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Deadline calendar: German energy transition

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Deadlines

Upcoming deadlines

68 upcoming deadlinesSubscribe to the calendaror download the file (ICS)

A classification for typical market roles, not a review of your individual case and not legal advice. Whether an obligation applies to your company (thresholds, exemptions) is for your legal department or counsel to confirm. The calendar doesn't replace your own deadline review.

What the labels mean

Each deadline shows what kind of date it is (applies from, due by, comments by, decision) and how binding it is. Without a label in the row, the date is adopted: the law, ruling or technical rule is final, and the details name its basis. "Not yet adopted" is a draft, and its date can still move. Consultations and targets oblige no one. A filled dot marks an adopted date, a ring an open or non-binding one. The "Level" filter refers to the selected market role; without a role it shows every deadline where any role has that level.

Q4 2026

19 deadlines
Due by25 October 2026

2027 levies: publication by the transmission system operators

Power gridTSOSupplier

The transmission system operators publish the 2027 CHP levy and offshore grid levy by 25 October. Suppliers and grid operators carry the values into price sheets and grid fee billing.

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency monitors publication under Section 62(1) no. 1(a) EnFG and can order it using its EnWG powers. Breaching an enforceable order is an administrative offence under Section 63(1) no. 2 EnFG, with fines of up to EUR 200,000. Legal basis ↗

Applicability: Transmission system operators; indirectly all electricity suppliers and electricity DSOs.

  • Electricity grid operatoraffectedElectricity DSOs apply the levies as a surcharge on grid withdrawal in their 2027 price sheets.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Transmission system operatorrole obligationTransmission system operators publish the 2027 levies on time on their joint website.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedSuppliers carry the levies into 2027 pricing and price change letters.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities
Comments by26 October 2026

Electricity efficiency benchmarking: data collection consultation closes

Consultation · openPower grid

Ruling Chamber 8 is consulting on which data electricity DSOs must supply for the efficiency benchmarking of the fifth regulatory period. Comments are due by 26 October 2026; the data collection follows afterwards.

If the deadline is missed: No direct legal consequence Commenting is voluntary. Operators that do not comment by 26 October 2026 do not bring their objections into this procedure; which data must be supplied only becomes binding with the final decision. Legal basis ↗

Applicability: Electricity DSOs in the standard incentive regulation procedure; the simplified procedure may differ.

  • Electricity grid operatoraffectedCan comment on the data catalogue until 26 October and checks which systems the data come from.Typically affected: Regulatory management, controlling, Grid planning, GIS, load flow, SAP IS-U / S/4HANA Utilities

Linked to: NEST: fifth regulatory period, electricity

Part of the bundle: Grid regulation and planning

Due by31 October 2026

Grid expansion plan under section 14d EnWG: first filing

Power grid

Distribution system operators with 100,000 or more customers submit their first grid expansion plan to the Federal Network Agency, then every two years by 31 October. Smaller operators are covered only if they curtailed more than 3 percent of wind or solar output in each of the two previous years.

Law · adopted

If the deadline is missed: Regulator can enforce Section 14d EnWG sets no penalty of its own. The regulator can order the filing under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG; breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

Applicability: Only for distribution system operators with 100,000 or more customers. Smaller operators only if more than 3 percent of possible wind or solar output was curtailed in each of the two previous years.

  • Electricity grid operatorcheck applicabilityChecks customer count and curtailment share; if covered, submits the plan with congestion analysis and measures to the BNetzA.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling

Part of the bundle: Grid regulation and planning

Due by31 October 2026

Congestion income 2027: report the planned use to the Federal Network Agency

TSO

Transmission system operators tell the Federal Network Agency by 31 October how they plan to use the 2027 congestion income from allocating cross-zonal capacity. The basis is Article 4 of the ACER methodology on the use of congestion income under Article 19 of Regulation (EU) 2019/943.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ACER methodology sets no sanction of its own. The Federal Network Agency decides on the use by 31 December and can require changes; it can enforce the reporting duty under Section 56(1) sentence 2 and Section 94 EnWG with coercive fines of EUR 1,000 to EUR 10 million. Legal basis ↗

Applicability: Only transmission system operators that earn congestion income from allocating cross-zonal transmission capacity.

  • Transmission system operatorrole obligationSubmits the planned use of the 2027 congestion income to the Federal Network Agency by 31 October.Typically affected: Regulatory management, controlling
Due by1 November 2026

EEG onshore wind tender: bid deadline 1 November 2026

Direct marketingGeneration

Bids for onshore wind turbines must reach the Federal Network Agency by the bid deadline. According to the agency, the volume is about 2,495 MW and the 2026 ceiling price is 7.25 cents per kilowatt hour.

Law · adopted

If the deadline is missed: Exclusion or loss of role Bids must reach the Federal Network Agency by the bid date (Section 30a(2) EEG); only bids received in time are opened (Section 32(1) sentence 2 EEG), so a late bid gets no award in this round. A bid is also excluded if the fee or security has not been paid in full by then (Section 33(1) no. 3 EEG). Legal basis ↗

Applicability: Developers and operators of onshore wind turbines holding a federal immission control permit.

  • Direct marketercheck applicabilityDirect marketers prepare marketing offers for awarded projects.Typically affected: Direct marketing and remote control
  • Plant operator (generation)check applicabilityPlant operators with permitted wind projects assess participation, bid value and security deposit.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by20 November 2026

Price change on 1 January 2027: notice deadline in default supply

Supplier

Default suppliers changing their general prices on 1 January 2027 must publish the change at least six weeks in advance, notify customers by letter and post it online. For household customers on special contracts, Section 41(5) EnWG sets a one month notice period.

Law · adopted

If the deadline is missed: Civil-law consequence Under Section 5(2) StromGVV and GasGVV a change to general prices only takes effect after public notice at least six weeks in advance; with later notice the new price does not apply from 1 January 2027. For household customers on special contracts Section 41(5) EnWG requires one month's notice but states no express consequence. Legal basis ↗

Applicability: Default suppliers of electricity and gas changing prices on 1 January 2027; special contract suppliers with household customers (one month notice).

  • Supplierrole obligationDefault suppliers finish 2027 pricing early enough that publication, customer letters and online notice go out by 20 November 2026 at the latest.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities, Customer and grid connection portal

Linked to: 2027 levies: publication by the transmission system operators, 2027 network charges: publication by 15 October

Due by30 November 2026

Redispatch 2.0: choice of settlement method for 2027

Power gridBalancingDirect marketingGeneration

Under ruling BK6-23-241, the plant operator sets the settlement method for each technical resource by 30 November for the following year. Without a decision the simplified peak settlement applies; the flat-rate settlement ends for existing resources at the end of 2028.

Regulatory ruling · adopted

If the deadline is missed: No direct legal consequence Without an assignment decision by 30 November, the simplified peak settlement applies to resources with fluctuating generation (BilAReM chapter 3.2.1); resources already on flat-rate settlement stay there until 31 December 2028 at the latest. The assignment holds for the whole following year. Legal basis ↗

Applicability: Operators of plants from 100 kW and controllable plants within Redispatch 2.0.

  • Electricity grid operatoraffectedElectricity DSOs take the assignment into the calculation of curtailed energy.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
  • Balance responsible partyaffectedBalance responsible parties check how the chosen method affects imbalance costs.Typically affected: Trading and procurement system (ETRM)
  • Direct marketeraffectedDirect marketers agree with plant operators which method best reflects the balancing compensation in the balance group.Typically affected: Direct marketing and remote control
  • Plant operator (generation)affectedPlant operators decide per technical resource between peak, simplified peak or flat-rate settlement and report the choice to the connecting grid operator.Typically affected: Plant master data and MaStR, Market communication gateway (EDIFACT, AS4, API)
Due by30 November 2026

Controllability: TSOs' overall report under Section 12(2c) EnWG

Power gridTSOMetering

The transmission system operators submit the overall report on network operators' controllability tests and on the equipment status reported by default metering operators to the Federal Network Agency and the Federal Ministry for Economic Affairs by 30 November. Under the TSOs' guidelines the checked results must reach them by 31 October; tests and reports run until 30 September.

Law · adopted

If the deadline is missed: Exclusion or loss of role If a default metering operator fails its check or contribution duty and it therefore cannot be established whether the deployment quota is missed by at least 25 percent, the Federal Network Agency can withdraw its default responsibility under Section 12(2g) no. 2 EnWG. It can order network operators to comply under Section 65 EnWG. Legal basis ↗

Applicability: TSOs with control area responsibility prepare the report; electricity DSOs and default metering operators contribute. Process and data format are set by the TSOs' guidelines under Section 12(2d) EnWG.

  • Electricity grid operatorrole obligationContributes to the overall report: reports controllability test results by 30 September and, as an upstream operator, checks downstream data by 31 October.Typically affected: Grid control system / SCADA, Regulatory management, controlling
  • Transmission system operatorrole obligationPrepares the overall report jointly with the other TSOs and submits it to the Federal Network Agency and the ministry by 30 November.Typically affected: Regulatory management, controlling, Grid control system / SCADA
  • Default metering point operatorrole obligationChecks the status of smart metering system and control unit deployment every year and passes it to the network operator for the overall report.Typically affected: Gateway administration and CLS management

Linked to: Smart meter rollout: 90 percent of the installation cases since February 2025

Due by1 December 2026

EEG ground-mounted solar tender: bid deadline 1 December 2026

Direct marketingGeneration

Bids for ground-mounted solar plants (first segment) must reach the Federal Network Agency by the bid deadline. According to the agency, the actual volume is about 2,079 MW.

Law · adopted

If the deadline is missed: Exclusion or loss of role Bids must reach the Federal Network Agency by the bid date (Section 30a(2) EEG); only bids received in time are opened (Section 32(1) sentence 2 EEG), so a late bid gets no award in this round. A bid is also excluded if the fee or security has not been paid in full by then (Section 33(1) no. 3 EEG). Legal basis ↗

Applicability: Developers and operators of ground-mounted solar plants above 1 MW.

  • Direct marketercheck applicabilityDirect marketers prepare marketing and profile valuation for awarded solar parks.Typically affected: Direct marketing and remote control, Trading and procurement system (ETRM)
  • Plant operator (generation)check applicabilityPlant operators with sites and a grid connection commitment assess participation and bid value.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Applies from2 December 2026

EU AI Act: labelling duty extends to AI already in use

Company-wide

The four-month transition period ends. Generative AI systems placed on the market before 2 August 2026 must mark their output in machine-readable form.

Law · adopted

If the deadline is missed: Fine possible If a provider of generative AI placed on the market before 2 August 2026 does not mark its output in machine-readable form by 2 December 2026 (Art. 50(2) and Art. 111(4) AI Act), the breach can be fined under Art. 99(4)(g) up to EUR 15 million or 3% of worldwide turnover, with the lower amount for SMEs and small mid-caps (Art. 99(6) and (6a)). The same range applies to deployers for disclosing deepfakes (Art. 50(4)). Legal basis ↗

Applicability: Art. 50(2) of the AI Act addresses providers of generative AI systems. Companies that only use bought-in systems are deployers and mainly face disclosure duties under Art. 50(4).

  • Company-wide, several rolescheck applicabilityDetermines for each generative AI system whether the company acts as provider and, if so, marks outputs in machine-readable form.Typically affected: AI systems and chatbots, Customer and grid connection portal

Linked to: EU AI Act: transparency duties under Art. 50

Due by29 December 2026

Power plant strategy (StromVKG): second auction for long-duration capacity

Generation

On 29 December 2026 the Federal Network Agency auctions another 4.5 gigawatts of long-duration capacity. Eligible are generation plants able to feed in 80 percent of their capacity for at least ten consecutive hours, with a 15-year commitment.

Law · adopted

If the deadline is missed: Exclusion or loss of role A bid must reach the Federal Network Agency by the bid date, with no reinstatement (Section 37(1) StromVKG). Bids without the fee or security paid by then are excluded under Section 49(1) no. 1 StromVKG. Legal basis ↗

Applicability: Only generation plants at sites without generation on 30 June 2026 or covered by the exceptions in section 12(3) StromVKG.

  • Plant operator (generation)check applicabilityPlant operators assess whether a new build or site meets the conditions and a bid is worthwhile.Typically affected: Plant master data and MaStR, Regulatory management, controlling
DecisionEnd of 2026

AgNes: framework ruling on electricity grid charges

Regulatory ruling · expectedPower gridSupplier

Under the draft of 6 August 2026, low-voltage connections up to 100,000 kWh keep a standing charge and an energy charge; those generating behind the connection pay a prosumer surcharge of 70 to 90 percent of the standing charge, plug-in solar devices excepted. Above that, and above low voltage, a capacity price applies, and generation plants above 30 kW pay a feed-in charge. The draft provides dynamic grid charges only for storage (2030 at the earliest, 2033 at the latest) and generation (2032 to 2035), not for final customers for now. Follow-up rulings in 2027, effect from 2029.

If the deadline is missed: No direct legal consequence The date is the Federal Network Agency's. Its notification, set for 1 January 2027 in the draft (operative point 20), starts other cut-offs, such as grandfathering for storage and generation plants with an investment decision before notification, to be proven to the network operator by 31 March 2027. Legal basis ↗

  • Electricity grid operatoraffectedPlans billing and tariff systems for the prosumer surcharge, capacity prices and feed-in charges from 2029; under the draft, prosumers are to be identified and reported to suppliers by 1 April 2028.Typically affected: Grid usage and customer billing, Regulatory management, controlling, SAP IS-U / S/4HANA Utilities
  • SupplieraffectedPrepares products and billing to pass new network charge components on to customers; under the draft, prosumer status appears on the bill from 1 April 2028.Typically affected: Grid usage and customer billing

Linked to: AgNes: consultation on the grid charge reform closes, MiSpeL: ruling on market integration of storage and charging points

Part of the bundle: Grid regulation and planning

Due by31 December 2026

Heating costs ordinance: retrofit remote reading

Heat networkCompany-wide

Heat suppliers retrofit or replace meters installed before 5 October 2021 that cannot be read remotely (FFVAV). Building owners do the same for heat and hot water meters and heat cost allocators (Heating Costs Ordinance).

Law · adopted

If the deadline is missed: Money is lost Where remotely readable equipment is missing contrary to Section 5(3) HeizkostenV, occupants may cut their share of the costs by 3 percent under Section 12(1) sentence 2 HeizkostenV. The FFVAV sets no penalty of its own for heat suppliers; their retrofit duty applies within the supply contract with the customer (Section 1(1) and Section 3(3) FFVAV). Legal basis ↗

Applicability: The FFVAV applies to heat suppliers, the Heating Costs Ordinance to building owners. Metering operators under the MsbG are not addressed.

  • Heat network operatorrole obligationRetrofits or replaces heat meters installed before 5 October 2021 that cannot be read remotely, by year end.Typically affected: Field service and work orders, EDM / MDM
  • Company-wide, several rolescheck applicabilityChecks for its own buildings and contracting models who carries the retrofit under the Heating Costs Ordinance as building owner.Typically affected: Field service and work orders

Part of the bundle: Metering at year end

Due by31 December 2026

Smart meter rollout: 90 percent of the installation cases since February 2025

Metering

By the end of 2026 default metering point operators must have completed at least 90 percent of the metering points that have fallen due since 25 February 2025. According to its press release, the Bundesnetzagentur collects progress twice a year, and it has been running supervisory proceedings against laggards since March 2026.

Law · adopted

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). If the rollout of control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

  • Default metering point operatorrole obligationFits at least 90 percent of metering points due since 25 February 2025 with smart metering systems by year end.Typically affected: Gateway administration and CLS management, Field service and work orders, SAP IS-U / S/4HANA Utilities

Part of the bundle: Metering at year end

Due by31 December 2026

WPG § 32: decarbonisation roadmap for heat networks

Heat network

Operators of existing heat networks submit the roadmap: 30 percent renewable by 2030, 80 percent by 2040.

Law · adopted

If the deadline is missed: Regulator can enforce The Heat Planning Act sets neither a fine nor a specific power to issue orders for a missing or late roadmap. Compliance is monitored by the authority each federal state designates under Section 33(5) WPG. Legal basis ↗

Applicability: Heat networks already fed entirely by renewable heat, unavoidable waste heat or a combination of both are outside the duty, as are networks under 1 km and networks with an approved BEW transformation plan. The pending WPG amendment would give only operators of industrial heat networks until the end of 2030.

  • Heat network operatorrole obligationDraws up the expansion and decarbonisation roadmap for each heat network and submits it to the competent authority.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
Due by31 December 2026

Smart meter rollout: 90 percent of new generation capacity up to 100 kilowatts

Power gridMetering

By the end of 2026 default metering point operators must have equipped at least 90 percent of the generation capacity up to 100 kilowatts that came online between 25 February 2025 and 30 September 2026. The yardstick is installed capacity, not the number of metering points.

Law · adopted

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). If the equipping of installations with control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

Applicability: Under the government draft for EEG 2027, the installation quotas in Section 45 MsbG would count metering points to be equipped instead of kilowatts, with the default metering point operator free to choose for this quota at 31 December 2026. Nothing has been adopted.

  • Electricity grid operatoraffectedSupplies plant master data from grid connection and the market master data register so the metering operator knows the cases.Typically affected: SAP IS-U / S/4HANA Utilities
  • Default metering point operatorrole obligationEquips generation up to 100 kW so that 90 percent of capacity commissioned from February 2025 to September 2026 is covered.Typically affected: Gateway administration and CLS management, Field service and work orders

Part of the bundle: Metering at year end

DecisionEnd of 2026

Gas WACC: the rate of return decision is issued

Regulatory ruling · expectedGas grid

The Bundesnetzagentur intends to set the flat-rate return on capital for gas grid operators by the end of 2026. Gas distribution operators then calculate the revenue caps of the fifth regulatory period from 2028 with the adopted rate.

If the deadline is missed: No direct legal consequence Issuing the decision by the end of 2026 is the Federal Network Agency's own target. The ruling fixes the rate for gas revenue caps from 2028; it can only be challenged by an appeal within one month of service (Section 78(1) EnWG). Legal basis ↗

  • Gas grid operatoraffectedCalculates revenue caps for the fifth gas regulatory period from 2028 with the rate that is set.Typically affected: Regulatory management, controlling

Linked to: Gas WACC: end of the consultation on the rate of return

Part of the bundle: Grid regulation and planning

Due by31 December 2026

CHP Act: cut-off for commercial operation or permit of CHP plants, heat networks and heat storage

GenerationHeat network

CHP Act support requires that CHP plants start commercial operation by 31 December 2026, or hold a federal immission control permit or binding order by then and start commercial operation within four years. Support for heat networks and heat storage is also tied to 31 December 2026 (commissioning or all permits under state law in place).

Law · adopted

If the deadline is missed: Money is lost The CHP premium under Section 6(1) sentence 1 no. 1 KWKG is only paid if the plant enters commercial operation by 31 December 2026, or holds an immission control permit or binding order by then and starts commercial operation within four years; awards from CHP tenders are exempt. Similar cut-offs apply to new heat networks and heat storage (Section 18(1) no. 1 and Section 22(1) no. 1 KWKG). Legal basis ↗

Applicability: New, modernised or retrofitted CHP plants and new or extended heat networks and heat storage seeking CHP Act support.

  • Plant operator (generation)affectedPlant operators secure commercial operation, permit or binding order for CHP projects by year end.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Heat network operatoraffectedHeat network operators check whether network and storage projects go live or hold all permits by year end.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by31 December 2026

Regulatory account: application for 2025

Power gridTSO

Electricity network operators apply for the 2025 regulatory account balance with the regulator by 31 December 2026.

Law · adopted

If the deadline is missed: Regulator can enforce The ARegV sets no penalty of its own, but the application is mandatory under Section 4(4) sentence 3 ARegV; the regulator can order it under Section 65(2) EnWG and enforce it with coercive fines. Under Section 5(3) sentence 3 ARegV the balance is only spread from the second year after the application. Legal basis ↗

Applicability: Operators in the standard procedure; different rules may apply in the simplified procedure or under state regulators.

  • Electricity grid operatorrole obligationFiles the 2025 regulatory account application with the competent regulator.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Transmission system operatorrole obligationFiles the 2025 regulatory account application with the Federal Network Agency.Typically affected: Regulatory management, controlling

Part of the bundle: Grid regulation and planning

Q1 2027

10 deadlines
Applies from1 January 2027

AFIR: ISO 15118-20 for new charging points

Charge points

From 2027, newly built or renovated publicly accessible charging points and private charging points in modes 3 and 4 must support at least ISO 15118-20. Bidirectional charging and Plug and Charge stay optional; anyone offering Plug and Charge needs both ISO 15118-2 and ISO 15118-20.

Law · adopted

If the deadline is missed: Regulator can enforce For publicly accessible charging points, the Federal Network Agency can require retrofitting and prohibit operation under Section 5(2) and (3) of the Charging Station Ordinance if Annex II to AFIR (Regulation (EU) 2023/1804) is not met. ISO 15118-20 sits in that annex since Delegated Regulation (EU) 2025/656. Legal basis ↗

Applicability: Applies to newly built or renovated charging points; existing ones are exempt. Private charging points only in modes 3 and 4.

  • Charge point operatorrole obligationFrom 2027 procures only charging points with ISO 15118-20 and upgrades backend and PKI if Plug and Charge is offered.Typically affected: Charging backend (OCPP, PKI)
Applies from1 January 2027

Grid package: system-serving connection capacity instead of maximum output

Law · not yet adoptedPower gridTSO

The right to a grid connection no longer covers the maximum generation output: for plants connected from 1 January 2027, the draft caps feed-in from new first-segment solar plants at 70 percent of installed capacity and from onshore wind at 280 watts per square metre of rotor area (Section 8 of the draft EEG). By then the transmission system operators submit procedure rules with prioritisation criteria to the Federal Network Agency, and distribution system operators may adopt them. Grid operators show available capacity on grid maps every month; the electronic enquiry procedure from 135 kilowatts only arrives in 2028 under the draft.

If the deadline is missed: Regulator can enforce Under the government bill (Bundestag printed paper 21/7866) the new duties carry no fine of their own. Duties such as the transmission system operators' submission of procedure rules or the monthly capacity map (Sections 17a and 17c of the draft EnWG) could be enforced by the regulator under Section 65 EnWG. Legal basis ↗

  • Electricity grid operatorcheck applicabilityMay adopt the transmission operators' prioritisation principles for connection requests and publishes available connection capacity on a map; the bill may still change in parliament.Typically affected: Customer and grid connection portal, Grid planning, GIS, load flow
  • Transmission system operatorcheck applicabilitySubmits joint procedure rules with prioritisation criteria for transmission grid connections to the Federal Network Agency by 1 January 2027; the bill may still change.Typically affected: Customer and grid connection portal

Part of the bundle: Grid regulation and planning

Applies from1 January 2027

EEG 2027 (government draft): no fixed tariff for new PV below 25 kW

Law · not yet adoptedPower gridMeteringSupplier

Under the government draft, subject to the Bundestag's decision and EU state aid approval: new PV systems below 25 kW receive a temporary transition payment from the grid operator for at most 36 months instead of the feed-in tariff, then direct marketing with a 1.5 ct/kWh bonus for up to 48 months. Rooftop systems below 100 kW cap feed-in at 50 percent permanently. Systems commissioned by 31 December 2026 stay under the old rules. In the MsbG, mandatory smart meters and control devices for generation start above 2 kW, and the installation quotas in Section 45 count metering points instead of kilowatts. The Bundesrat wants to drop the 2 kW threshold; the federal government rejects that.

If the deadline is missed: No direct legal consequence Under the draft (Bundestag printed paper 21/7867), payment obligations for breaches under Section 52 EEG fall on plant operators; it sets no separate sanction for network operators, metering point operators or suppliers. According to the explanatory memorandum, network operators need software to administer the temporary transition payment. Legal basis ↗

Applicability: Under the draft this only affects new systems commissioned from 1 January 2027. Existing systems stay under the old rules; plug-in solar devices up to 2 kW are exempt.

  • Electricity grid operatorcheck applicabilityPrepares EEG settlement for grid operator offtake, transition payment and bonus and checks the 50 percent cap at commissioning; the bill may still change in parliament.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities, Market communication gateway (EDIFACT, AS4, API)
  • Default metering point operatorcheck applicabilityPlans the 2 to 7 kW segment into the mandatory rollout with control devices, plus early installations for direct marketing; status government draft.Typically affected: Gateway administration and CLS management, Field service and work orders
  • Suppliercheck applicabilityConsiders offering direct marketing for small systems in its own area; status government draft.Typically affected: Market communication gateway (EDIFACT, AS4, API), Grid usage and customer billing
Applies from1 January 2027

BSI TR-03109-6 v2.0 for gateway administrators

Metering

Gateway administrators have their GWA system assessed against version 2.0 at the next certification or recertification from 1 January 2027. Version 2.0 covers remote workplaces, cloud service providers, zero trust, time servers and penetration tests, among other things. Version 1.0 stays valid until 31 December 2028.

Regulatory ruling · adopted

If the deadline is missed: Exclusion or loss of role Conformity with TR-03109-6 is proven by certification. If the default metering point operator lacks the certificates required under Section 25 MsbG, the fallback metering operator takes over in emergency operation (Section 11(2) no. 2 MsbG) and, six months later, the default responsibility (Section 11(4) MsbG). Legal basis ↗

Applicability: Applies to metering operators that run gateway administration themselves; otherwise the contracted service provider is affected. Version 1.0 stays valid until the end of 2028.

  • Default metering point operatorrole obligationMoves gateway administration to version 2.0 at its next certification or recertification from 2027.Typically affected: Gateway administration and CLS management, ISMS and security operations

Part of the bundle: Metering at year end

Applies from1 January 2027

BSI TR-03109-1 v2.0: gateway certificates only with MUSS+

MeteringCompetitive metering

Anyone certifying a smart meter gateway against version 2.0 of the protection profile and TR-03109-1 must also prove the MUSS+ requirements from 1 January 2027. According to the BSI these include a WAN API, registering power metering over the local metrological network and factory reset by the service technician, plus TAF 8 in its new form and TAF 15. By mid-October 2026 no gateway had been certified under version 2.0.

Regulatory ruling · adopted

If the deadline is missed: Exclusion or loss of role Without MUSS+ proof there is no version 2.0 certificate from that date. Without a valid certificate, a smart meter gateway may not be used as part of a smart metering system under Section 24(4) MsbG, and under Section 25(1) MsbG the gateway administrator may only use gateways with valid certificates. Legal basis ↗

Applicability: Addressed to manufacturers that have gateways certified. Metering point operators are affected through procurement and rollout of new devices.

  • Default metering point operatoraffectedAsks gateway vendors when devices certified under version 2.0 with MUSS+ will be available and plans procurement and rollout for 2027 and 2028 around those dates.Typically affected: Gateway administration and CLS management, Field service and work orders
  • Competitive metering point operatoraffectedAsks gateway vendors when version 2.0 devices can be delivered and plans procurement accordingly.Typically affected: Gateway administration and CLS management, Field service and work orders

Part of the bundle: Metering at year end

Due by1 January 2027

Fallback metering operator: publication for 2027

Metering

At the start of the calendar year the Bundesnetzagentur publishes the name, address and website of the fallback metering operator responsible for each federal state, together with the operators that declared readiness. The basis is the monitoring data under section 35 EnWG.

Law · adopted

If the deadline is missed: No direct legal consequence Publication under Section 11(3) sentence 2 MsbG is a duty of the Federal Network Agency. It shows who takes over emergency operation if a default metering point operator drops out, loses its certificates or lacks approval (Section 11(2) MsbG). Legal basis ↗

Applicability: The duty to publish lies with the Federal Network Agency. For municipal utilities the entry is information, not a deadline of their own.

  • Default metering point operatoraffectedChecks the Federal Network Agency's list when handing over metering points or after declaring readiness as fallback operator.Typically affected: Regulatory management, controlling

Part of the bundle: Metering at year end

Applies from1 January 2027

AFIR: card payment at existing fast chargers from 50 kW

Charge points

From 1 January 2027, publicly accessible charging points from 50 kW along the TEN-T road network or at safe and secure truck parking areas must accept ad hoc charging via a card reader or contactless card device, including points built before 13 April 2024.

Law · adopted

If the deadline is missed: Regulator can enforce If a charging point does not meet Article 5(1) AFIR (Regulation (EU) 2023/1804), the Federal Network Agency can require retrofitting under Section 5(2) of the Charging Station Ordinance and prohibit operation under Section 5(3). Legal basis ↗

Applicability: Publicly accessible charging points from 50 kW on the TEN-T road network or at safe and secure parking areas, where charging is paid.

  • Charge point operatorrole obligationCharge point operators retrofit affected existing charging points with card readers or NFC terminals and connect payment to backend and billing.Typically affected: Charging backend (OCPP, PKI), Grid usage and customer billing
Applies from18 January 2027

EU ETS 2: first allowance auction on EEX (early auctions)

Supplier

EU ETS 2 allowances are auctioned on EEX from 18 January 2027, although the regular phase only starts in 2028. Gas suppliers that must surrender allowances as obligated entities from 2028 can buy earlier; taking part in primary auctions requires a Union Registry account.

Regulatory ruling · adopted

If the deadline is missed: No direct legal consequence No sanction attaches to the auction date. Under Section 7(2) TEHG obligated entities must surrender allowances annually by 31 May from 2028; those who surrender too few pay under Section 46 TEHG. Legal basis ↗

Applicability: Obligated entities under the TEHG placing fuels for buildings, road transport and other sectors on the market, mainly gas suppliers. Taking part in the auctions is a procurement decision.

  • Suppliercheck applicabilityAssesses whether to buy allowances for the 2028 surrender duty in the 2027 early auctions and sets up a Union Registry account and EEX access for that.Typically affected: Trading and procurement system (ETRM), Regulatory management, controlling

Linked to: EU ETS 2 starts: emissions trading for buildings and transport replaces the national BEHG

Due by31 January 2027

Congestion income 2026: report the actual use to the Federal Network Agency

TSO

Transmission system operators report to the Federal Network Agency by 31 January how they actually used the 2026 congestion income from allocating cross-zonal capacity. The basis is Article 19(5) of Regulation (EU) 2019/943 and Article 5(2) of the ACER methodology on the use of congestion income; the Federal Network Agency sets the date.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ACER methodology sets no sanction of its own. The Federal Network Agency performs the tasks under Regulation (EU) 2019/943 under Section 56(1) EnWG and can enforce the reporting duty with coercive fines under Section 94 EnWG; the report also feeds its annual report under Article 19(5) of the Regulation. Legal basis ↗

Applicability: Only transmission system operators that earn congestion income from allocating cross-zonal transmission capacity. If the deadline falls on a weekend, Section 31 VwVfG applies.

  • Transmission system operatorrole obligationReports the actual use of the 2026 congestion income to the Federal Network Agency by 31 January.Typically affected: Regulatory management, controlling

Linked to: Congestion income 2027: report the planned use to the Federal Network Agency

Applies from1 March 2027

VDE-AR-N 4105:2026-03: end of the transition period

Power gridCompetitive metering

From this date only the 2026-03 edition applies to connecting generation plants to the low-voltage grid. Technical connection conditions, notification forms (F.1.1, F.1.2) and the connection assessment up to 500 kW have to be switched over by then.

Technical rule · adopted, date open

If the deadline is missed: Civil-law consequence The application rule is not a statute and carries no penalty of its own. It sets general minimum technical requirements; conflicting requirements in technical connection conditions are void under Section 19(1a) EnWG, and the regulator can have them removed under Section 65 EnWG. Legal basis ↗

Applicability: Applies to grid operators, installers and plant operators connecting generation plants and storage to the low-voltage grid. Unchanged existing installations are not covered as long as safe and trouble-free operation is assured.

  • Electricity grid operatorrole obligationSwitches technical connection conditions, notification forms and the assessment process to the 2026-03 edition and records the applicable edition for every case until then.Typically affected: Customer and grid connection portal, Grid planning, GIS, load flow, Plant master data and MaStR
  • Competitive metering point operatoraffectedRegisters generation plants and storage using the new forms and aligns metering concepts with feed-back capable charging equipment treated as storage.Typically affected: Customer and grid connection portal, Grid usage and customer billing

Q2 2027

7 deadlines
Applies from2027, date open

Energy sharing: practical start with the BNetzA platform

Power gridSupplier

Network operators jointly build a nationwide web platform under Section 20b EnWG that also registers energy sharing agreements. The Federal Network Agency sets the date; until then energy sharing runs through the service model.

Law · adopted, date open

If the deadline is missed: Regulator can enforce There is no specific fine. The regulator can enforce the duty under Section 20b(1) EnWG to build the platform jointly through Section 65 EnWG; a binding date only exists once the Federal Network Agency sets one under Section 20b(3) EnWG. Legal basis ↗

  • Electricity grid operatorrole obligationTakes part in building and running the joint platform under Section 20b EnWG; the Federal Network Agency sets the date.Typically affected: Customer and grid connection portal, Market communication gateway (EDIFACT, AS4, API)
  • Suppliercheck applicabilityChecks whether energy sharing offers have to be registered on the platform once it is live.Typically affected: Customer and grid connection portal

Linked to: Energy sharing under § 42c EnWG

Part of the bundle: Market communication and EDM wave

Applies from1 April 2027

MaKo format release, notice no. 58

Power gridTSOMeteringSupplier

On 1 April 2027 ActivationDocument AWT version 1.1g and transport rules version 1.11, including the changes to certificate use with mTLS, become binding. The previously consulted replacement of UTILTS by API web services is off the table.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The versions are binding under the market communication rulings. The Federal Network Agency can have breaches remedied under Section 65 EnWG, or Section 76 MsbG for metering point operators, and enforce this with coercive fines of up to EUR 10 million (Section 94 EnWG). If a secure connection fails because certificates are missing or invalid, the party that did not provide them or used them incorrectly bears the consequences (transport rules, chapter 12). Legal basis ↗

Applicability: ActivationDocument AWT concerns only market partners involved in redispatch. Transport rules 1.11 apply to exchange via AS2, email (SMTP), SFTP and REST; AS4 has its own rules.

  • Electricity grid operatorrole obligationMoves redispatch messages to ActivationDocument AWT 1.1g and updates the transport path to version 1.11.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • Transmission system operatorrole obligationReceives redispatch calls in ActivationDocument AWT 1.1g format and adjusts certificate use for mTLS.Typically affected: Market communication gateway (EDIFACT, AS4, API), Direct marketing and remote control
  • Default metering point operatorrole obligationUpdates the transport path to version 1.11; the planned API replacement of UTILTS is dropped, so UTILTS traffic stays.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • Supplierrole obligationKeeps UTILTS processing for metering times and calculation formulas and adapts the transport path to version 1.11.Typically affected: Market communication gateway (EDIFACT, AS4, API)

Linked to: MaKo format release, notice no. 56

Part of the bundle: Market communication and EDM wave

Applies from1 April 2027

VDE-AR-N 4100:2026-04: end of the transition period

Technical rule · not yet adoptedPower gridMetering

Projects already in planning or under construction on the cut-off date may be completed under the old edition until this day. After that, only the 2026-04 edition applies to customer installations on the low-voltage grid, including instrument transformer installations with semi-indirect metering up to 1,000 A and the meter-position field for communication modules and control units.

If the deadline is missed: Regulator can enforce The application rule is not a statute and carries no penalty of its own. Under Section 20 sentence 2 NAV, technical connection conditions must reflect generally accepted engineering standards; the regulator can have breaches of the NAV stopped under Section 65 EnWG. Legal basis ↗

Applicability: Applies to customer installations on the low-voltage grid. Unchanged existing installations are not covered; triggers for an upgrade include a capacity increase, feed-in, controllable consumption devices under Section 14a EnWG and additional grid connections.

  • Electricity grid operatorrole obligationUpdates the technical connection conditions to the 2026-04 edition and checks meter position, instrument transformer installations and short-circuit ratings against the new requirements.Typically affected: Customer and grid connection portal, Plant master data and MaStR
  • Default metering point operatoraffectedTakes the new meter-position field for communication modules and control units into account in rollout planning and installation specifications.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: VDE-AR-N 4105:2026-03: end of the transition period

Applies from1 April 2027

Schedule nomination process description v4.7 becomes binding

TSOBalancing

From 1 April 2027 version 4.7 of the schedule nomination process description applies to all market participants required to implement it. The changes relate to European market coupling.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce Through Annex 3 the process description is part of the approved balance group contract; the Federal Network Agency can have breaches remedied under Section 65 EnWG. The approved balance group contract (BK6-18-061) provides in clause 20 for a formal warning in case of breaches and extraordinary termination if they recur. Legal basis ↗

  • Transmission system operatorrole obligationApplies version 4.7 of the process description in scheduling.Typically affected: Trading and procurement system (ETRM), Market communication gateway (EDIFACT, AS4, API)
  • Balance responsible partyaffectedChecks whether the scheduling system supports version 4.7.Typically affected: Trading and procurement system (ETRM)

Part of the bundle: Market communication and EDM wave

Due by30 April 2027

Quality element for grid reliability: submit 2026 data to the Federal Network Agency

Power grid

Electricity distribution system operators in the standard procedure submit their 2026 supply interruption data and the other items of the survey form to the Federal Network Agency by 30 April 2027. The agency uses them to set the quality element, a bonus or penalty on the revenue cap. This is the last date under this determination.

Regulatory ruling · adopted

If the deadline is missed: Fine possible The determination also rests on Section 69(7) EnWG. According to the ruling chamber, failing to provide the information, providing it late or incorrectly is an administrative offence under Section 95(1) no. 3(a) EnWG, with a fine of up to EUR 100,000 (Section 95(2) no. 5 EnWG). Legal basis ↗

Applicability: Electricity distribution system operators in the standard procedure of the fourth regulatory period, including those overseen by a state regulator. Not for operators in the simplified procedure or closed distribution systems.

  • Electricity grid operatorrole obligationSubmits the survey form with 2026 interruption data through the Federal Network Agency's energy data portal by 30 April 2027.Typically affected: Regulatory management, controlling, Grid control system / SCADA
Due by18 May 2027

Power plant strategy (StromVKG): auction for generation capacity

Generation

On 18 May 2027 the Federal Network Agency auctions 2 gigawatts of generation capacity. Only generation plants are eligible, with a 15-year commitment.

Law · adopted

If the deadline is missed: Exclusion or loss of role A bid must reach the Federal Network Agency by the bid date, with no reinstatement (Section 37(1) StromVKG). Bids without the fee or security paid by then are excluded under Section 49(1) no. 1 StromVKG. Legal basis ↗

Applicability: Only generation plants at sites without generation on 30 June 2026 or covered by the exceptions in section 12(3) StromVKG.

  • Plant operator (generation)check applicabilityPlant operators assess whether a new build or site meets the conditions and a bid is worthwhile.Typically affected: Plant master data and MaStR, Regulatory management, controlling

Linked to: Power plant strategy (StromVKG): second auction for long-duration capacity

Due by30 June 2027

Capital cost mark-up 2028: application to the regulator

Power grid

Network operators that want capital costs from investments made after the base year reflected in their 2028 revenue cap apply for the capital cost mark-up under Section 10a ARegV by 30 June 2027. The revenue cap is adjusted on 1 January 2028.

Law · adopted

If the deadline is missed: Money is lost Without a timely application the 2028 revenue cap is not adjusted for the capital cost mark-up; under Section 4(4) ARegV the next application is only possible by 30 June of the following year. Legal basis ↗

Applicability: A right to apply, not a duty. Electricity; gas networks move to the fifth regulatory period rules from 2028. State regulators may set procedural rules for operators under their supervision.

  • Electricity grid operatorcheck applicabilityDecides whether to apply for a 2028 capital cost mark-up and files the application with acquisition and production costs, useful lives and construction cost subsidies by 30 June 2027.Typically affected: Regulatory management, controlling

Linked to: Regulatory account: application for 2025

Q3 2027

3 deadlines
Due by31 August 2027

Congestion management: report the 2028 cost reference value and the 2026 difference

TSO

The transmission system operators report their joint reference value for 2028 congestion management costs to the Federal Network Agency by 31 August 2027. By the same date they report the difference between actual 2026 costs and the 2026 reference value and the key for splitting the bonus or penalty.

Law · adopted

If the deadline is missed: Regulator can enforce Section 17 ARegV sets no penalty of its own. The Federal Network Agency can order the report under Section 65(2) EnWG and enforce it with coercive fines; the bonus or penalty enters the revenue cap ex officio under Section 4(5) ARegV. Legal basis ↗

Applicability: Transmission system operators only, jointly.

  • Transmission system operatorrole obligationCalculates the 2028 reference value jointly with the other TSOs and reports it with the 2026 difference and the allocation key by 31 August 2027.Typically affected: Regulatory management, controlling
Due by29 September 2027

Revenue cap 2028: TSO report on the adjustment and provisional network charges

TSO

Transmission system operators report to the Federal Network Agency two working days before 1 October, in 2027 by 29 September, on the adjustment of their 2028 revenue cap and how they set provisional network charges. The basis is determination BK8-19/0001-A of 11 September 2019.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The reporting duty rests on a determination under Section 29(1) EnWG. If a transmission system operator fails to comply, the Federal Network Agency can order compliance under Section 65(2) EnWG and enforce it with coercive fines. Legal basis ↗

Applicability: Transmission system operators only. Distribution system operators are not covered; for them the 15 October publication applies.

  • Transmission system operatorrole obligationReports the adjusted 2028 revenue cap and the derivation of provisional network charges to the Federal Network Agency by 29 September 2027.Typically affected: Regulatory management, controlling, Grid usage and customer billing

Linked to: Congestion management: report the 2028 cost reference value and the 2026 difference

Applies fromEnd of September 2027

MiSpeL: end of the transition period

Power gridMeteringStorage

Until the end of September 2027 the demarcation option and the flat-rate option can be used only with the consent of the grid operator and the metering operator. Both use that period to set up metering, data delivery and billing for the two options.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce From 1 October 2027 grid and metering operators must enable the demarcation and flat-rate options even without their consent (MiSpeL, operative point 7). If they do not, the Federal Network Agency can order remedies under Section 85(3) EEG with Section 65 EnWG; breaching the enforceable order is an administrative offence under Section 86(1) no. 3 EEG (up to EUR 200,000). Legal basis ↗

Applicability: Concerns sites with storage or charging points in mixed use. The individual steps follow from the operative part and the annexes of the ruling.

  • Electricity grid operatoraffectedSets up the processes that let both MiSpeL options run without case-by-case consent by the end of the transition period.Typically affected: EDM / MDM, Grid usage and customer billing
  • Default metering point operatoraffectedProvides the metering and data delivery the demarcation option needs at storage and charging sites.Typically affected: EDM / MDM, Field service and work orders
  • Storage operatorcheck applicabilityClarifies whether moving to one of the two options pays off during the transition period or only afterwards.Typically affected: Plant master data and MaStR

Linked to: MiSpeL: ruling on market integration of storage and charging points

Part of the bundle: Market communication and EDM wave

Q4 2027

8 deadlines
Applies from1 October 2027

Secure exchange rules for scheduling v2.4 become binding

TSOBalancing

From 1 October 2027 version 2.4 of the rules for secure exchange in scheduling applies to all market participants required to implement it. It covers transmission channels and certificates for schedule exchange.

Regulatory ruling · adopted

If the deadline is missed: Civil-law consequence The recipient may leave schedule messages that are not properly signed or encrypted unprocessed, and the sender bears the consequences (chapter 7 of the rules). The approved balance group contract (BK6-18-061) provides in clause 20 for a formal warning in case of breaches and extraordinary termination if they recur. Legal basis ↗

  • Transmission system operatorrole obligationMoves schedule intake to the version 2.4 security rules.Typically affected: Trading and procurement system (ETRM), ISMS and security operations
  • Balance responsible partyrole obligationMoves schedule exchange with the TSO to the version 2.4 security rules.Typically affected: Trading and procurement system (ETRM), ISMS and security operations

Linked to: Schedule nomination process description v4.7 becomes binding

Due by14 October 2027

Renewables grid cost pass-through: binding notification to the TSO

Power gridTSO

Distribution system operators with eligible extra costs from renewables integration submit their binding pass-through notification for 2028 to their transmission system operator. The deadline is the last working day before 15 October.

Regulatory ruling · adopted

If the deadline is missed: Money is lost Under operative item 5(b) of ruling BK8-24-001-A, a late notification means the transmission system operator no longer reimburses the pass-through amount for 2028, and the figures can no longer be corrected. This also applies if only the notification to the regulator by 1 October was on time. Legal basis ↗

Applicability: Only DSOs claiming a particular burden from renewables connections under ruling BK8-24-001-A.

  • Electricity grid operatoraffectedDSOs with eligible renewables extra costs submit their 2028 pass-through amount to the TSO.Typically affected: Regulatory management, controlling
  • Transmission system operatoraffectedTSOs receive the notifications and include the amounts in the nationwide distribution.Typically affected: Regulatory management, controlling

Part of the bundle: Grid regulation and planning

Due by15 October 2027

2028 network charges: publication by 15 October

Power gridGas gridSupplier

Electricity and gas distribution grid operators publish their 2028 network charges online. If the charges are not yet calculated on the cut-off date, operators publish the expected level derived from the revenue cap.

Law · adopted

If the deadline is missed: Regulator can enforce Section 20 EnWG sets no penalty of its own for late publication. The regulator can order publication under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG; breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

  • Electricity grid operatorrole obligationPublishes 2028 electricity network charges by 15 October, if need be as expected values based on the revenue cap.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • Gas grid operatorrole obligationPublishes 2028 gas network charges by 15 October, if need be as expected values based on the revenue cap.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedFeeds the new network charges into 2028 pricing and customer communication.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities

Part of the bundle: Grid regulation and planning

Applies from29 October 2027

REMIT II: new reporting formats and first exposure report

SupplierBalancingDirect marketingGenerationStorage

From 29 October 2027 the new data fields apply to continuous transaction reporting to ACER. Market participants with positions of 600 GWh per year or more report exposures quarterly, first in October 2027; balancing service transactions must be reported monthly from 29 April 2028.

Law · adopted

If the deadline is missed: Fine possible Failing, intentionally or recklessly, to report transaction data to ACER under Article 8(1) REMIT, or reporting it incorrectly, incompletely or late, is an administrative offence under Section 95(1c) no. 7 EnWG, with fines of up to EUR 10,000. The Federal Network Agency can also take supervisory measures under Section 65(6) EnWG. Legal basis ↗

Applicability: REMIT market participants with transactions in wholesale electricity and gas products; exposure reporting only from 600 GWh per year, assessed separately for electricity and gas.

  • Supplierrole obligationSuppliers trading wholesale switch reporting channels and data fields to the new format and check the 600 GWh threshold for exposure reporting.Typically affected: Trading and procurement system (ETRM), Regulatory management, controlling
  • Balance responsible partyaffectedBalance responsible parties supply trade data for the new reporting fields.Typically affected: Trading and procurement system (ETRM)
  • Direct marketerrole obligationDirect marketers adapt transaction reports and prepare monthly reporting of balancing service transactions.Typically affected: Trading and procurement system (ETRM), Direct marketing and remote control
  • Plant operator (generation)check applicabilityPlant operators trading themselves or offering balancing services check whether they report as market participants.Typically affected: Regulatory management, controlling
  • Storage operatoraffectedStorage operators with wholesale or balancing transactions check their reporting duties under the new catalogue.Typically affected: Trading and procurement system (ETRM), Regulatory management, controlling
Due by1 December 2027

Capacity market (StromVKG): first technology-open capacity auction

TSODirect marketingGenerationStorageCompany-wide

The first capacity auction takes place on 1 December 2027, open to generation plants, electricity storage, controllable loads and plant pools. Prequalification with the responsible transmission system operator is required first; applications are only possible from the seventh to the fifth month before the bid date.

Law · adopted

If the deadline is missed: Exclusion or loss of role Without prequalification the Federal Network Agency excludes a bid under Section 49(2) StromVKG, and prequalification can only be applied for within the window in Section 26(2). A late bid does not count, and there is no reinstatement (Section 37(1) StromVKG). Legal basis ↗

Applicability: Operators of generation plants, electricity storage and controllable loads, and aggregators wishing to bid.

  • Transmission system operatorrole obligationTransmission system operators run prequalification on the joint online platform and publish volumes and ceiling prices.Typically affected: Customer and grid connection portal, Regulatory management, controlling
  • Direct marketercheck applicabilityDirect marketers and aggregators assess bids for plant pools and small plant pools.Typically affected: Direct marketing and remote control
  • Plant operator (generation)check applicabilityPlant operators assess which power or CHP plants to prequalify and offer.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Storage operatorcheck applicabilityStorage operators assess participation; eligible capacity depends on the maximum delivery duration.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Company-wide, several rolescheck applicabilityCompanies with controllable loads assess offering load reduction as capacity.Typically affected: Plant master data and MaStR
Applies from2 December 2027

EU AI Act: high-risk requirements, Annex III

Power gridCompany-wide

From 2 December 2027 the high-risk duties apply to Annex III systems, such as credit checks and applicant screening. Under the Commission's draft guidelines of 19 May 2026, grid AI is only covered where, as a safety component, it directly protects the asset and the operator is designated a critical entity. The Bundesnetzagentur has been the supervisory authority since 29 July 2026.

Law · adopted

If the deadline is missed: Fine possible Breaches of the duties of providers (Art. 16) and deployers (Art. 26) of high-risk AI can be fined under Art. 99(4)(a) and (e) of the AI Act up to EUR 15 million or 3% of worldwide turnover, with the lower amount for SMEs. Under Art. 111(2), systems placed on the market or put into service before 2 December 2027 are only covered after a significant change. Legal basis ↗

  • Electricity grid operatorcheck applicabilityChecks whether AI in grid control and control systems protects the asset as a safety component and whether the company counts as a critical entity. Only then is it high-risk under Annex III point 2.Typically affected: Grid control system / SCADA, AI systems and chatbots
  • Company-wide, several rolescheck applicabilityChecks whether AI systems serve an Annex III purpose, such as credit checks or applicant screening, and prepares the deployer duties under Art. 26.Typically affected: AI systems and chatbots, ISMS and security operations

Linked to: EU AI Act: transparency duties under Art. 50, KI-MIG: the Bundesnetzagentur becomes market surveillance authority

Decision2027

AgNes: follow-up rulings that fill in the detail

Regulatory ruling · expectedPower gridSupplier

After the framework ruling at the end of 2026, the Bundesnetzagentur plans to fill in the new system in follow-up rulings during 2027. Distribution system operators plan billing and systems against this detail.

If the deadline is missed: No direct legal consequence The Federal Network Agency issues the follow-up rulings. If they slip, less time remains to convert price sheets, billing and systems before the new system applies from 2029. Legal basis ↗

  • Electricity grid operatoraffectedAligns billing and systems with the follow-up rulings once they are published.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities
  • Suppliercheck applicabilityChecks which new charge components change tariffs and customer billing.Typically affected: Grid usage and customer billing

Linked to: AgNes: framework ruling on electricity grid charges

Due by31 December 2027

SAP ECC and IS-U: end of mainstream maintenance

Vendor notice · not bindingCompany-wide

Extended maintenance until 2030 at a surcharge. Migrations to S/4HANA Utilities take 18 to 36 months.

If the deadline is missed: No direct legal consequence The date is set by SAP, not by law. From 2028 SAP only covers legal changes in extended maintenance, at a premium and until the end of 2030 at the latest; without it the system is no longer adapted to new legal requirements. Legal basis ↗

Applicability: Only affects companies running SAP ECC or IS-U. The date follows from SAP's maintenance strategy, not from law.

  • Company-wide, several rolesaffectedPlans the move from SAP IS-U to S/4HANA Utilities or contracts extended maintenance until 2030.Typically affected: SAP IS-U / S/4HANA Utilities

Q1 2028

4 deadlines
Applies from1 January 2028

NEST: fifth regulatory period, gas

Gas grid

New incentive regulation under the NEST rulings of December 2025. The fifth period lasts five years, to the end of 2032 (RAMEN Gas, operative item 3.1), followed by three-year periods.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The start of the period triggers no penalty itself; the regulator sets the revenue caps ex officio (RAMEN Gas, operative item 4.1). It can enforce duties under the NEST rulings, such as notifying the capital cost markup by 30 June of the previous year, under Section 65 EnWG. Legal basis ↗

  • Gas grid operatorrole obligationEnters the fifth gas regulatory period, which runs for five years; three-year periods follow.Typically affected: Regulatory management, controlling

Linked to: Gas WACC: the rate of return decision is issued

Applies from1 January 2028

EU ETS 2 starts: emissions trading for buildings and transport replaces the national BEHG

SupplierHeat networkCompany-wide

The regular phase of EU ETS 2 starts on 1 January 2028; the first surrender of allowances for 2028 emissions is due by 31 May 2029. Reporting and surrender duties under the national BEHG continue through 2027.

Law · adopted

If the deadline is missed: Fine possible If an obligated entity does not surrender enough allowances by 31 May, the authority sets a payment of EUR 100 per missing tonne of CO2 equivalent under Section 46(1) TEHG, indexed to inflation since 2012. The allowances must still be surrendered, and the name is published in the Federal Gazette (Section 46(3) and (4) TEHG). Legal basis ↗

Applicability: Obligated entities under BEHG and TEHG placing fuels for buildings, road transport and additional sectors on the market; indirectly all customers.

  • Supplierrole obligationGas suppliers placing fuels on the market as obligated entities move monitoring, allowance procurement and price pass-through to EU ETS 2.Typically affected: Trading and procurement system (ETRM), Grid usage and customer billing, Regulatory management, controlling
  • Heat network operatoraffectedHeat network operators whose fuels are outside EU ETS 1 factor the EU ETS 2 carbon price into heat prices and indexation clauses.Typically affected: Grid usage and customer billing
  • Company-wide, several rolescheck applicabilityCompanies assess carbon costs for fleet and building heat from 2028.Typically affected: Regulatory management, controlling
Applies from1 January 2028

BRÜCKEN ruling: provisions for decommissioning and dismantling gas grids

Gas grid

From the fifth regulatory period, allocations to and releases of provisions for decommissioning and unavoidable dismantling of gas grids count as cost shares outside the efficiency benchmark. Operators and lessors of gas grids need a traceable derivation of those provisions in the cost review.

Regulatory ruling · adopted

If the deadline is missed: Money is lost The BRÜCKEN ruling (BK9-25/618) only recognises provisions for necessary decommissioning and unavoidable dismantling. Amounts without a traceable derivation are not recognised as cost shares outside the efficiency benchmark. Legal basis ↗

Applicability: Concerns operators and lessors of gas distribution grids under incentive regulation. The classification takes effect with the fifth regulatory period for gas; how far provisions from the base year count is set out in the ruling.

  • Gas grid operatoraffectedDerives the provisions for decommissioning and unavoidable dismantling in a traceable way and submits them in the cost review for the fifth regulatory period.Typically affected: Regulatory management, controlling

Linked to: NEST: fifth regulatory period, gas

Applies from1 January 2028

Smart meter gateways: installation only to version 2.0 of protection profile and TR-03109-1

MeteringCompetitive metering

Under the BSI transition rules, gateways certified to protection profile PP-0073 version 1.3 and TR-03109-1 version 1.1 may only be installed until 31 December 2027, and recertification to that standard can be requested until that date at the latest. After that, version 2.0 applies to newly installed gateways. Devices already in the field can move to the new standard by software update.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce Under Section 19(2) MsbG, only systems that meet Sections 21 and 22 may be used for billing, balancing and grid-related metering and control; the yardstick is the protection profiles and technical guidelines in the version in force, which the BSI publishes under Section 22(2). The Federal Network Agency can act against breaches under Section 76 MsbG. Legal basis ↗

Applicability: Applies to installation. For gateways already in the field, the transition rules point to migration by software update.

  • Default metering point operatoraffectedSwitches procurement so that only version 2.0 gateways are installed from 2028 and agrees the software migration of installed devices with vendors and gateway administration.Typically affected: Gateway administration and CLS management, Field service and work orders
  • Competitive metering point operatoraffectedUses up old-standard stock by the end of 2027 and installs only version 2.0 gateways from 2028.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: BSI TR-03109-1 v2.0: gateway certificates only with MUSS+

Q2 2028

2 deadlines
Applies from1 June 2028

Energy sharing across the grid boundary

Power gridSupplier

From 1 June 2028 energy sharing must also work across adjacent balancing areas. According to the Federal Network Agency's Notice No. 73, the supplier based service model covers this too, with no further implementation by network operators.

Law · adopted

If the deadline is missed: Regulator can enforce There is no specific fine. If a distribution system operator does not enable shared use with the adjacent balancing area (Section 42c(4) sentence 1 no. 2 EnWG), the regulator can order remedies under Section 65 EnWG. According to the Federal Network Agency's Notice No. 73, the supplier-based service model covers this stage too. Legal basis ↗

  • Electricity grid operatorcheck applicabilityChecks coordination needs with the adjacent network operator; per the Federal Network Agency the service model suffices here too.Typically affected: Market communication gateway (EDIFACT, AS4, API)
  • Suppliercheck applicabilityChecks whether to offer energy sharing across adjacent balancing areas as a service.Typically affected: Grid usage and customer billing

Linked to: Energy sharing under § 42c EnWG

Due by30 June 2028

WPG: heat plans for all municipalities under 100,000 inhabitants

Gas gridHeat network

After the large cities, all remaining municipalities must submit their heat planning; utilities provide the data basis.

Law · adopted

If the deadline is missed: No direct legal consequence The deadline binds the planning bodies, usually municipalities, not the network operators. If grid or heat network operators withhold the information owed under Section 11(1) no. 2 WPG, the planning body can order it with a deadline under Section 11(6) WPG. Legal basis ↗

Applicability: The planning duty lies with municipalities of 100,000 inhabitants or fewer; network operators contribute data.

  • Gas grid operatoraffectedAligns gas network areas and conversion paths with municipal heat planning.Typically affected: Grid planning, GIS, load flow
  • Heat network operatoraffectedProvides the municipality with data on network, generation and expansion plans for heat planning.Typically affected: Grid planning, GIS, load flow

Q3 2028

2 deadlines
Due by1 July 2028

MaBiS hub: test systems of all market partners ready (BDEW scenario)

Regulatory ruling · not yet adoptedPower gridSupplier

Under the BDEW introduction scenario, the test systems of all market partners and of the MaBiS hub are available from 1 July 2028. Every interface to the hub has to pass at least one test by 30 September 2028. Parallel operation starts on 1 January 2029.

If the deadline is missed: No direct legal consequence There is no decision yet in proceeding BK6-24-210, and the date comes from the industry's introduction scenario. It only becomes binding and enforceable under Section 65 EnWG once a ruling sets it. Legal basis ↗

Applicability: The dates are a BDEW proposal that the Federal Network Agency put out for consultation unchanged in procedure BK6-24-210-1. They are not binding: notice no. 58 of 1 October 2026 lists the MaBiS hub ruling as pending.

  • Electricity grid operatoraffectedAdapts balancing and data exchange systems to the MaBiS hub interfaces.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
  • SupplieraffectedMoves balancing group processes and data reconciliation to the central MaBiS hub.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
Applies from1 July 2028

Metering Act Section 40: new gas meters with load profile metering on the smart meter gateway

Gas gridMeteringCompetitive metering

New gas meters with interval (load profile) metering must be connected to existing smart meter gateways from 1 July 2028 at the latest. Other new gas meters follow once connection is technically possible and causes no extra cost.

Law · adopted

If the deadline is missed: Regulator can enforce Section 40 MsbG sets no penalty of its own. The Federal Network Agency can order compliance under Section 76(2) MsbG and enforce it with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). Legal basis ↗

Applicability: Newly installed gas meters with interval metering at metering points with an existing smart meter gateway.

  • Gas grid operatoraffectedGas DSOs ensure receipt and processing of meter data via the gateway infrastructure.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
  • Default metering point operatorrole obligationDefault gas metering operators plan meter types, interfaces and gateway connection for new interval gas meters.Typically affected: Gateway administration and CLS management, EDM / MDM, Field service and work orders
  • Competitive metering point operatoraffectedCompetitive metering operators handling interval gas meters also set up gateway connection.Typically affected: Gateway administration and CLS management, EDM / MDM

Q4 2028

2 deadlines
Due byDecember 2028 at the earliest, date open

BSIG § 39: first evidence for critical installations

Company-wide

Operators of critical installations must prove their security measures through an audit, review or certification, then every three years. The BSI sets the date, at the earliest three years after the installation counts as critical.

Law · adopted, date open

If the deadline is missed: Fine possible Section 39 BSIG does not apply to energy networks and energy installations under Sections 5c to 5e EnWG (Section 28(5) BSIG); for them Section 95(1) nos. 3c and 3d EnWG penalise missing or late documentation. For other critical installations, failing to provide the evidence under Section 39(1) BSIG, or providing it late, is an administrative offence under Section 65(2) no. 10 BSIG, with fines of up to EUR 1 million. Legal basis ↗

Applicability: Only for operators of critical facilities under the BSIG. Section 39 BSIG does not apply to energy supply networks and energy installations subject to Sections 5c to 5e EnWG (Section 28(5) BSIG), so utilities are only affected through other critical facilities.

  • Company-wide, several rolescheck applicabilityPrepares audit, inspection or certification if facilities count as critical; the BSI sets the date.Typically affected: ISMS and security operations

Linked to: German NIS2 implementation act in force

Due by31 December 2028

Smart meter rollout: 90 percent of the 2027 to 2028 installation cases

Metering

By the end of 2028 default metering point operators must have equipped at least 90 percent of the metering points that fall due for installation in 2027 and 2028.

Law · adopted

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). If the rollout of control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

  • Default metering point operatorrole obligationFits at least 90 percent of metering points due in 2027 and 2028 with smart metering systems.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of the installation cases since February 2025

Q1 2029

5 deadlines
Applies from1 January 2029

§ 14a EnWG: end of the transition period

Power gridMetering

Preventive control is only allowed until 31 December 2028; from 2029 grid operators control solely on a grid-oriented basis using grid state assessment, which has applied to new installations since 2024. The old § 14a rules end on the same date: legacy installations above 4.2 kW with a reduced network charge move into the new rules, night storage heaters keep the old arrangement, and the rest lose the reduction.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce From 1 January 2029 ruling BK6-22-300 no longer permits preventive control (Annex 1 item 10.5), and the new rules apply to legacy installations above 4.2 kW with the old § 14a reduction (item 10.2). The Federal Network Agency can order a breach to stop under Section 65 EnWG and enforce this with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Controllable consumption devices at low voltage above 4.2 kW: non-public charging points, heat pumps, air conditioning and battery storage. Pre-2024 installations without a § 14a reduction stay outside but may switch voluntarily.

  • Electricity grid operatorrole obligationReplaces preventive control with grid-oriented control by 31 December 2028 at the latest, announces the switch to device operators and suppliers in advance, and moves legacy installations above 4.2 kW with the old § 14a reduction into the new rules on 1 January 2029.Typically affected: Grid control system / SCADA
  • Default metering point operatoraffectedProvides control units and gateway connections for legacy installations that move into grid-oriented control on 1 January 2029.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of the installation cases since February 2025

Applies from1 January 2029

AgNes: new grid charge system takes effect

Regulatory ruling · not yet adoptedPower gridSupplier

StromNEV expires on 31 December 2028; the BNetzA rulings replace the ordinance.

If the deadline is missed: Regulator can enforce Under the draft ruling (operative point 1.2), only grid charges under the AgNes system are permitted from 1 January 2029. A network operator that bills otherwise can be ordered by the regulator to comply under Section 65 EnWG. Legal basis ↗

  • Electricity grid operatoraffectedBills network charges from 2029 under the Federal Network Agency's new framework instead of the StromNEV.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • SupplieraffectedPasses the new network charge structures on in tariffs and bills from 2029.Typically affected: Grid usage and customer billing

Linked to: AgNes: follow-up rulings that fill in the detail

Applies from1 January 2029

NEST: fifth regulatory period, electricity

Power grid

New electricity incentive regulation under the NEST rulings; the fifth period lasts five years (RAMEN Strom, operative item 3.1). From 2029 network reliability feeds into the revenue cap as a bonus or deduction, while network performance indicators are only published for now.

Regulatory ruling · adopted

If the deadline is missed: Money is lost From 2029 the regulator sets annual bonuses or deductions on the revenue cap where a network operator's reliability deviates from the reference value (quality element, ruling GBK-24-02-1#4, operative item 5.4.1). It can enforce other duties under the NEST rulings under Section 65 EnWG. Legal basis ↗

  • Electricity grid operatorrole obligationEnters the fifth electricity regulatory period; from 2029 network reliability affects the revenue cap as a quality element.Typically affected: Regulatory management, controlling
Applies from1 January 2029

Customer installations: transition period for existing installations ends

Power gridSupplierGenerationCompany-wide

For customer installations under Section 3 nos. 65 and 66 EnWG connected by 23 December 2025, grid regulation rules only apply from 1 January 2029. Operators of such installations clarify by then whether and which regulatory requirements apply to them.

Law · adopted

If the deadline is missed: Regulator can enforce From 1 January 2029 the grid regulation rules also apply to these existing installations (Section 118(7) EnWG). If they are not met, the regulator can order measures under Section 65 EnWG; breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

Applicability: Operators of customer installations and customer installations for in-house supply connected by 23 December 2025.

  • Electricity grid operatoraffectedElectricity DSOs expect requests on metering concepts, takeover or grid connection of former customer installations.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM, Grid planning, GIS, load flow
  • Suppliercheck applicabilitySuppliers running tenant electricity or district models check whether the customer installations they use count as grids from 2029.Typically affected: Regulatory management, controlling, Market communication gateway (EDIFACT, AS4, API)
  • Plant operator (generation)check applicabilityPlant operators with direct lines or site supply check how their installation is classified.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Company-wide, several rolescheck applicabilityCompanies with contracting or site grid business assess restructuring, handover or regulation of existing customer installations.Typically affected: Regulatory management, controlling
Applies from1 January 2029

MsbG Section 19(5): non-compliant metering systems above 100,000 kWh or 100 kW only under conditions

MeteringCompetitive metering

From 1 January 2029, metering systems that do not meet smart metering system requirements may only be installed and used at metering points above 100,000 kWh annual consumption or at plants above 100 kW if a smart metering system installation has been announced or ordered, there are no disproportionate risks, and the connection user has consented or the BSI has issued a determination. For all other metering points this limit has applied since the end of 2025.

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG has no administrative fine provision. The Federal Network Agency can order the conduct to stop under Section 76 MsbG and enforce the order with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Metering points under Section 30(1) no. 1 MsbG: annual consumption above 100,000 kWh or plants with installed capacity above 100 kW. Household customers can withdraw consent at any time.

  • Default metering point operatorrole obligationReplaces non-compliant metering systems at large consumers and plants above 100 kW by the end of 2028, or secures an announced or ordered smart metering system plus consent or a BSI determination for continued use.Typically affected: Field service and work orders, Gateway administration and CLS management, SAP IS-U / S/4HANA Utilities
  • Competitive metering point operatorrole obligationReviews its own installed metering systems at customers above 100,000 kWh or 100 kW and switches to compliant technology by the end of 2028 or documents the exemption conditions.Typically affected: Field service and work orders, Gateway administration and CLS management

Linked to: Smart meter rollout: 90 percent of the 2027 to 2028 installation cases

Q3 2029

1 deadline
Due by4 August 2029

Electricity storage: commissioning deadline for the grid fee exemption under Section 118(6) EnWG

Power gridTSOStorage

Electricity storage commissioned within 18 years from 4 August 2011 is exempt for 20 years from grid fees on electricity drawn for storage. The exemption only applies to the extent the stored electricity is fed back into the same grid with a time delay.

Law · adopted

If the deadline is missed: Exclusion or loss of role Storage commissioned after the deadline is not exempt from grid fees under Section 118(6) sentence 1 EnWG; commissioning means the first draw of electricity for trial operation (sentence 6). Under the AgNes draft (operative point 17.5) the exemption is also to require an investment decision before the ruling is notified, to be proven by 31 March 2027. Legal basis ↗

Applicability: Electricity storage built after 31 December 2008 drawing from the grid and commissioned by the deadline.

  • Electricity grid operatoraffectedElectricity DSOs check the exemption conditions and bill storage withdrawal accordingly.Typically affected: Grid usage and customer billing, EDM / MDM
  • Transmission system operatoraffectedTransmission system operators reimburse downstream DSOs for lost revenue.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Storage operatoraffectedStorage operators factor the commissioning date into project planning and business cases.Typically affected: Plant master data and MaStR, Regulatory management, controlling

Q4 2029

1 deadline
Applies from1 October 2029

MaBiS hub: go-live (BDEW scenario)

Regulatory ruling · not yet adoptedPower gridSupplier

Under the BDEW introduction scenario, parallel operation ends on 1 October 2029 and only the new process landscape with the MaBiS hub applies from then on. Block 1 of the ruling (BK6-24-210-1) was open for comment until 17 November 2025; block 2 on balance group settlement follows.

If the deadline is missed: No direct legal consequence The go-live date so far only appears in the industry's introduction scenario; there is no decision yet in proceeding BK6-24-210. Only a ruling would make the date binding and enforceable under Section 65 EnWG. Legal basis ↗

Applicability: The date is a BDEW proposal that the Federal Network Agency has put out for consultation in procedure BK6-24-210-1 but not adopted. Notice no. 58 of 1 October 2026 lists the MaBiS hub ruling as pending.

  • Electricity grid operatoraffectedWorks with central balancing settlement in the MaBiS hub from go-live.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
  • SupplieraffectedReceives balancing settlement and data reconciliation from the MaBiS hub from go-live.Typically affected: EDM / MDM

Linked to: MaBiS hub: test systems of all market partners ready (BDEW scenario)

Q4 2030

2 deadlines
Due by31 December 2030

Smart meter rollout: 90 percent of the 2029 to 2030 installation cases

Metering

Third period quota of the statutory rollout: at least 90 percent of the metering points that fall due in 2029 and 2030. The target year for the full stock is 2032.

Law · adopted

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). If the rollout of control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

  • Default metering point operatorrole obligationFits at least 90 percent of metering points due in 2029 and 2030 with smart metering systems.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of the 2027 to 2028 installation cases

Target31 December 2030

Coalition committee: smart meter rollout above 90 percent of all relevant metering points by end of 2030

Policy · not bindingMetering

The coalition committee wants the rollout for all relevant metering points more than 90 percent complete by the end of 2030, two years ahead of the current MsbG target year 2032. A low-cost "Smart Meter Light" is planned for customers outside the mandatory rollout. No draft bill has been published yet.

If the deadline is missed: No direct legal consequence The target is a coalition decision without legal effect. The binding quotas remain those in Section 45 MsbG, which the Federal Network Agency can enforce under Section 76 MsbG. Legal basis ↗

Applicability: A political target; which metering points count as relevant and whether the quota applies per operator will only be set by the announced MsbG amendment.

  • Default metering point operatorcheck applicabilityChecks whether the rollout plan, framework contracts and installation capacity could support completing the mandatory rollout by the end of 2030; the target only becomes binding with the MsbG amendment.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of the 2029 to 2030 installation cases, Smart meter rollout: 90 percent of all mandatory cases

Q4 2031

1 deadline
Due by31 December 2031

EU proposal: smart metering systems for 50 percent of all final customers (Article 18b Regulation (EU) 2019/943)

Law · not yet adoptedMetering

Under Commission proposal COM(2026) 600, smart metering systems would have to cover at least 50 percent of all final customers, with 75 percent as the next step. Member states below 30 percent when the regulation enters into force get until 31 December 2031 and 31 December 2034; Germany stood at 5.9 percent on 30 June 2026. The cost-benefit analysis would only apply to rollout beyond 75 percent. Nothing has been adopted yet.

If the deadline is missed: No direct legal consequence Under the proposal the quota is addressed to member states and sets no sanction for metering operators. Consequences for default metering operators would only follow from implementation in the MsbG. Legal basis ↗

Applicability: Commission proposal in the ordinary legislative procedure; content and dates may change in Council and Parliament. The duty is addressed to member states; national law decides how it falls on metering operators.

  • Default metering point operatorcheck applicabilityAssesses what a quota based on all final customers rather than mandatory installation cases would mean for rollout planning, device procurement and installation capacity; it only becomes binding with the regulation and an MsbG amendment.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of all mandatory cases

Q4 2032

1 deadline
Due by31 December 2032

Smart meter rollout: 90 percent of all mandatory cases

Metering

Final mark of the statutory rollout: by the end of 2032, 90 percent of all metering points to be equipped need an intelligent metering system. Optional installation cases count towards the quota since the EnWRÄndG of 18 December 2025.

Law · adopted

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). If the rollout of control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

  • Default metering point operatorrole obligationHas fitted at least 90 percent of all metering points due with smart metering systems by the end of 2032.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of the 2029 to 2030 installation cases

Where it gets tight

Three bundles where several deadlines need the same system and the same team. Each dot is one deadline.

October 2026 to October 2027

Market communication and EDM wave

Team: Market communication, EDM, IS-U operations
Shared systems: Market communication gateway (EDIFACT, AS4, API), EDM / MDM, SAP IS-U / S/4HANA Utilities

  • 1 October 20263 deadlines, passed
  • 1 April 20272 deadlines
  • 2027, date open1 deadline
  • End of September 20271 deadline

4 of 7 dates are still ahead.

The deadlines and why it gets tight

Mitteilung 56, WiM Gas 2.0 and the MiSpeL ruling all landed on 1 October 2026. Mitteilung 58 brings the new redispatch format and transport rules 1.11 on 1 April 2027, and the MiSpeL transition ends at the end of September 2027. Going live on one version and starting the project for the next fall into the same weeks.

December 2026 to January 2027

Metering at year end

Team: Default metering, gateway administration, field service
Shared systems: Gateway administration and CLS management, Field service and work orders, Market communication gateway (EDIFACT, AS4, API)

  • 31 December 20263 deadlines
  • 1 January 20273 deadlines

6 of 6 dates are still ahead.

The deadlines and why it gets tight

Both 90 percent rollout quotas and remote reading of heat meters fall due at year end. In January, TR-03109-6 version 2.0 follows with the next recertification of the gateway administration system, along with the MUSS+ requirements for new gateway certificates. Every one of them pulls on the same installers, the same gateway administration system and the same deliveries of gateways and control boxes.

October 2026 to January 2027

Grid regulation and planning

Team: Regulatory management, grid planning, grid connection
Shared systems: Regulatory management, controlling, Grid planning, GIS, load flow, Customer and grid connection portal

  • 14 October 20261 deadline, passed
  • 15 October 20261 deadline, passed
  • 26 October 20261 deadline
  • 31 October 20261 deadline
  • 31 December 20261 deadline
  • End of 20262 deadlines
  • 1 January 20271 deadline
  • 14 October 20271 deadline
  • 15 October 20271 deadline

8 of 10 dates are still ahead.

The deadlines and why it gets tight

Grid charges on 15 October, the § 14d grid expansion plan on 31 October, the AgNes framework and gas WACC at year end, the grid package from January 2027. The same revenue cap model, the same GIS and usually the same few people in regulation and grid planning.

Already in force (15)

Show all 15
Applies from1 October 2026

Use instead of curtail: daily tenders for curtailment volumes (Section 13k EnWG)

Power gridTSOHeat network

Since 1 October 2026, TSOs with control area responsibility allocate the electricity volumes that would otherwise be curtailed due to transmission congestion through daily competitive tenders to registered additional loads in relief regions. The flat-rate allocation of the trial phase has ended. Amprion and TransnetBW do not designate relief regions at the start.

Law · in force

If the deadline is missed: Regulator can enforce The Act sets no specific administrative fine for the Section 13k EnWG obligation. The Federal Network Agency can enforce compliance under Section 65 EnWG. Legal basis ↗

Applicability: Only additional loads in the relief regions designated by the TSOs; installations with an agreement under Section 13(6a) EnWG are excluded. The minimum capacity per installation or aggregate may not exceed 500 kW.

  • Electricity grid operatoraffectedCoordinates data exchange and allocated volumes for relief installations in its own grid with the TSO.Typically affected: Grid control system / SCADA
  • Transmission system operatorrole obligationRuns the daily tenders before the day-ahead auction closes at the latest, designates relief regions and registers relief installations.Typically affected: Grid control system / SCADA, Trading and procurement system (ETRM)
  • Heat network operatorcheck applicabilityChecks whether power-to-heat units in a relief region can be registered as relief installations and take part in the tenders.Typically affected: Plant master data and MaStR
Applies from1 October 2026

Gas: new metering point operator framework contract

Gas gridMeteringCompetitive metering

Gas network operators and metering point operators had to draw up a new metering point operator framework contract by 1 October 2026. The previous ruling BK7-17-026 was revoked on the same day.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce Ruling BK7-24-01-009 sets no penalty of its own. Failing to conclude the framework contract in its current version, or as a gas network operator failing to publish it (operative item 15), breaches a ruling; the Federal Network Agency can enforce this under Section 76(1) and (4) MsbG with coercive fines of EUR 1,000 to EUR 10 million. Legal basis ↗

  • Gas grid operatorrole obligationApplies the new framework contract and moves existing arrangements with metering point operators onto it.Typically affected: Market communication gateway (EDIFACT, AS4, API), Customer and grid connection portal
  • Default metering point operatorrole obligationConcludes the new framework contract with gas network operators.Typically affected: Market communication gateway (EDIFACT, AS4, API)
  • Competitive metering point operatoraffectedConcludes the new framework contract to keep operating gas metering points.Typically affected: Market communication gateway (EDIFACT, AS4, API)

Linked to: GeLi Gas 2.0 applies

Applies from1 October 2026

WiM Gas 2.0 applies

Gas gridMetering

Digitalised metering switch processes for gas, new message formats.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce WiM Gas 2.0 implements ruling BK7-19-001. The Federal Network Agency can have breaches remedied under Section 76 MsbG for metering point operators and Section 65 EnWG for network operators, and enforce this with coercive fines of up to EUR 10 million (Section 94 EnWG). Legal basis ↗

  • Gas grid operatorrole obligationMaintains assignment and master data of gas metering points under the new metering change processes.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
  • Default metering point operatorrole obligationHandles metering operator changes, device changes and meter data transfer for gas under WiM Gas 2.0.Typically affected: Market communication gateway (EDIFACT, AS4, API), Field service and work orders, EDM / MDM

Linked to: MaKo format release, notice no. 56, GeLi Gas 2.0 applies

Part of the bundle: Market communication and EDM wave

Applies from1 October 2026

MaKo format release, notice no. 56

Power gridGas gridMeteringSupplier

25 AHB and MIG versions covering 13 EDIFACT message types, AS4 profile 1.2 and the AS4 transport rules 2.6 become binding. Test plan, exception handling and fallback scenarios need to be in place.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce The versions are binding under the market communication rulings. The Federal Network Agency can have breaches remedied under Section 65 EnWG, or Section 76 MsbG for metering point operators, and enforce this with coercive fines of up to EUR 10 million (Section 94 EnWG); breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

  • Electricity grid operatorrole obligationRuns the new AHB/MIG versions in production from 1 October, including UTILMD electricity 2.2 with the remote controllability flag.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities, EDM / MDM
  • Gas grid operatorrole obligationMoves UTILMD gas to version G1.2 and tests gas processes against the new check identifiers.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
  • Default metering point operatorrole obligationMoves MSCONS, ORDERS and UTILMD to the new versions and updates the AS4 connection to profile 1.2.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • Supplierrole obligationProcesses switching, master data and invoice messages in the new versions and resolves rejections via APERAK.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities, Grid usage and customer billing

Part of the bundle: Market communication and EDM wave

Applies from2 August 2026

EU AI Act: transparency duties under Art. 50

Company-wide

Since 2 August 2026 the Art. 50 transparency duties apply: a chatbot or voicebot must be recognisable as AI, and generated content must be marked in a machine-readable way. For systems placed on the market before that date, the Art. 50(2) marking applies from 2 December 2026.

Law · in force

If the deadline is missed: Fine possible Breaches of the transparency duties in Art. 50 of the AI Act can be fined under Art. 99(4)(g) up to EUR 15 million or 3% of worldwide annual turnover, with the lower amount for SMEs and small mid-caps. The Federal Network Agency is generally the competent authority (Sections 2 and 17 KI-MIG). Legal basis ↗

Applicability: Art. 50 splits by role: providers make sure people recognise a chatbot as AI (para. 1) and that generated content is marked machine-readably (para. 2). Deployers inform people about emotion recognition and disclose deepfakes (paras. 3 and 4).

  • Company-wide, several rolescheck applicabilityChecks which systems talk to customers or generate text, images or audio, and puts the Art. 50 notice and marking in place.Typically affected: AI systems and chatbots
Applies from29 July 2026

KI-MIG: the Bundesnetzagentur becomes market surveillance authority

Company-wide

For AI systems in critical infrastructure and in HR, the Bundesnetzagentur is the supervisor, contact point and complaints body. Anyone using AI in grid operations or customer service now has a German counterpart for evidence and complaints.

Law · in force

If the deadline is missed: Regulator can enforce The KI-MIG sets companies no deadline of its own. Since 29 July 2026 it has made the Federal Network Agency the market surveillance and fining authority for the AI Act (Sections 2, 11 and 17 KI-MIG); false or incomplete information supplied to it can be fined under Art. 99(5) AI Act up to EUR 7.5 million or 1% of worldwide turnover. Legal basis ↗

  • Company-wide, several rolesaffectedAligns AI documentation and evidence with the Federal Network Agency as the competent market surveillance authority.Typically affected: AI systems and chatbots
Applies from1 July 2026

Standard metering contracts for default metering operators

Power gridMeteringCompetitive meteringSupplier

BK6-24-125: MSB-RV, MSV-AN and MSV-LF are binding for default metering point operators.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce Ruling BK6-24-125 sets no penalty of its own. Under Section 76(1) MsbG the Federal Network Agency can order conduct contrary to the ruling to stop and enforce this with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationConcludes new metering operator framework contracts on the amended MSB-RV, adapts existing ones and publishes the MSB-RV on its website so it can be concluded in text form.Typically affected: Customer and grid connection portal, SAP IS-U / S/4HANA Utilities
  • Default metering point operatorrole obligationConcludes metering contracts with connection users and suppliers on the standard MSV-AN and MSV-LF templates.Typically affected: SAP IS-U / S/4HANA Utilities, Customer and grid connection portal
  • Competitive metering point operatoraffectedSigns the metering operator framework contract with the grid operator on the amended template or adapts the existing one.Typically affected: SAP IS-U / S/4HANA Utilities
  • SupplieraffectedSigns the standard MSV-LF metering contract with the default metering operator.Typically affected: SAP IS-U / S/4HANA Utilities
Applies from1 June 2026

Energy sharing under § 42c EnWG

Power gridSupplier

Since 1 June 2026 energy sharing has to be possible within a network operator's balancing area. According to the Federal Network Agency's Notice No. 73, the supplier based service model is enough and network operators need to implement nothing further.

Law · in force

If the deadline is missed: Regulator can enforce There is no specific fine. If a distribution system operator does not enable shared use under Section 42c(4) EnWG, the regulator can order remedies under Section 65 EnWG; breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). According to the Federal Network Agency's Notice No. 73, the supplier-based service model already meets the duty. Legal basis ↗

  • Electricity grid operatorcheck applicabilityChecks whether the service model works in its grid area; under Notice No. 73 no further implementation duties apply.Typically affected: Market communication gateway (EDIFACT, AS4, API)
  • Suppliercheck applicabilityDecides whether to offer energy sharing as a service and, if so, settles allocation, balancing and residual supply by contract.Typically affected: Grid usage and customer billing, EDM / MDM
Applies from1 April 2026

GeLi Gas 2.0 applies

Gas gridSupplier

New supplier switch processes for gas, UTILMD Gas 1.1.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce The Federal Network Agency can have breaches of ruling BK7-19-001 (GeLi Gas 2.0) remedied under Section 65 EnWG and enforce this with coercive fines of up to EUR 10 million (Section 94 EnWG); breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

  • Gas grid operatorrole obligationHandles gas supplier switches under GeLi Gas 2.0 using the new UTILMD gas versions.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
  • Supplierrole obligationRegisters and deregisters gas customers under the new switching processes and handles responses automatically.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
Applies from17 March 2026

KRITIS umbrella act in force

Company-wide

Physical resilience of critical facilities: registration with BBK and BSI, resilience plans. The original registration deadline was dropped; the ordinance will set the new one.

Law · in force

If the deadline is missed: Fine possible Failing to register under Section 8(1) KRITISDachG, or registering incorrectly or late, is an administrative offence under Section 24 KRITISDachG: up to EUR 100,000, or up to EUR 1 million for defying a BBK order. The resilience duties themselves carry no fine; for electricity, gas and hydrogen the Federal Network Agency can order remedies under Section 5f(6) EnWG. Legal basis ↗

Applicability: Applies to operators of critical facilities. Thresholds and the registration deadline follow from the ordinance under the act.

  • Company-wide, several rolescheck applicabilityChecks which power, gas, heat and water facilities fall under the KRITIS umbrella act and prepares registration and a resilience plan.Typically affected: ISMS and security operations
Applies from1 January 2026

24-hour supplier switch: full obligation, electricity

Power gridMeteringSupplier

Star-shaped switch process via the MaLo ID; extension to gas and hydrogen still open.

Law · in force

If the deadline is missed: Regulator can enforce The Federal Network Agency can order compliance with Section 20a(2) EnWG and ruling BK6-22-024 under Section 65 EnWG and enforce it with coercive fines of up to EUR 10 million (Section 94 EnWG). Affected customers and market partners can demand remedy and cessation under Section 32 EnWG, and damages where there is fault. Legal basis ↗

  • Electricity grid operatorrole obligationConfirms registrations and deregistrations within the 24-hour cycle and keeps MaLo ID master data current.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities, EDM / MDM
  • Default metering point operatoraffectedDelivers meter readings and master data fast enough for the switch to complete within 24 hours.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • Supplierrole obligationCompletes supplier switches via the MaLo ID within 24 hours on every working day.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
Applies from23 December 2025

Electricity suppliers: duty to hold adequate hedging strategies (Section 5(4a) EnWG)

Supplier

Electricity suppliers serving household customers must hold and follow adequate hedging strategies against wholesale price risk. The Federal Network Agency can request the strategies at any time and demand changes.

Law · in force

If the deadline is missed: Regulator can enforce Under Section 5(4a) sentence 3 EnWG the Federal Network Agency can request the hedging strategy at any time and demand changes. If the supplier's economic capability is not ensured, it can prohibit supply in whole or in part under Section 5(5) EnWG. Legal basis ↗

Applicability: All electricity suppliers with household customers.

  • Supplierrole obligationSuppliers document their procurement and hedging strategy so it can be submitted when the Federal Network Agency asks for it.Typically affected: Trading and procurement system (ETRM), Regulatory management, controlling
Applies from6 December 2025

German NIS2 implementation act in force

Company-wide

Applies without a transition period: registration, risk management, reporting within 24 and 72 hours, management liability.

Law · in force

If the deadline is missed: Fine possible For energy networks and energy installations, Sections 5c to 5e EnWG replace the BSIG duties. Section 95(1) nos. 3b to 3e EnWG fines breaches on the scale of Section 65 BSIG: up to EUR 10 million for essential and EUR 7 million for important entities, or 2% and 1.4% of worldwide turnover above EUR 500 million turnover. A missed registration under Section 33 BSIG can be fined up to EUR 500,000 (Section 65(2) no. 6 BSIG). Legal basis ↗

Applicability: Applies to important and essential entities under the BSIG. Sector, headcount, turnover, balance sheet total and critical facility status decide.

  • Company-wide, several rolescheck applicabilityChecks whether it is an important or essential entity, registers with the BSI and sets up risk management and incident reporting.Typically affected: ISMS and security operations
Applies from1 April 2025

§ 14a EnWG module 3: offer and bill the time-variable network charge

Power gridMeteringSupplier

Since 1 April 2025, distribution system operators offer and bill a time-variable network charge with three tariff levels to operators of controllable consumption devices. Tariff levels and the quarters they apply in go on the annual price sheet. Since May 2026 the Federal Network Agency has been opening enforcement proceedings against grid operators that do not implement module 3 or do so inadequately.

Regulatory ruling · in force

If the deadline is missed: Regulator can enforce The Federal Network Agency enforces ruling BK8-22/010-A with coercive fines: it threatens network operators that fail to implement module 3, or do so inadequately, and imposes the fine if the shortcomings are not fixed in time; under Section 94 EnWG it ranges from EUR 1,000 to EUR 10 million. The ruling chamber publishes the names of the companies concerned (Section 74 EnWG). Legal basis ↗

Applicability: Only market locations with a controllable consumption device under section 14a EnWG, a smart metering system and no interval power metering. Module 3 can only be chosen on top of module 1.

  • Electricity grid operatorrole obligationOffers module 3, shows the high, standard and low load tariff levels and the quarters they apply in on the price sheet, and bills the time-variable charge to the grid user when module 3 is chosen.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities, Market communication gateway (EDIFACT, AS4, API), Regulatory management, controlling
  • Default metering point operatoraffectedConfigures the module 3 metering times in the smart metering system when the grid operator orders them and confirms the configuration.Typically affected: Gateway administration and CLS management, Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • Supplierrole obligationShows the network charges per tariff level separately on the invoice for supply contracts that include network charges. In practice the module choice mostly runs through the supplier, who orders metering times and billing data from the grid operator.Typically affected: Grid usage and customer billing, Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
Applies from25 February 2025

Solar Peak Act: no EEG payment at negative prices for new plants

Power gridDirect marketingGeneration

For plants commissioned from 25 February 2025, the reference value drops to zero in every period with a negative spot market price. Plants below 100 kW are only covered from the end of the year in which a smart metering system is installed.

Law · in force

If the deadline is missed: Money is lost For periods with a negative spot price the reference value drops to zero under Section 51(1) EEG, so no payment claim arises; Section 51a EEG extends the support period in return. An operator on the fallback tariff who does not report the volume fed in during such periods under Section 51(3) EEG loses 5 percent of the monthly claim per day affected. Legal basis ↗

Applicability: EEG plants commissioned from 25 February 2025 and existing plants that opt in voluntarily.

  • Electricity grid operatoraffectedElectricity DSOs reflect the reduction and the extended support period in EEG billing.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities
  • Direct marketeraffectedDirect marketers adapt marketing contracts and curtailment logic because the market premium lapses at negative prices.Typically affected: Direct marketing and remote control, Trading and procurement system (ETRM)
  • Plant operator (generation)role obligationPlant operators plan for zero support in quarter hours with negative prices on new plants and review dispatch, storage and curtailment.Typically affected: Plant master data and MaStR, Grid usage and customer billing

Past dates (10)

Passed due dates, closed consultations and decisions taken. Whatever continues as an obligation is listed under "Already in force" or as a deadline of its own.

Show all 10
Target31 December 2026

§ 14a control: target for working control

droppedPower gridMetering

Under the four-stage approach of Technical Study 2.0, working control with core processes for first use cases is due by the end of 2026. This is a target, not a statutory MsbG deadline.

  • Electricity grid operatorcheck applicabilityBuilds processes to send control commands to § 14a devices through the metering operator.Typically affected: Grid control system / SCADA, Market communication gateway (EDIFACT, AS4, API)
  • Default metering point operatorcheck applicabilitySets up control via smart meter gateway and control box for first § 14a use cases; the date is a target, not a statutory deadline.Typically affected: Gateway administration and CLS management, Market communication gateway (EDIFACT, AS4, API)

Linked to: Smart meter rollout: 90 percent of the installation cases since February 2025, MaKo format release, notice no. 56

Part of the bundle: Metering at year end

Comments by21 October 2026

Redispatch without balancing: consultation on cost reimbursement closes

Consultation · closedPower gridBalancingGeneration

Ruling Chamber 8 is consulting on how DSOs reimburse costs when redispatch measures are not specifically balanced. Comments are due by 21 October 2026, with the final ruling targeted by year end.

If the deadline is missed: No direct legal consequence Comments are voluntary. Anyone who submits nothing by 21 October 2026 can no longer bring objections into this consultation; Ruling Chamber 8 then publishes the final ruling. Legal basis ↗

  • Electricity grid operatoraffectedCan comment until 21 October and models which reimbursements arise without targeted balancing.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Balance responsible partycheck applicabilityAssesses how the reimbursement affects balancing groups.Typically affected: Trading and procurement system (ETRM)
  • Plant operator (generation)check applicabilityAssesses whether reimbursement for curtailed plants is calculated differently.Typically affected: Plant master data and MaStR

Linked to: Redispatch 2.0: choice of settlement method for 2027

Comments by16 October 2026

aFRR at the Czech border: consultation on the capacity method closes

Consultation · closedTSO

Ruling Chamber 6 is consulting on the proposal by the German, Austrian and Czech TSOs to amend the probabilistic method for cross-zonal capacity available for exchanging aFRR. Comments are due by 16 October 2026.

If the deadline is missed: No direct legal consequence Commenting is voluntary. Parties that do not comment by 16 October 2026 do not bring their objections into this procedure; only the method approved by the Federal Network Agency becomes binding. Legal basis ↗

Applicability: Concerns the control areas bordering the Czech Republic; the German-Austrian aFRR cooperation is not affected.

  • Transmission system operatorcheck applicabilityCan comment on the amendment proposal until 16 October and checks whether cross-border aFRR procurement at the Czech border changes.Typically affected: Grid control system / SCADA, Trading and procurement system (ETRM)
Due by15 October 2026

2027 network charges: publication by 15 October

Law · date passedPower gridGas gridSupplier

Electricity and gas distribution grid operators publish their 2027 network charges online. If the charges are not yet calculated on the cut-off date, operators publish the expected level derived from the revenue cap.

If the deadline is missed: Regulator can enforce Section 20 EnWG sets no penalty of its own for late publication. The regulator can order publication under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG; breaching the enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Legal basis ↗

  • Electricity grid operatorrole obligationPublishes 2027 electricity network charges by 15 October, if need be as expected values based on the revenue cap.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • Gas grid operatorrole obligationPublishes 2027 gas network charges by 15 October, if need be as expected values based on the revenue cap.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedFeeds the new network charges into 2027 pricing and customer communication.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities

Part of the bundle: Grid regulation and planning

Due by14 October 2026

Renewables grid cost pass-through: binding notification to the TSO

Regulatory ruling · date passedPower gridTSO

Distribution system operators with eligible extra costs from renewables integration submit their binding pass-through notification for 2027 to their transmission system operator. The deadline is the last working day before 15 October.

If the deadline is missed: Money is lost Under operative item 5(b) of ruling BK8-24-001-A, a late notification means the transmission system operator no longer reimburses the pass-through amount for 2027, and the figures can no longer be corrected. This also applies if only the notification to the regulator by 1 October was on time. Legal basis ↗

Applicability: Only DSOs claiming a particular burden from renewables connections under ruling BK8-24-001-A.

  • Electricity grid operatoraffectedDSOs with eligible renewables extra costs submit their 2027 pass-through amount to the TSO.Typically affected: Regulatory management, controlling
  • Transmission system operatoraffectedTSOs receive the notifications and include the amounts in the nationwide distribution.Typically affected: Regulatory management, controlling

Part of the bundle: Grid regulation and planning

Decision1 October 2026

MiSpeL: ruling on market integration of storage and charging points

Power gridMeteringSupplierStorageCharge points

The Federal Network Agency adopted the ruling on 1 October 2026 (ref. 618-25-02). A demarcation option and a flat-rate option set how volumes at storage units and charging points in mixed use are split for EEG support and levy privileges.

Regulatory ruling · adopted

If the deadline is missed: Money is lost Market premium and levy privileges for storage units and charging points in mixed use are only available if volumes are determined and proven under Annex 1 (demarcation option) or Annex 2 (flat-rate option) of the ruling (operative points 1 to 4). Until 30 September 2027 this requires the consent of the grid operator and the metering operator (point 9(a)). Legal basis ↗

Applicability: Concerns sites with storage or charging points that mix grid power and self-generated power. During the transition period up to the end of September 2027 both options need the consent of the grid operator and the metering operator, and the flat-rate option also needs state aid clearance for its legal basis.

  • Electricity grid operatoraffectedHandles the demarcation and flat-rate options for storage and charging points in its own grid and adapts metering setups and billing.Typically affected: EDM / MDM, Grid usage and customer billing
  • Default metering point operatoraffectedProvides the quarter-hourly metering the demarcation option requires at storage and charging sites.Typically affected: EDM / MDM, Field service and work orders
  • Suppliercheck applicabilityChecks how mixed use of storage feeds into balancing and customer billing.Typically affected: Grid usage and customer billing
  • Storage operatoraffectedChooses between the demarcation and the flat-rate option and clarifies which metering and evidence that choice requires.Typically affected: Plant master data and MaStR, EDM / MDM
  • Charge point operatorcheck applicabilityChecks whether charging points in mixed use fall under the options and what metering that needs.Typically affected: Charging backend (OCPP, PKI), EDM / MDM

Part of the bundle: Market communication and EDM wave

Comments by28 September 2026

Grid development scenarios 2027: end of the consultation

Consultation · closedPower gridGas grid

Distribution grid operators and municipal utilities can comment on the electricity and gas/hydrogen drafts. The assumptions frame the grid development plan.

If the deadline is missed: No direct legal consequence Commenting was voluntary. Anyone who submitted nothing by 28 September 2026 did not feed their assumptions into the 2027 scenario frameworks, which underpin the grid development plans. Legal basis ↗

  • Electricity grid operatoraffectedCould comment on load, generation and storage assumptions in the electricity scenario framework until 28 September 2026.Typically affected: Regulatory management, controlling
  • Gas grid operatoraffectedCould comment on the gas and hydrogen scenario framework that shapes how distribution grids are converted.Typically affected: Regulatory management, controlling
Comments by18 September 2026

AgNes: consultation on the grid charge reform closes

Consultation · closedPower grid

Comments on the new electricity grid charge system at the Grand Ruling Chamber; framework ruling by end of 2026.

If the deadline is missed: No direct legal consequence Comments were voluntary. Anyone who did not submit by 18 September 2026 can no longer bring objections into this consultation; the ruling is due to be adopted in 2026. Legal basis ↗

  • Electricity grid operatoraffectedCould comment on the draft electricity network charge framework until 18 September.Typically affected: Regulatory management, controlling
Comments by14 September 2026

Gas WACC: end of the consultation on the rate of return

Consultation · closedGas grid

Gas distribution grid operators can comment on the draft decision on the flat-rate return on capital. The 3.76 percent rate carries the revenue caps from 2028.

If the deadline is missed: No direct legal consequence Commenting was voluntary. Operators that did not comment by 14 September 2026 did not bring their objections into this procedure; the rate only becomes binding with the final decision. Legal basis ↗

  • Gas grid operatoraffectedCould comment on the draft until 14 September and models revenue caps from 2028 with the draft rate.Typically affected: Regulatory management, controlling
Due by31 December 2025

Smart meter rollout: 20 percent of the mandatory installation cases

Law · date passedMetering

Default metering point operators had to fit at least 20 percent of all metering points due for a smart metering system by the end of 2025. The Bundesnetzagentur opened supervisory proceedings against 434 companies that missed the quota, running since March 2026.

If the deadline is missed: Regulator can enforce If the default metering point operator misses the quota, the Federal Network Agency can order measures under Sections 45(2) and 76 MsbG and enforce them with coercive fines of EUR 1,000 to EUR 10 million (Section 76(4) MsbG, Section 94 EnWG); such proceedings have been running since March 2026. If the rollout of control units falls short by at least 25 percent and this contributes significantly to a possible threat to system security, it can withdraw the default responsibility under Section 12(2g) EnWG. Legal basis ↗

Applicability: The quota counts the mandatory cases under § 30 (1) nos. 2 to 5 and (2) MsbG, meaning final customers between 6,000 and 100,000 kilowatt hours a year plus controllable loads under § 14a EnWG. The basis is the total number of metering points across all grid areas covered by the default responsibility.

  • Default metering point operatorrole obligationShows the Bundesnetzagentur that at least 20 percent of mandatory installation cases carry a smart metering system, and works through any open supervisory proceeding.Typically affected: Gateway administration and CLS management, Field service and work orders, SAP IS-U / S/4HANA Utilities

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