Yard of a utility depot on a frosty morning: one installer loads boxes into a white van while a second checks the route sheet beside the pallet truck

Chapter 8 · Part IV: Market and practice

Rollout practice: figures, supervision and what nobody measures

The smart meter rollout in figures: corrected BNetzA statistics, 434 supervisory proceedings, the barometer that never returned and data that does not exist.

Status: 22 min readDigitalising the Energy Transition
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Summary

Three sets of figures are in circulation for 31 December 2025. The Federal Network Agency first reported 5.5 percent of all metering locations with a smart metering system. In September 2026 it corrected that to 4.4 percent, and for the same date it puts the share of mandatory installation cases equipped at 23.3 percent. Only the first number is wrong today. The other two measure different things.

By mid-2026 the rollout stood at 26.1 percent of the mandatory cases that count towards the quota and 5.9 percent of the total stock. 434 companies have faced supervisory proceedings since March. Coercive fines imposed by mid-September: none. Politically, more has been announced than decided: the coalition wants more than 90 percent by the end of 2030, and a draft regulation from the European Commission proposes targets for all final customers.

Do the devices actually deliver quarter-hour values, or operate a control box? Nobody publishes a figure.

Three figures for one reference date

On 21 September 2026 the Federal Network Agency (BNetzA) swapped two numbers on its rollout page. For 31 December 2025 it now lists 2,406,454 metering locations with an intelligent metering system (iMSys), 4.4 percent of the stock1. In spring the figures had been 3,094,346 devices and 5.5 percent2. Close to 700,000 devices gone. On paper.

Why? The press release of the same day says the totals were flawed and double-counted, for instance at metering locations with a PV system above 7 kW and consumption above 6,000 kWh3. A connection like that sits in two installation groups. The current survey form explicitly allows one metering location to be assigned to several groups, which is why it asks for the total number of devices in a separate question4. Add up the groups and you count twice.

The mandatory-case quota wasn't touched. "The quotas on which the ongoing supervisory proceedings are based are not affected by this," the agency writes3. Ten days earlier the federal government had put a number on that base: 4,709,487 mandatory installation cases5.

Reference dateWhat is countediMSysBaseShare
31 Dec 2025total stock, first release3,094,346about 56.5 m metering locations5.5 %2
31 Dec 2025total stock, corrected2,406,454not stated4.4 %1
31 Dec 2025mandatory cases1,095,7154,709,48723.3 %5
30 Jun 2026mandatory cases1,259,2704,831,17826.1 %1
30 Jun 2026total stock3,172,57954,135,2025.9 %1
Conflicting sources

Two totals for the same day

First version, as reported on 7 April 2026: 5.5 percent of about 56.5 million metering locations2. The agency's version since 21 September 2026: 4.4 percent1. Older articles and slide decks don't get corrected. Whenever you see a figure for the end of 2025, check which month the source is from.

Mandatory cases versus total stock

26.1 or 5.9 percent? Both describe 30 June 2026. Both sit on the same agency page1.

26.1 %
of mandatory cases had an iMSys by mid-2026
reference date 30 June 2026
5.9 %
of all metering locations were equipped on that date
a factor of 4.4 below the mandatory quota
434
companies have faced supervisory proceedings since March 2026
150 closed by 21 September 20263
0
coercive fines had been imposed by 11 September 2026
threatened: 5,000 to 500,000 euros5

The mandatory quota only counts final customers using 6,000 to 100,000 kilowatt hours a year, plus controllable consumer devices under §14a EnWG1. The total quota takes in every metering location, the many households below that threshold included. Between the two lies a factor of 4.4.

Quote only one of them and you distort the picture. At 26.1 percent the rollout looks well under way. At 5.9 percent it has barely begun. Neither is true.

Three sets of figures for 31 December 2025 and the status on 30 June 2026 Bar chart with shares in percent. Reference date 31 December 2025: total stock in the first release 5.5 percent with 3,094,346 iMSys, superseded; total stock after the Federal Network Agency's correction 4.4 percent with 2,406,454 devices; mandatory installation cases 23.3 percent, 1,095,715 of 4,709,487. Reference date 30 June 2026: mandatory cases 26.1 percent, 1,259,270 of 4,831,178; total stock 5.9 percent, 3,172,579 of 54,135,202. On 30 June 2026 the mandatory quota is 4.4 times the total quota. A vertical line in the 31 December 2025 block marks the target of 20 percent of mandatory cases for that date under section 45 MsbG. A note below the chart gives the next target: by 31 December 2026, 90 percent of the metering points due for equipment since 25 February 2025 must be equipped. That is a period quota and cannot be compared with the bars. REFERENCE DATE 31 DECEMBER 2025 REFERENCE DATE 30 JUNE 2026 Total stock, first release 3,094,346 iMSys 5.5 % superseded Total stock, corrected 2,406,454 iMSys 4.4 % Mandatory cases 1,095,715 of 4,709,487 23.3 % Mandatory cases 1,259,270 of 4,831,178 26.1 % Total stock 3,172,579 of 54,135,202 5.9 % 0 % Target, 31 Dec 2025 (§45): 20 % of mandatory cases Next target, 31 Dec 2026: 90 % of the metering points due for equipment since 25 Feb 2025. That is a period quota and cannot be compared with these bars. Factor 4.4

Open figure full size

Figure 1: The three sets of figures for 31 December 2025 and the status on 30 June 2026. Blue for mandatory cases, turquoise for the total stock, dashed for the superseded first release. The vertical line marks the target of 20 percent of mandatory cases on 31 December 2025 under section 45 MsbG. It applies to each default metering point operator individually, not to the average and not to the total stock. The next target, due on 31 December 2026, covers 90 percent of the metering points that have fallen due for equipment since 25 February 2025. It is a period quota and cannot be compared with the bars.

Behind the average there's a gradient. The 19 operators with more than 500,000 metering locations average 29.7 percent; the 591 with fewer than 30,000, 19.2 percent1. That smallest class makes up almost three quarters of all 803 default metering point operators. And the averages are unweighted.

The total stock is fuzzy too. Competitive metering point operators report voluntarily, many have stopped sending data, and for them the agency plugs in historical values1. So the real total quota is probably higher, it says. By how much? It doesn't say.

How the period quota is measured

From the end of 2026 a different count matters. Chapter 1 covers the mechanics; this is about measurement. Under section 45(1) no. 4(b) MsbG, at least 90 percent of the metering points that have needed equipping since 25 February 2025 must be equipped by 31 December 20266. A second quota falls due on the same date, for generation plants, and it counts capacity: the equipped metering points must cover at least 90 percent of the capacity commissioned between 25 February 2025 and 30 September 2026, under no. 2(a)6. The government's draft for the EEG 2027 wants to switch these plant quotas to metering points (chapter 1).

What falls under the period quota? The agency's survey form spells it out: existing metering locations that become mandatory cases through higher consumption or a new §14a device, plus metering locations in new buildings or newly commissioned connections4. Two more rules from the same form carry weight. A §14a case only counts with a control unit. And that unit only counts once it's integrated into the operator's systems and ready for operation. A box that's installed but not integrated counts as not equipped4.

Strict. And consistent, since a box that isn't connected controls nothing.

How often does the agency measure? Half-yearly, says the top of the page. Quarterly, says the FAQ below it1. The law just says "regularly"6.

Supervision under section 76: 434 proceedings, no fine

On 27 March 2026 the agency opened 77 proceedings against companies that, by its figures, hadn't started the rollout yet7. A first step, it said. Six months later the count stood at 434 companies. 150 proceedings had been closed, for instance because the quota had since been met or the default responsibility had been transferred3. The government's answer of 11 September gives 108 closures as of 31 August5. Two reference dates. No contradiction.

Chapter 1 deals with the provision itself. In practice a proceeding moves in stages: a hearing with the chance to comment7, then an order to remedy the breach and the threat of a coercive fine, and finally the fine itself1. Section 94 EnWG, to which section 76(4) MsbG refers, sets the range at 1,000 euros to ten million euros89. The amounts threatened so far lie between 5,000 and 500,000 euros. "No coercive fines have been imposed so far," the government replied5.

A coercive fine isn't a penalty. Its job is to force compliance, and it can be repeated and raised1. Which is how an authority can run hundreds of proceedings without collecting a single euro. Is the pressure working? Only the closures show it. The government puts the delays down to operators' IT migrations, scarce hardware and an overstretched electrical trade5.

Not firmly established

The number 77: three readings, probably one group

In trade articles, 77 stands for the proceedings opened on 27 March 20267, for the companies with a quota of 0 percent among the 4343, or for default operators said not to have installed a single device by the end of 2025. The agency's table for 31 December 2025 lists exactly 77 companies at 0 percent, in both columns10. Its FAQ refers to supervisory proceedings "for the 0% companies"1. So the same group is probably meant all three times. The agency hasn't confirmed that, and "not a single device" goes further than the table, which only shows the quota for the mandatory group. By 30 June 2026, 41 companies were still at 0 percent11, not necessarily 41 of the 77. Arithmetically, 284 of the 434 proceedings were still open on 21 September; the agency itself doesn't state that difference.

Counterpoint: what a quota should count

Optional installation case is, under section 29(2) MsbG, any metering point outside the mandatory cases that the default metering point operator equips with an iMSys anyway. Under section 45(1) sentence 4, such installations reduce the number of mandatory cases the operator has to equip, as do early installations at a customer's request under section 34(2) sentence 2 no. 1126.

Until the fourth quarter of 2025 the agency published one quota per company, the one without optional installations. Only that quota showed the installation of the mandatory cases "clearly and transparently", it argued. Then the act of 18 December 2025 made clear that optional installations count towards compliance1.

Since then the table has had two columns. The supervisory proceedings use the quota with optional cases. Yet that quota "does not represent the actual state of installation in this group", the agency adds1. Some companies just get "n/a" in that column, for instance because the calculation would land above 100 percent or below zero.

How far do optional installations shift the quota? Our own analysis of the table as of 18 September 2026 gives a sober answer11. For 743 of the 803 companies both quotas appear as numbers. The median gap is 1.3 percentage points. 19 companies show a gap of 20 points or more, and 66 sit below 20 percent without optional installations and above it with them.

A lot of noise about a few outliers? Not quite. For those 66, the counting method decides whether they clear the 20 percent mark.

An iMSys in a household below the threshold is a full device. Its customer can sign up for an exchange-linked tariff with it, and the law credits it to the operator. That speaks for the new count. Against it: as a progress measure for the mandatory cases the quota loses precision, and the agency says as much itself. So give both values in reports, and name the column.

The barometer that never came back

"In the coming years, the progress barometer will express how the digitalisation of the energy transition has developed compared with the previous year or years." A promise, made in the edition for the reporting year 202013.

It was the last one. Published on 3 June 202114, indicators frozen on 31 January 2021, overall score 44 out of 100, up from 36 the year before and 22 in the 2018 base year13. EY had rated eight key factors for what was then the Federal Ministry for Economic Affairs, from certification status to the customer view. Some sub-scores now read like a trailer for chapter 5. Availability of the control unit: 25 points13.

Negative finding

No edition after reporting year 2020

No edition for 2021 or later could be found, neither at the ministry nor at the Clearingstelle EEG|KWKG. Nobody declared the series discontinued, either. For five years now there has been no annual progress measure that captures more than the installation rate.

The successor is the report under section 48 MsbG. From 30 June 2024 the ministry submits it at least every four years15; the first came out on 22 July 202416. No scoring system. And the next one isn't due until mid-2028: four years without an interim reading, while the next quotas fall due at the end of 2026 and the end of 2028.

Acceptance: what the evidence shows

The most recent survey commissioned by the ministry is more than five years old. For the barometer, Prolytics polled 1,000 households and 400 businesses in February and March 2021. 61 percent of households supported the rollout of modern metering devices, up from 52 percent in the survey before; among businesses, approval of smart meter installation rose from 52 to 64 percent. 43 percent of households felt poorly informed13.

Newer figures come from an industry association. Bitkom Research polled 1,002 households in April and May 2026: 69 percent said they use a smart meter or could imagine doing so, and 8 percent said they already have one. Among the households without one, 77 percent felt poorly informed17. Earlier waves polled the population rather than households, so the figures can't be compared.

Then there are the complaint statistics. In 2025 the Schlichtungsstelle Energie, the energy ombudsman, received 19,074 applications, 601 of them citing "modern metering devices", roughly 3.2 percent, with more than one reason possible per application18. iMSys aren't listed separately. For providers installing nationwide alongside the default operators, the ombudsman sees "in some cases still considerable processing and communication problems", right through to transmitting readings to the supplier18.

In the government's view, acceptance grows mainly with access to dynamic tariffs5. Figures to back that up? None in the same answer.

Negative finding

No statistics on objections or savings

There is no right to object to a mandatory installation. No central statistics are kept on complaints or objection letters received by local operators, and the agency's consumer service doesn't distinguish between enquiries and complaints5. How much households save with an iMSys is, according to the government, "not recorded statistically at a central level"5. And no survey could be found on how many customers actually use portals or apps to view their consumption.

Make or buy

For the 591 smallest default operators the question comes up early: what to do in-house, what to buy1. Responsibility stays put either way. The gateway administrator isn't a market role of its own; it's a function of the metering point operator19.

Building blockWhat the rules requireWhat sticks when you buy it in
Gateway administrationThe GWA meets BSI TR-03109-6 and proves its certification to the sub-CA20The FNN note describes no process for switching service provider; TR-03109-1 covers only the gateway side1921
CLS management as an active external market participantISO/IEC 27001 certification, or proof that a certified third party provides the service20A provider serving several clients must separate them technically or organisationally20
Metering at individual metering pointsThe connection user may choose a third party, but not until two years after the default operator installed an iMSys22Competitive operators have no quota and report voluntarily1
Default responsibilityTransfer or cooperation; in a cooperation the metering points of all areas count together6Transfers were one of the reasons for the 150 closed proceedings3

A more radical answer to that last row comes from outside. The Smart-Meter-Initiative was founded in January 2024 by three electricity suppliers that sell dynamic tariffs and need metering systems for them; a fourth joined in March 202423. It sees the fragmented structure of more than 800 metering point operators as the real obstacle and calls for consolidation2. For households outside the mandatory cases it promotes a simpler "smart meter light", meant to complement the mandatory rollout rather than replace it24. An interested party, then.

Chapters 3 and 5 cover the gateway administrator and the control box.

The gateway administrator change

How much hangs on a change shows in an October 2024 note from FNN, the VDE's forum for network technology and operation19. It covers the case where the metering point operator changes and the new one takes over the installed gateways. Figure 2 simplifies the sequence. The old administrator fetches the new one's certificate triple from the LDAP directory, loads its public keys into the gateway's security module and sets up the new administrator's connection profiles in a separate area called "gwapre". Only then does the gateway accept the switchGWA command2521. It connects to the new administrator, which acknowledges receipt, technically with an HTTP 200 according to the FNN note19. Under the technical guideline, though, the switch isn't complete until the new administrator has authenticated to the security module2521. With the HTTP 200, the note already hands over full control. Only the guideline is binding.

Gateway administrator change when the metering point operator changes and takes over the devices Simplified sequence in six lanes: new metering point operator (MSB), new gateway administrator (GWA), smart meter gateway, old gateway administrator, old metering point operator and the directory of the sub-CA in the smart metering PKI. Device takeover under WiM: 1 the new MSB requests a device takeover offer from the old one; 2 the old GWA supplies the technical device data to the old MSB; 3 the old MSB makes a takeover offer; 4 the new GWA supplies its configuration data including certificate details to the new MSB; 5 the new MSB orders the takeover with this configuration data; 6 the old MSB confirms with the remaining device data. Data handover and switch: 7 the new MSB passes the device data to its GWA; 8 the old MSB passes the new GWA's configuration data to its own GWA; 9 the old GWA fetches the new GWA's certificate triple from the sub-CA's LDAP directory, which it needs to configure the gateway; 10 it imports the new GWA's keys into the security module and sets up the new GWA's WAN communication profiles in the gwapre area; without this preparation the gateway rejects the switch command; 11 at the agreed time it triggers switchGWA on the gateway and then passes APN data if needed; 12 the gateway connects to the new GWA; 13 the new GWA acknowledges receipt, with an HTTP 200 according to the FNN note, and authenticates to the gateway's security module; only then is the switch complete and the fallback period to the old GWA over; 14 it reports success to its MSB. Completion under WiM: 15 the new MSB tells the old one when it took over metering point operation; 16 the old MSB informs its GWA that the change succeeded. New MSB takes over New GWA of new MSB SMGW in the field Old GWA of old MSB Old MSB hands over SM-PKI sub-CA, LDAP DEVICE TAKEOVER UNDER WIM DATA HANDOVER AND SWITCH ON THE GATEWAY COMPLETION UNDER WIM Request device takeover 1 Device data 2 Takeover offer 3 Configuration 4 Order incl. GWA configuration 5 Confirmation with remaining device data 6 Device data 7 New GWA data 8 Fetch new GWA certificate triple 9 gwapre profiles 10 switchGWA, APN 11 Connect 12 Authentication 13 Success notice 14 Takeover date 15 Success notice 16 Market process (WiM) Data MSB and GWA Command to gateway PKI and connection

Open figure full size

Figure 2: The gateway administrator change when the metering point operator changes and takes over the devices under WiM Strom, simplified from the VDE FNN note of October 2024. Related steps are sometimes merged into one arrow, and the SM-PKI lane is added. The preparation in the gwapre area (step 10) and authentication as the final step (step 13) follow TR-03109-1 and its annex VI. Like the source, the figure shows only the success case, not a change of the gateway administration service provider alone.

The preconditions are tough. Every configuration of an external market participant on the gateway has to be ended first. Authorised market partners then order their readings again, this time from the new operator19. LTE450? One provider. Without separate framework contracts between that provider and both operators, nothing works technically. Taking over SIM cards has no standard, and the note doesn't describe the error case at all. The gateway itself has a fallback: if the new administrator doesn't authenticate within the period set with the switch command, 24 hours by default, it aborts and carries on with the old administrator's keys25.

What about the APN, the access point into the mobile network? According to the note, the old administrator switches it only after the switch command, and only if one is used19. In the guideline, a change of access network is a separate process. Old and new access data both stay on the gateway so it can fall back21. Two fallback levels, in other words. If something fails, both switches have to be reversible, the note says19.

Revoking certificates isn't part of either sequence, the note's or the guideline's1921. All the smart metering PKI's certificate policy settles is who may revoke: until the new administrator has replaced the gateway's operational certificates with ones it requested itself, only the old one can revoke them20. For the exit contract, that means the old administrator stays involved until the certificates have been swapped.

As of October 2024 the change could not yet be handled fully automatically through market processes19. There is no newer version of the note as of October 2026. Since February 2025 the FNN project group on gateway administrator system integration has been tasked with establishing the change process end to end and extending it to downstream components26. Whether the market processes now carry it fully automatically couldn't be verified.

And the case that matters most for make or buy? Missing from the note. WiM doesn't provide for an operator that merely switches its gateway administration provider, and the note expressly leaves it out19. By contrast, the guideline describes the gateway side with or without a change of metering point operator. For a change of access network it advises testing the sequence and agreeing the handover of all necessary data by contract21. That clause belongs in the service contract.

Key point

If you buy in gateway administration or CLS management, settle the exit at the same time: handover of configuration data, certificate change, WAN contracts, time windows. The FNN note on the gateway administrator change doesn't cover a change of service provider.

What nobody measures

The agency's survey form asks about metering locations by consumption and capacity class, about optional installations and about control units4. What it leaves out tells you more.

Negative finding

Gaps in the official statistics

The form doesn't ask which tariff use cases the gateways have switched on, and the rollout page gives no figure for it41; chapter 4 explains the consequences. Mandatory cases with a control unit are recorded on the form, but the agency doesn't publish a separate number, and the government's answer of 11 September 2026 doesn't give one either5. How many quarter-hour values actually reach their recipients isn't asked, nor which WAN technology connects the gateways. A minor interpellation in the Bundestag explicitly asked about fault reports, replacement numbers and failure rates since 2023. The answer gives none of these figures5.

The agency demands that the devices record and transmit quarter-hour values reliably3. Whether they do, it doesn't publish.

So the statistics know whether a device hangs on the wall. Whether it sends values, and whether it controls anything, each operator knows only for itself.

What comes next

Start with the targets. They're moving.

Forecast

Announced, not yet law

On 2 July 2026 the coalition committee decided to tighten the targets: "By the end of 2030 the rollout is to be more than 90 percent complete for all relevant metering points." Customers outside the mandatory rollout are to get a low-cost "smart meter light"27. The economics ministry has announced the amendment of the Metering Point Operation Act for the fourth quarter of 202628. No draft could be found by mid-October.

Brussels adds a second yardstick, so far only as a draft. Under the Commission's proposal for a regulation of 17 July 2026, at least 50 percent of all final customers are to have a smart metering system by the end of 2030 and 75 percent by the end of 2033. A member state below 30 percent when the regulation enters into force gets one more year for each target29. That would count all final customers, not the mandatory cases. Of all figures, the total quota would become the yardstick, the one that at home only serves transparency1 and stood at 5.9 percent of metering locations in mid-2026. Final customers and metering locations aren't the same thing, though. The Bundesrat's committees recommend rejecting the draft's plan to drop the cost-benefit analysis up to the 75 percent mark30.

Beyond that, three building sites reach past the mandatory electricity rollout.

Gas first. Since 1 July 2026 customers can demand early equipment at gas metering points as well, to be carried out within four months31. And a connection owner may pick a different metering point operator for an entire property if that operator bundles electricity with gas, water, district heating or space heating via the gateway at no extra cost32. Chapter 2 explains how multi-utility metering is connected technically.

In submetering a deadline is running out. Heat meters and heat cost allocators that can't be read remotely must be retrofitted or replaced by 31 December 2026. Since 1 December 2022 only devices that can be connected securely to a smart meter gateway may be installed. Under the Heating Costs Ordinance, though, they only have to be connected if the owner has chosen the bundled offer for space heating33. Connectable doesn't mean connected.

Charging infrastructure has a clear mandatory case: a charge point with a §14a agreement makes the metering point a mandatory case for an iMSys with a control unit12. What's open is the separation of energy flows. How electricity from storage and bidirectional charge points is determined and proven is set out in the agency's MiSpeL determination of 1 October 2026. Until 30 September 2027 it only applies if the grid operator and the metering point operator agree34.

Much of this chapter ends up among the open questions and negative findings the book collects at the end. For your own planning, four steps will do:

  1. Pull both quotas from the agency's table

    Note your company's quota with and without optional installations, each with its reference date and table version. The agency may still change reported values after checking them11.

  2. Recalculate the period quota yourself

    Count the metering locations that have needed equipping since 25 February 2025, using the survey form's definition. §14a cases only count with an integrated control unit that's ready for operation.

  3. Check the exit clause in your service contract

    Does your contract with your GWA or CLS provider say how configuration and certificates are handed over if you switch, and who takes on the WAN contracts?

  4. Close your own gaps

    TAF configuration, control boxes in operation, the share of quarter-hour values received: record them yourself. The official statistics deliver none of these figures.

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. Federal Network Agency: iMSys rollout, results of the first half-yearly survey 2026 with FAQ, page as of 21 September 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  2. energiezukunft: Current figures on the smart meter rollout, 7 April 2026, with the Federal Network Agency's figures for 31 December 2025 as published at the time and the position of the Smart-Meter-Initiative (German). energiezukunft.eu, retrieved 14 October 2026. Trade press.
  3. Federal Network Agency: press release "Bundesnetzagentur veröffentlicht halbjährliche Erhebung im Messwesen" (half-yearly metering survey published), 21 September 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  4. Federal Network Agency: metering survey form for the first half of 2026, sheets for default operators and notes (German). bundesnetzagentur.de, retrieved 14 October 2026.
  5. German Bundestag: answer of the federal government to a minor interpellation on coercive measures in the smart meter rollout, printed paper 21/7996 of 11 September 2026, answers to questions 1 to 7, 14, 15 to 21 and 30 to 41 (German). dserver.bundestag.de, retrieved 14 October 2026.
  6. Section 45 Metering Point Operation Act (MsbG), equipment obligations, paragraph 1 sentence 1 nos. 2 and 4, sentences 3 and 4, and paragraph 4 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  7. Federal Network Agency: Federal Network Agency opens proceedings over failures in the smart meter rollout, press release of 27 March 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026.
  8. Section 76 MsbG, supervisory measures of the Federal Network Agency, paragraphs 1, 2 and 4 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  9. Section 94 Energy Industry Act (EnWG), coercive fine, sentence 3 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  10. 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.
  11. Federal Network Agency: rollout quotas iMSys H1 2026, table per default metering point operator, as of 18 September 2026 (German). bundesnetzagentur.de, retrieved 14 October 2026. The median, the threshold counts and the count of zero quotas are our own analysis of the reported values.
  12. Section 29 MsbG, equipment of metering points, paragraph 1 no. 2 and paragraph 2 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  13. EY for the Federal Ministry for Economic Affairs and Energy: Barometer Digitalisierung der Energiewende, reporting year 2020, pp. 5, 9, 16 to 18 and 79 (German). bundeswirtschaftsministerium.de, retrieved 14 October 2026.
  14. 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.
  15. Section 48 MsbG, reports of the Federal Ministry for Economic Affairs and Energy, paragraph 1 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  16. Clearingstelle EEG|KWKG: analyses and reports of the Federal Ministry for Economic Affairs and Climate Action under section 48 MsbG in 2024 (digitalisation report), dated 22 July 2024 (German). clearingstelle-eeg-kwkg.de, retrieved 14 October 2026.
  17. Bitkom: Die Digitalisierung der Energiewende (digitalising the energy transition), presentation of 30 June 2026, slides 9, 10 and 15 (Bitkom Research, telephone survey of 1,002 households, calendar weeks 16 to 20 of 2026) (German). bitkom.org, retrieved 14 October 2026. Association survey.
  18. Schlichtungsstelle Energie: activity report 2025, p. 6 and pp. 11 f. (German). schlichtungsstelle-energie.de, retrieved 14 October 2026.
  19. VDE FNN: process description of a gateway administrator change when the metering point operator changes with device takeover under WiM Strom, note version 1.0, October 2024, chapters 1 to 4 (German). vde.com, retrieved 14 October 2026.
  20. Federal Office for Information Security (BSI): certificate policy of the smart metering PKI, version 1.1.2 of 25 January 2023, sections 1.3.3.4, 3.5.1.1, 5.1.1 and 5.1.2 (German). bsi.bund.de, retrieved 14 October 2026.
  21. BSI: TR-03109-1, annex VI: operating processes involving the smart meter gateway, version 2.0 of 13 December 2024, section 3.11.2 (gateway administrator change with or without a change of metering point operator, preconditions and table 3.43) and section 3.11.3 (change of WAN access network) (German). bsi.bund.de, retrieved 14 October 2026.
  22. Section 5 MsbG, right of choice of the connection user, paragraph 1 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  23. Ostrom: Ostrom becomes a partner of the Smart-Meter-Initiative, statement of 7 March 2024 (German). ostrom.de, retrieved 14 October 2026. Company statement by a member.
  24. Smart-Meter-Initiative: concept paper Smart Meter Light, technical and regulatory options for a low-cost and cyber-secure rollout path outside the mandatory installation cases, July 2026, summary p. 3 (German). a.storyblok.com, retrieved 14 October 2026. Position of an interested party.
  25. BSI: TR-03109-1, version 2.0 of 13 December 2024, section 3.18 (gateway administrator change, FA.DoSwitchGwa with REQ.FA.DoSwitchGwa.10, and FA.AcceptSwitchGwa) and section 3.22.19 (switch parameters, default 86,400 seconds) (German). bsi.bund.de, retrieved 14 October 2026.
  26. VDE FNN: call for experts, project group on GWA system integration, 25 February 2025; the list of FNN notes still shows the process description of the GWA change as version 1.0 of October 2024 (German). vde.com, retrieved 14 October 2026.
  27. 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.
  28. Zeitung für kommunale Wirtschaft: Verteilnetzpaket und Smart Meter: Worauf es jetzt ankommt (distribution grid package and smart meters, what matters now), column of 3 August 2026 (German). zfk.de, retrieved 14 October 2026. Trade press.
  29. 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.
  30. Bundesrat: recommendations of the committees on COM(2026) 600, printed paper 501/1/26 of 5 October 2026, p. 3, for the plenary session of 16 October 2026 (German). dserver.bundestag.de, retrieved 14 October 2026.
  31. Section 34 MsbG, paragraph 2 sentence 2 no. 1, early equipment as an additional service (German). gesetze-im-internet.de, retrieved 14 October 2026.
  32. Section 6 MsbG, right of choice of the connection owner, paragraph 1 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  33. Section 5 Heating Costs Ordinance (HeizkostenV), equipment for recording consumption, paragraphs 2, 3 and 6 (German). gesetze-im-internet.de, retrieved 14 October 2026.
  34. Federal Network Agency: determination on the market integration of storage and charge points (MiSpeL), ref. 618-25-02 of 1 October 2026, operative provision 9 a) (German). bundesnetzagentur.de, 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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