Agency counts installed intelligent metering systems, not functions1. How many gateways actually deliver grid status data under TAF 10, or high-frequency values under TAF 14? Nobody publishes that. Chapter 4.

Until 2021 an annual progress monitor put a score on all this, the "Barometer Digitalisierung der Energiewende". Its last edition came out on 3 June 20212, covered the year 2020 and stood at 44 out of 1003. Nothing since. Its place went to the digitalisation report under section 48 MsbG, first published in July 2024, which drops the scoring and appears only every few years4. Anyone measuring progress in 2026 therefore has individual statistics. A running overall picture? No.

Dynamic tariffs are no better documented. The monitoring report counts 412 suppliers offering one in 20245. How many households use such a tariff isn't recorded anywhere, and the 2026 report hadn't appeared by mid-October (chapter 6).

Negative finding

No coercive fine actually imposed

Since March 2026 the Federal Network Agency has opened supervisory proceedings against 434 companies for missing rollout quotas and closed 150 of them again6. An actually imposed coercive fine had not been publicly documented by mid-October 2026. Chapter 8.

Where sources contradict each other

Conflicting sources

UTILTS: replacement consulted on, then kept

On 31 July 2026 ruling chambers 6 and 7 put a draft out for consultation in notice no. 57: "Die UTILTS wird vollständig durch API-Webdienste ersetzt", UTILTS would be fully replaced by API web services7. On 1 October 2026 notice no. 58 reversed that: "Die UTILTS bleibt damit erhalten", UTILTS stays8. The newer notice applies. Slide decks and project plans from August and September 2026 often still carry the old position. Chapter 7.

Two rollout figures for 31 December 2025 are going round. Trade articles from spring 2026 give 3,094,346 intelligent metering systems, or 5.5 percent of all metering locations9. The Federal Network Agency later corrected that to 2,406,454 systems and 4.4 percent1. Nobody updated the older articles.

An old state lives on in the catalogue of tariff use cases, too. The full list of TAF 1 to 14 stopped applying with version 1.1 of the guideline in September 2021, which keeps only TAF 1, 2, 6, 7, 9, 10 and 1410. Version 2.0 of 13 December 2024 adds a TAF 15 and reassigns number 811, and the BSI note on TAF 5 and 16 of September 2025 lists TAF 15 as well12. Reading "TAF 1 to 14"? Then you're reading the state before 2021 (chapter 4).

A smaller case: the errata to the guideline on TAF 14. The Higher Administrative Court of North Rhine-Westphalia dates them 12 December 201913, the BSI download page the 16th14. So the book only says December 2019.

Not firmly established

The number 77

Reports on rollout supervision keep coming back to the number 77. In March 2026 the Federal Network Agency opened 77 proceedings against metering point operators that, according to its figures, had not yet started the rollout15. By September 2026 there were 434 proceedings in total, and 77 of those companies stood at zero6. The agency's table for 31 December 2025 lists exactly 77 companies at 0 percent16, so the same group is probably meant each time. "77 proceedings" as the total is wrong, and "77 operators without a single device" goes further than the table. Chapter 8.

Terms without evidence

TermWhat can be found
BK6-24-242Not traceable as the file number of a §14a determination. The determination that governs control is BK6-22-30017.
CEEDS as an EU legal frameworkNeither "CEEDS" nor "Common European Energy Data Space" appears in the Commission's digitalisation roadmap, COM(2026) 501. The text speaks of a framework for simplified cross-border energy data exchange18.

What hasn't been decided yet

AgNes, the new grid charge system, is a matter for the Federal Network Agency's Grand Ruling Chamber for energy19. The draft came out on 6 August 2026, the decision is still pending, and the system is meant to apply from 202920. Module 3 under §14a stays untouched. What happens to modules 1 and 2, the draft doesn't say explicitly (chapter 6).

May the gateway replace the control box? Also open. Gateways with an integrated control module are already in the field, BSI-certified according to the manufacturer21. Yet as of mid-October 2026 the BSI product list shows no certificate against version 2.0 of the protection profile, the version that describes this function22 (chapters 4 and 5). The BSI's staged model, for its part, has been announcing a third stage since version 2.1 in November 2021. It still doesn't describe it23.

On the rollout itself, too, more has been announced than decided. The coalition wants tighter targets, more than 90 percent of the relevant metering points by the end of 2030, and a "smart meter light" for customers outside the mandatory cases24. A draft regulation from the European Commission would require at least 50 percent of all final customers to have a smart metering system by the end of 2030 and 75 percent by the end of 2033, with one extra year for member states below 30 percent at entry into force25. None of it is law as of mid-October 2026 (chapter 8).

That leaves the EU network code on demand response. Not adopted. No adoption could be found after the ACER recommendation of 7 March 202526, so German grid operators currently have no obligation under it.

Sources

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

  1. Federal Network Agency: Rollout of intelligent metering systems, statistics as of 30 June 2026 with corrected values for 31 December 2025 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  2. Clearingstelle EEG|KWKG: record of the study Barometer Digitalisierung der Energiewende 2020, dated 3 June 2021 (German). clearingstelle-eeg-kwkg.de, retrieved 14 October 2026.
  3. EY for the Federal Ministry for Economic Affairs and Energy: Barometer Digitalisierung der Energiewende, reporting year 2020, p. 5 (German). bundeswirtschaftsministerium.de, retrieved 14 October 2026. Study.
  4. Federal Ministry for Economic Affairs and Energy: digitalisation report under section 48 MsbG (German). bundeswirtschaftsministerium.de, retrieved 14 October 2026.
  5. Federal Network Agency and Federal Cartel Office: Monitoring report energy 2025 (German). data.bundesnetzagentur.de, retrieved 14 October 2026.
  6. Federal Network Agency: press release on the rollout of intelligent metering systems, 21 September 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  7. Federal Network Agency, ruling chambers 6 and 7: notice no. 57 on data formats, 31 July 2026, consultation for the 1 April 2027 implementation date (German). bundesnetzagentur.de, retrieved 14 October 2026.
  8. Federal Network Agency, ruling chamber 6: notice no. 58 on data formats, 1 October 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  9. energiezukunft: current figures on the smart meter rollout, 7 April 2026, with the uncorrected data as of 31 December 2025 (German). energiezukunft.eu, retrieved 14 October 2026. Trade press.
  10. BSI: TR-03109-1, version 1.1 of 17 September 2021, table 4.1 and changelog for chapter 4 (German). bsi.bund.de, retrieved 14 October 2026.
  11. BSI: TR-03109-1, version 2.0 of 13 December 2024, tables 3.2 and 3.11 (German). bsi.bund.de, retrieved 14 October 2026.
  12. BSI: event-based tariff use cases TAF5 and TAF16, implementation note of 16 September 2025 (German). bsi.bund.de, retrieved 14 October 2026.
  13. Higher Administrative Court of North Rhine-Westphalia, order of 4 March 2021, case 21 B 1162/20, paragraph 8 (German). nrwe.justiz.nrw.de, retrieved 14 October 2026.
  14. BSI: TR-03109-1, errata on TAF 14, download page dated 16 December 2019 (German). bsi.bund.de, retrieved 14 October 2026.
  15. Federal Network Agency: press release on supervisory proceedings in metering, 27 March 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  16. Federal Network Agency: rollout quotas iMSys Q4 2025, table per default metering point operator, reference date 31 December 2025 (German). bundesnetzagentur.de, retrieved 14 October 2026. The file is no longer linked from the rollout page; the count of zero quotas is our own analysis.
  17. Federal Network Agency, ruling chamber 6: controllable consumption devices under §14a EnWG, proceeding BK6-22-300 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  18. European Commission: Strategic Roadmap for Digitalisation and AI in the Energy Sector, COM(2026) 501, Council document ST 10101/2026 INIT. data.consilium.europa.eu, retrieved 14 October 2026.
  19. Federal Network Agency, Grand Ruling Chamber Energy: AgNes determination procedure, GBK-25-01-1#3, procedure page as of 21 September 2026. bundesnetzagentur.de, retrieved 14 October 2026.
  20. Federal Network Agency: press release on the draft determination for the general grid charge system for electricity, 6 August 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  21. Zeitung für kommunale Wirtschaft: digitalisation ticker, two items of 1 July 2026 on gateways with an integrated CLS module and on control directly from the gateway (German). zfk.de, retrieved 14 October 2026. Trade press, company statements.
  22. BSI: certified products under section 24 MsbG, smart meter gateway (German). bsi.bund.de, retrieved 14 October 2026.
  23. BSI: staged model for developing the standards for digitalising the energy transition, part 2 state of the art, version 2.1 of 11 November 2021 (German). bsi.bund.de, retrieved 14 October 2026.
  24. CDU, CSU and SPD: Ein Programm für Aufschwung und Beschäftigung (a programme for recovery and employment), result of the coalition committee of 2 July 2026, p. 7 (German). bundesregierung.de, retrieved 14 October 2026. Political declaration of intent.
  25. European Commission: proposal for a regulation amending Regulation (EU) 2019/943 on future-proof electricity bills in the Union (lower system costs, more electrification and digitalisation), COM(2026) 600 final of 17 July 2026, Article 18b; Bundesrat printed paper 501/26 of 1 September 2026, p. 40 (German version). dserver.bundestag.de, retrieved 14 October 2026. Draft in procedure 2026/0203(COD), not law.
  26. ACER: Recommendation No 01/2025 on the Network Code on Demand Response, 7 March 2025. acer.europa.eu, retrieved 14 October 2026.

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