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Deadline calendar: German energy transition

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Deadlines

Upcoming deadlines

178 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

26 deadlines
Due by15 November 2026

Federal Network Agency quarterly survey: report supplier switches and disconnections (15 February, May, August, November)

Power gridGas grid

Electricity and gas DSOs send the Federal Network Agency monthly data on supplier switches and disconnections via MonEDa, for each quarter by the 15th of the second following month at the latest; for the third quarter of 2026 by 15 November 2026, then 15 February, 15 May and 15 August. The survey form is filled in on a rolling basis and earlier quarters' values stay in it.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The page sets no specific consequence. Under Section 35(2) EnWG the powers of Section 69 apply to monitoring: the agency can demand the information by decision (Section 69(1) no. 1 and (7)) and enforce it with coercive fines under Section 94 EnWG; breaching an enforceable order under Section 69(7) sentence 1 is an administrative offence under Section 95(1) no. 3(a) EnWG (fine of up to EUR 100,000, Section 95(2) no. 5). Legal basis ↗

Applicability: All electricity and gas DSOs. The basis is the monitoring task under Section 35 EnWG. 15 November 2026 is a Sunday; the agency gives no substitute date.

  • Electricity grid operatorrole obligationExtracts the quarter's monthly switching and disconnection figures from the billing system and uploads the updated survey form to MonEDa.Typically affected: SAP IS-U / S/4HANA Utilities, Regulatory management, controlling
  • Gas grid operatorrole obligationReports monthly switching and disconnection figures for the gas network with the updated survey form via MonEDa.Typically affected: SAP IS-U / S/4HANA Utilities, 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. The Federal Network Agency takes up breaches of Section 41(5) EnWG under Section 65 EnWG: on 29 August 2025 it ordered one electricity supplier that had not informed final customers in a simple and understandable way (Section 41(5) sentences 1 and 3, not the one month period) to reverse price changes (case 522-4.07.01/8#1) and then imposed coercive fines of EUR 100,000 (31 March 2026) and EUR 175,000 (31 July 2026); the decisions are not yet final. 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

Comments by23 November 2026

KONNI 2.1: second consultation on a conversion fee from L-gas to H-gas closes

Consultation · openSupplierBalancing

Ruling Chamber 7 is consulting on a draft operative part and the amended standard conversion contract for the THE market area: from 1 April 2027 the market area manager would be allowed to charge balancing group managers a conversion fee in both directions, including from L-gas to H-gas, with seasonal factors and a cap of EUR 0.45/MWh for the short period to 30 September 2027. Comments are due by 23 November 2026.

If the deadline is missed: No direct legal consequence Comments are voluntary. Anyone who submits nothing by 23 November 2026 can no longer bring objections into this procedure; Ruling Chamber 7 then decides on the ruling taking effect on 1 April 2027. Legal basis ↗

Applicability: Only the THE market area spanning H- and L-gas. The ruling is addressed to the market area manager; the fee reaches balancing group managers through the balancing group contract.

  • Suppliercheck applicabilityChecks how a conversion fee from L-gas to H-gas changes procurement and pricing for L-gas customers from April 2027.Typically affected: Trading and procurement system (ETRM), Grid usage and customer billing
  • Balance responsible partyaffectedUnder the draft pays a conversion fee from April 2027 also for quantities balanced across qualities from L-gas to H-gas, and can comment on the draft until 23 November.Typically affected: Trading and procurement system (ETRM)
Due by30 November 2026

Redispatch 2.0: choice of settlement method for 2027

Power gridBalancingDirect marketingGeneration

Under BK6-23-241 (BilAReM section 3.2.1), operators of wind and solar plants from 100 kW set 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 unless feed-in is not metered quarter-hourly.

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, and beyond that without quarter-hourly metering. The assignment holds for the whole following year. Legal basis ↗

Applicability: Operators of wind and solar plants from 100 kW in negative 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 obligations are missed by at least 25 percent in a way that could significantly endanger system security in a control area, 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 by30 November 2026

EEG: report a change of sales form for 1 January 2027 by end of November

Power gridDirect marketingGeneration

Plant operators must notify the network operator before the start of the preceding calendar month if they first sell in a form under Section 21b EEG or switch between forms, including the balancing group (Section 21c(1) EEG). For a switch on 1 January 2027 that is 30 November 2026; the rule applies to every month change.

Law · adopted

If the deadline is missed: Money is lost Anyone not notifying the assignment or switch under Section 21c pays the network operator EUR 10 per kilowatt of installed capacity for each calendar month of the breach and additionally for the following month (Section 52(1) no. 9, (2) and (4) no. 2 EEG). The claim to a payment for decentralised feed-in under Section 18 StromNEV is also lost for the whole calendar year (Section 52(7) EEG). Legal basis ↗

  • Electricity grid operatoraffectedProcesses switch notifications and reassigns installations as of the first of the month.Typically affected: Market communication gateway (EDIFACT, AS4, API), Grid usage and customer billing
  • Direct marketeraffectedTriggers the switch notification for newly contracted installations in time before the preceding month.Typically affected: Trading and procurement system (ETRM), Market communication gateway (EDIFACT, AS4, API)
  • Plant operator (generation)role obligationNotifies the network operator by 30 November 2026 of a switch into direct marketing or between sales forms as of 1 January 2027.Typically affected: Plant master data and MaStR
Due by1 December 2026

EEG first-segment solar tender: bid deadline 1 December 2026

Direct marketingGeneration

Bids for first-segment solar plants (ground-mounted and on structures that are neither buildings nor noise barriers) must reach the Federal Network Agency by the bid date. According to the agency, the volume is about 2,226 MW and the ceiling price 5.53 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 first-segment solar plants under Section 3 no. 41a EEG above 1 MW. The maximum bid size is 20 MW as long as state aid approval for 50 MW is missing.

  • 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 by2 December 2026

Gas network charges 2027: final charges along the cascade (2, 12 and 16 December)

Gas grid

Under the gas cooperation agreement, gas TSOs publish their final charges for the following year by 2 December, distribution system operators directly downstream of a TSO that themselves have downstream networks by 12 December, and all other downstream DSOs by 16 December (KoV Section 6 nos. 5 and 6). The provisional charges go to downstream operators in text form by 30 September, 6 October and 10 October.

Technical rule · adopted

If the deadline is missed: Regulator can enforce The cooperation agreement is a contract among gas network operators; Section 20(1b) sentence 5 EnWG obliges them to cooperate within it. The agreement sets no specific sanction for the missed date. The regulator can enforce the duty to cooperate under Section 65 EnWG. Legal basis ↗

Applicability: Applies to gas network operators that apply the gas cooperation agreement. The level (transmission, directly downstream, further downstream) determines the date. The deadline under Section 20(1) EnWG of 15 October applies alongside.

  • Gas grid operatorrole obligationIncorporates the final upstream charges and publishes its own final 2027 charges by 2, 12 or 16 December 2026 depending on its level.Typically affected: Regulatory management, controlling, Grid usage and customer billing, Customer and grid connection portal

Linked to: 2027 network charges: publication by 15 October

Due by29 December 2026

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

Generation

On 29 December 2026 the Federal Network Agency auctions further long-duration capacity, in principle 4.5 gigawatts; the exact volume follows from the announcement due on 10 November 2026. 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, existing plants and plants with an investment decision before notification and commissioning by 4 August 2029 only 20 years after commissioning. 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

Building owners retrofit or replace heat and hot water meters and heat cost allocators that cannot be read remotely and were installed up to 1 December 2021, or later as a replacement or addition within a system that is not remotely readable (Section 5(2) sentence 4 HeizkostenV), by the end of 2026 (Section 5(3) HeizkostenV). The same duty applies to a heat supplier that bills occupants directly by their share of total consumption (Section 1(3) HeizkostenV).

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. Sections 4 to 11 HeizkostenV are consumer protection laws under Section 2(2) no. 40 UKlaG, so associations can seek injunctions against breaches. Legal basis ↗

Applicability: The Heating Costs Ordinance applies to building owners and those treated as such (Section 1(2)), and to heat suppliers only where they bill occupants directly by share of total consumption (Section 1(3)). It does not apply where retrofitting is technically impossible or would cause undue hardship (Section 5(3) sentence 2). Heat suppliers' own retrofit duty under the FFVAV is a separate deadline.

  • Heat network operatorcheck applicabilityChecks for contracting and direct billing of occupants whether the building owner's retrofit duty lies with the heat supplier.Typically affected: Field service and work orders, Grid usage and customer billing
  • 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

For final consumers in the cases of Section 30(1) nos. 2 to 5 and (2) MsbG, i.e. with annual consumption above 6,000 up to 100,000 kWh, with an agreement under Section 14a EnWG or with a control unit at the grid connection point, default metering point operators must have equipped at least 90 percent of the metering points that have fallen due since 25 February 2025 by the end of 2026 (Section 45(1) sentence 1 no. 4(b) MsbG). For final consumers above 100,000 kWh the quota only starts in 2028 (no. 3). According to its press release, the Bundesnetzagentur collects progress twice a year; its supervisory proceedings since March 2026 concern the 20 percent quota for the end of 2025 (no. 4(a)).

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 heat networks not fed entirely by renewable heat or unavoidable waste heat submit the roadmap. Targets under Section 29 WPG: at least 30 percent renewable heat or unavoidable waste heat from 2030, 80 percent from 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: Exempt are heat networks already fed entirely by renewable heat, unavoidable waste heat or a combination, networks up to 1 km long, and networks with a BEW transformation plan or BEW feasibility study for which a module 1 application was filed by the end of 2025 or which are approved by final decision under module 2 by the end of 2026. 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 from plants above 7 and up to 100 kilowatts

Power gridMetering

By the end of 2026 default metering point operators must have equipped at least 90 percent of the capacity of plants above 7 and 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 equipping under Section 29(1) no. 2 MsbG (smart metering systems with control units) falls short of the quotas by at least 25 percent and this could contribute significantly to a 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 above 7 and 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 gridGas gridTSO

Electricity and gas network operators apply to the competent regulator for approval of their 2025 regulatory account balance by 31 December 2026.

Law · adopted

If the deadline is missed: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: All network operators under incentive regulation, including the simplified procedure (Section 24(3) ARegV does not exclude Section 4(4)). Depending on the operator, the Federal Network Agency or the state regulator is competent.

  • Electricity grid operatorrole obligationFiles the 2025 regulatory account application with the competent regulator.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Gas grid operatorrole obligationFiles the application for approval of the 2025 regulatory account balance 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

Due by31 December 2026

FFVAV: make district heating meters remotely readable by the end of 2026

Heat network

District heating and cooling suppliers retrofit meters installed before 5 October 2021 that cannot be read remotely by 31 December 2026, or replace them with remotely readable ones (Section 3(3) FFVAV). Meters installed after 5 October 2021 must already be remotely readable.

Law · adopted

If the deadline is missed: Civil-law consequence The FFVAV contains neither a fine provision nor a regulator's competence; the duty applies within the supply contract with the customer (Section 1(1) FFVAV). Sections 3 to 5 FFVAV are consumer protection laws under Section 2(2) no. 40 UKlaG, so associations can bring injunction and removal claims against heat suppliers. Legal basis ↗

Applicability: Applies to companies supplying customers with district heating or cooling, including supply relationships under public law (Section 1 FFVAV). Where the meter is connected to a smart meter gateway, setup and billing of metering follow the MsbG (Section 3(6) FFVAV).

  • Heat network operatorrole obligationRetrofits or replaces heat meters at the transfer points installed before 5 October 2021 that cannot be read remotely, by year end.Typically affected: Field service and work orders, EDM / MDM

Part of the bundle: Metering at year end

Due by31 December 2026

Small electricity DSOs: notify charging points and stop operating them

Power grid

Electricity distribution system operators with fewer than 100,000 customers connected directly or indirectly to their network must notify the Federal Network Agency in text form of their activities relating to charging points they already developed, managed or operated before 27 July 2021, and cease them by the end of 31 December 2026, unless the agency has granted approval under Section 7c(2) EnWG beforehand (Section 118(34) sentences 1 to 4 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce From 1 January 2027 these charging points no longer count as approved; continuing to operate them breaches Section 7c(1) EnWG. The Federal Network Agency can order operations to stop under Section 65 EnWG and enforce this with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Only electricity distribution system operators under Section 7(2) sentence 1 EnWG (vertically integrated undertakings with fewer than 100,000 customers connected directly or indirectly to their electricity distribution network) and only charging points they developed, managed or operated before 27 July 2021. For larger DSOs the deadline ended on 31 December 2023.

  • Electricity grid operatorrole obligationNotifies the Federal Network Agency of its own charging points from before 27 July 2021 and stops or transfers their operation by 31 December 2026 unless approval under Section 7c(2) has been granted.Typically affected: Charging backend (OCPP, PKI), Regulatory management, controlling
Due by31 December 2026

Biogas grid connection: last day for the advance payment under the old rules

Gas grid

For a grid connection request for a biogas upgrading plant, the special rules of Section 33(1) to (9) GasNZV as in force until the end of 2025 only continue to apply if the connecting party's advance payment under Section 33(5) sentence 1 GasNZV has reached the gas network operator by the end of 31 December 2026 (Section 118(4) EnWG). Otherwise Section 17 EnWG governs the connection.

Law · adopted

If the deadline is missed: Exclusion or loss of role If the advance payment arrives after 31 December 2026, the connection request falls outside the transitional rule in Section 118(4) EnWG; the connection is then governed by Section 17 EnWG instead of the old Section 33 GasNZV. Legal basis ↗

Applicability: Concerns gas network operators with open connection requests for biogas upgrading plants. The connecting party makes the payment; the network operator must be able to document its receipt.

  • Gas grid operatoraffectedSorts open connection requests for biogas upgrading plants by whether the advance payment arrived by 31 December 2026 and applies the old rules or Section 17 EnWG accordingly.Typically affected: Regulatory management, controlling, Grid usage and customer billing
Due by31 December 2026

Delete or anonymise personal metering data (MsbG maximum periods)

Power gridMeteringCompetitive meteringSupplier

Metering point operators must delete or anonymise personal metering data no later than three years after the end of the year of collection, i.e. data from 2023 by the end of 2026 (Section 60(6) MsbG). Network operators keep data used for network operation, planning and forecasts and for the concession fee for at most one year after the end of the year of collection (Section 66(3) sentence 2 no. 1), suppliers likewise for energy volume forecasts (Section 69(3) sentence 2 no. 1); for data collected in 2025 this period ends on 31 December 2026. For other purposes three years apply unless a Federal Network Agency determination provides otherwise.

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG sets no administrative offence. The Federal Network Agency can order measures under Section 76 MsbG and enforce them with coercive fines under Section 94 EnWG (Section 76(4) MsbG). Legal basis ↗

Applicability: Maximum periods: data must be deleted earlier as soon as they are no longer needed for the task. The Federal Network Agency can set different periods (Section 47(2) no. 13, Section 75 MsbG); the part on metering data processing in the MaBiS hub proceedings has not been adopted yet.

  • Electricity grid operatorrole obligationDeletes or anonymises 2025 data held for network operation, planning, forecasts or the concession fee by 31 December 2026; other data from 2023.Typically affected: EDM / MDM, SAP IS-U / S/4HANA Utilities, ISMS and security operations
  • Default metering point operatorrole obligationDeletes or anonymises personal metering data from 2023 by 31 December 2026 unless no longer needed earlier.Typically affected: EDM / MDM, Gateway administration and CLS management, ISMS and security operations
  • Competitive metering point operatorrole obligationDeletes or anonymises personal metering data from 2023 by 31 December 2026 unless no longer needed earlier.Typically affected: EDM / MDM, Gateway administration and CLS management, ISMS and security operations
  • Supplierrole obligationDeletes or anonymises 2025 data held only for energy volume forecasts by 31 December 2026; other data from 2023.Typically affected: EDM / MDM, SAP IS-U / S/4HANA Utilities, ISMS and security operations
Due by31 December 2026

Electricity and energy tax: choose monthly or annual filing for 2027

SupplierGeneration

Suppliers liable for electricity or energy tax decide how they file for 2027. For electricity annual filing is the default; anyone wanting monthly filing declares this to the main customs office by 31 December 2026 (Section 8(2) StromStG). For natural gas monthly filing is the default; annual filing must be declared in writing before the calendar year starts and applies for full calendar years until revoked (Section 39(1) and (2) EnergieStG).

Law · adopted

If the deadline is missed: No direct legal consequence Without a timely declaration the default applies: electricity tax is filed annually (Section 8(2) StromStG), energy tax on natural gas monthly (Section 39(1) EnergieStG). Legal basis ↗

  • Suppliercheck applicabilityDecides on monthly or annual tax filing for 2027 and submits the declaration to the main customs office by 31 December 2026.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing
  • Plant operator (generation)check applicabilityAs a self-generator liable for electricity tax, decides on the 2027 filing method and files any declaration for monthly filing with the main customs office by 31 December 2026.Typically affected: Plant master data and MaStR, Grid usage and customer billing
Due by31 December 2026

KWKG: apply for approval of CHP plants in continuous operation since 2025

GenerationHeat network

Operators of CHP plants that started continuous operation in 2025 apply for approval to the Federal Office for Economic Affairs and Export Control by 31 December 2026. It then takes effect from the start of continuous operation (Section 11(3) sentence 1 KWKG); the same applies after modernisation or retrofitting.

Law · adopted

If the deadline is missed: Money is lost If the application is filed later, the approval is only granted retroactively to 1 January of the year of application (Section 11(3) sentence 2 KWKG); no surcharge is paid for the time before. Legal basis ↗

Applicability: Applies to CHP plants outside the auction segment. For plants with an auction award, the award lapses if the plant is not approved within twelve months of starting continuous operation (Section 18(2) KWKAusV).

  • Plant operator (generation)role obligationFiles the approval application for CHP plants in continuous operation since 2025 by 31 December 2026.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Heat network operatoraffectedChecks whether own CHP plants in the heat network started continuous operation in 2025.Typically affected: Plant master data and MaStR
Due by31 December 2026

Heat networks: notify complex measure by end of 2026, otherwise 30 percent from 2030

Heat network

Heat network operators that want to use the deferral of the 30 percent obligation because of a complex measure must notify the competent state authority of it by the end of 31 December 2026 and must have started construction by the end of 31 December 2027 (Section 29(3) WPG).

Law · adopted

If the deadline is missed: Exclusion or loss of role Without timely notification and start of construction the deferral is lost; the 30 percent obligation then applies from 1 January 2030 under Section 29(1) no. 1 WPG. The WPG contains no fine. Legal basis ↗

  • Heat network operatorrole obligationDecides whether a major project (such as a large heat pump or geothermal plant) is notified as a complex measure and files the notification with the state authority by 31 December 2026.Typically affected: Plant master data and MaStR, Regulatory management, controlling

Linked to: Heat networks: at least 30 percent renewable heat or waste heat from 2030

Due by31 December 2026

Gas TSOs: publish revenue information under Annex I of the Gas Regulation

Gas grid

Gas transmission system operators publish each year before 1 January the information under Annex I point 1 of Regulation (EU) 2024/1789 on the methods, parameters and values used to set their regulated revenues, accessibly and in German and English on their website (BK9-25/617, operative points 1, 3 and 4).

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Only gas transmission system operators, not gas distribution system operators.

  • Gas grid operatorrole obligationAs a gas TSO, publishes the Annex I revenue information by 31 December for the following year, in German and English.Typically affected: Regulatory management, controlling, Customer and grid connection portal

Q1 2027

32 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 joint procedure rules for transmission grid connections to the Federal Network Agency, which may include prioritisation principles; distribution system operators may adopt them. Operators with an extra-high/high or high/medium voltage transformation level show the connection capacity available there on a map every month (Section 17c(1) draft EnWG); the electronic enquiry procedure from 135 kilowatts only arrives in 2028 under the draft.

If the deadline is missed: Fine possible 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. Under the draft, a breach of the new network operator duties (Sections 17a and 17c EnWG draft) would also be an abuse of market position under Section 30(1) sentence 2 no. 1 EnWG, as these provisions sit in Part 3 Division 2 EnWG. The regulator could require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorcheck applicabilityMay adopt the transmission operators' prioritisation principles for connection requests; with a high/medium voltage transformation level it publishes the connection capacity available there on a map every month. 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 for transmission grid connections to the Federal Network Agency by 1 January 2027 and may include prioritisation principles; 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): transition payment instead of a feed-in tariff for new small systems

Law · not yet adoptedPower gridMeteringSupplier

Under the government draft, subject to the Bundestag's decision and EU state aid approval: new systems no longer receive a feed-in tariff, and the market premium only starts at 25 kW. Instead the grid operator pays a temporary transition payment for at most 36 months, for systems below 50 kW commissioned in 2027, below 25 kW commissioned in 2028 and below 7 kW commissioned in 2029 or 2030. Systems below 25 kW in other direct marketing receive 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 (Bundestag printed paper 21/8298, no. 54).

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

MeteringCompetitive 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
  • Competitive metering point operatorrole obligationMoves its own 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. According to the BSI, gateways under TR v1.1 and protection profile v1.3 may still be installed until 31 December 2027 as a transitional measure.

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; under the BSI transitional rule, gateways under TR v1.1 and protection profile v1.3 may still be installed until 31 December 2027. 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 under Section 11(3) sentence 1 no. 3 MsbG, i.e. the operator with the most smart metering systems nationwide, together with the operators that declared readiness under sentence 1 nos. 1 and 2. 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 from1 January 2027

EEG 2027 (government draft): refinancing contribution for new plants from 100 kW

Law · not yet adoptedPower gridGeneration

Under the government draft, subject to the Bundestag's decision and EU state aid approval: operators of new plants from 100 kW with an award or a notification under Section 20(2) EEG pay the grid operator a refinancing contribution per kilowatt hour fed in for years in which the annual market value exceeds the applicable value. The grid operator collects it with monthly instalments due on the 15th of the following month, and it falls due four weeks after the final statement reaches the plant operator.

If the deadline is missed: Regulator can enforce Under the draft, the Federal Network Agency monitors that payments under Section 21d are properly determined, collected and received (Section 85(1) no. 3(d) EEG draft). Breaching an enforceable order under Section 85(3) EEG in conjunction with Section 65 EnWG is an administrative offence under the current Section 86(1) no. 3 EEG (up to EUR 200,000). Legal basis ↗

Applicability: Under the draft only plants from 100 kW with an award or a notification under Section 20(2) EEG that are commissioned from 1 January 2027 and, where awarded, won their award in a bid round from 2027; biomass plants other than sewage and landfill gas plants are exempt.

  • Electricity grid operatorcheck applicabilityPrepares collection, instalments and final statements for the refinancing contribution in EEG settlement; the bill may still change in parliament.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities
  • Plant operator (generation)check applicabilityFactors the refinancing contribution for new plants with a market premium into business cases; status government draft.Typically affected: Plant master data and MaStR
Due by1 January 2027

WaKandA: publish an overview of the hydrogen clusters

Gas grid

Operators of regulated hydrogen networks publish, by 1 January 2027 on a joint website, an overview of the clusters in the hydrogen market area, the connections between them with their capacity and the status of planned cluster connections. The overview is updated quarterly.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce No specific administrative offence is listed. The regulator can enforce compliance by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG; failing to comply with an enforceable order under Section 65(1) or (2) is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Only operators of hydrogen networks within Part 3 Section 3b EnWG: the hydrogen core network, hydrogen infrastructure confirmed under Section 15d(3) sentence 1 EnWG, or operators that opted in under Section 28j(3) EnWG. Gas network operators without a hydrogen network are not covered.

  • Gas grid operatorcheck applicabilityChecks whether its own hydrogen network falls under the determination and then supplies cluster and capacity data for the joint overview.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
Applies from1 January 2027

Federal subsidy for transmission network costs 2027 to 2029

Law · not yet adoptedPower gridTSOSupplier

Under the government bill, transmission system operators receive a subsidy of EUR 5.525 billion a year for 2027 to 2029 (Section 24d draft EnWG) that lowers transmission network charges; the Bundesrat calls for EUR 6.5 billion, so the amount is open. Transmission system operators publish their charge with and without the subsidy, distribution system operators also publish a notional network charge without it, and suppliers point out the subsidy on the bill (Section 118(5b) draft EnWG).

If the deadline is missed: Regulator can enforce The bill does not provide for a specific administrative offence. The regulator can enforce the publication duties by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Applies only if the act is passed as in the government bill. The act enters into force on the day after promulgation; 1 January 2027 is the start of the period the subsidy and duties cover.

  • Electricity grid operatorcheck applicabilityUnder the bill, prepares a notional network charge without the subsidy for publication alongside the 2027 charge.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Transmission system operatorcheck applicabilityCalculates the 2027 transmission charges including the subsidy and, under the bill, publishes them with and without it.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Suppliercheck applicabilityUnder the bill, plans the subsidy notice on the bill and allows for the risk of higher final charges.Typically affected: Grid usage and customer billing
Due by1 January 2027

Report the revenue cap adjustment and the network charge adjustment (Section 28 ARegV)

Power gridGas grid

Network operators report to the regulator on 1 January the adjustment of the revenue cap under Section 4(3) ARegV with the underlying changes in cost shares, and the adjustment of network charges (Section 28 sentence 1 nos. 1 and 4 ARegV); operators with investment measures under Section 23 report their status on the same day (no. 6). In 2027 the date falls on New Year's Day.

Law · adopted

If the deadline is missed: Fine possible Section 28 ARegV sets no specific administrative offence. The regulator can order the report under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Applies as long as ARegV is applicable. For electricity the RAMEN Strom determination (para. 4.2 sentence 3) continues the 1 January report from 2029; for gas the RAMEN Gas determination governs the procedure from 2028.

  • Electricity grid operatorrole obligationReports the adjusted revenue cap with the changed cost shares and the network charge adjustment to the regulator.Typically affected: Regulatory management, controlling
  • Gas grid operatorrole obligationReports the adjusted revenue cap with the changed cost shares and the network charge adjustment to the regulator.Typically affected: Regulatory management, controlling
Due by1 January 2027

TSOs' system stability report (Section 12i EnWG)

TSO

TSOs with control area responsibility report to the regulator every two years on the security, reliability, stability and performance of their network and of the electricity supply system, after 2025 again on 1 January 2027 (Section 12i(1) EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 12i EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

  • Transmission system operatorrole obligationSubmits the system stability report with status and needs for action per area of system stability.Typically affected: Grid control system / SCADA, Regulatory management, controlling
Applies from1 January 2027

Section 14a: exemption for non-controllable devices ends with 2026 commissioning

Power gridGeneration

For controllable consumption devices that demonstrably cannot be controlled and cannot be made controllable at reasonable cost, paragraphs 3 to 5 of determination BK6-22-300 only do not apply if they are commissioned by 31 December 2026 (Annex 1 para. 10.6). For commissioning from 2027 participation in grid-oriented control and the ban on refusing or delaying the connection for lack of grid capacity apply without this exemption.

Regulatory ruling · adopted

If the deadline is missed: Fine possible BK6-22-300 sets no specific sanction. The regulator can order compliance under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationChecks for registrations from 2027 that every new controllable device is connected as controllable and keeps cases under para. 10.6 separately.Typically affected: Customer and grid connection portal, SAP IS-U / S/4HANA Utilities, Regulatory management, controlling
  • Plant operator (generation)affectedAs operator of a controllable consumption device, such as a storage unit or heat pump, sets out to the network operator that control is technically impossible and proves it where necessary; the exemption only applies to commissioning by 31 December 2026.Typically affected: Plant master data and MaStR

Linked to: § 14a EnWG: end of the transition period

Applies from1 January 2027

Offer a fixed-price contract: suppliers with more than 200,000 customers on 31 Dec 2026

Supplier

Electricity suppliers that supply more than 200,000 final consumers at the end of 31 December of a year must also offer a fixed-price contract in the following year with a binding term of at least twelve months and a fixed price for the supplier component (Section 41a(4) EnWG). For 2027 the customer count on 31 December 2026 decides.

Law · adopted

If the deadline is missed: Regulator can enforce Section 41a EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Only electricity suppliers with more than 200,000 final consumers supplied on 31 December of the previous year; the test repeats every year. Suppliers offering only dynamic tariffs are exempt (Section 41a(5) EnWG).

  • Suppliercheck applicabilityCounts final consumers supplied on 31 December 2026; above 200,000 it keeps a fixed-price product with at least twelve months' term on offer in 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Customer and grid connection portal
Applies from1 January 2027

Methane Regulation: importers prove equivalent monitoring at producer level

SupplierCompany-wide

From 1 January 2027 importers prove that supply contracts for natural gas, crude oil or coal from third countries concluded or renewed since 4 August 2024 only cover volumes whose production is subject to equivalent monitoring, reporting and verification (Article 28(1) Regulation (EU) 2024/1787).

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. The Commission recommends that member states do not apply the penalties under Article 33(5)(m), (n) and (o) to importers' breaches of the obligations for 2027, 2028 and 2029, except in cases of fraud (Recommendation (EU) 2026/1835); the obligation itself remains. There is no German implementing act yet; the ministerial draft is still being coordinated within the federal government (Bundestag printed paper 21/8334). Legal basis ↗

Applicability: Only undertakings that import natural gas, crude oil or coal from third countries into the Union (importers under Regulation (EU) 2024/1787). Suppliers buying on the wholesale market inside the Union are not importers.

  • Suppliercheck applicabilityChecks import contracts since 4 August 2024 for equivalent MRV evidence from producers and reports it from 2027.Typically affected: Trading and procurement system (ETRM)
  • Company-wide, several rolescheck applicabilityAs an importer, proves equivalent monitoring from 2027.Typically affected: Trading and procurement system (ETRM)
Due by15 January 2027

Guarantee of origin register: report feed-in data by form (15 January, May, September)

Power grid

Network operators that do not send feed-in data of registered installations to the guarantee of origin register automatically report them by 15 January, 15 May and 15 September at the latest for the preceding period (Section 41(4) sentence 1 HkRNDV).

Law · adopted

If the deadline is missed: Fine possible Failing to transmit the data, or transmitting them incorrectly, incompletely, in the wrong way or late, is an administrative offence (Section 48(2) no. 1 HkRNDV with Section 86(1) no. 4(c) EEG). Legal basis ↗

Applicability: Only network operators that do not transmit feed-in data to the register automatically.

  • Electricity grid operatorrole obligationReports feed-in volumes of registered installations for the last third of 2026 by 15 January 2027 unless automated transmission is in place.Typically affected: EDM / MDM, Grid usage and customer billing
Due by15 January 2027

Electricity and energy tax: estimate of 2027 annual tax by 15 January

Supplier

Suppliers with annual returns and advance payments send the main customs office, by 15 January, a sound and traceable estimate of the expected annual tax; below 2,400 euros no notice is needed. On 30 June they estimate again and report by 15 August if the new estimate exceeds 100,000 euros and exceeds the set advance payments by more than 20 per cent (Section 8(6) StromStG, Section 39(5) EnergieStG).

Law · adopted

If the deadline is missed: Fine possible Failing, intentionally or recklessly, to make a notice under Section 8(6) sentences 4 to 7 StromStG, or making it incorrectly or late, is an administrative offence with a fine of up to 5,000 euros (Section 14(1) no. 1 and (2) StromStG). The same applies to natural gas via Section 64 EnergieStG with Section 381 AO. Legal basis ↗

  • Supplierrole obligationEstimates 2027 electricity and gas tax from sales planning and reports it by 15 January 2027; checks the deviation as of 30 June.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing

Linked to: Electricity and energy tax: choose monthly or annual filing for 2027

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.

Law · adopted

If the deadline is missed: No direct legal consequence No sanction attaches to the auction date. Obligated entities under Section 7(2) TEHG must first surrender allowances by 31 May 2029 for 2028 emissions (Art. 30k(2)(d) Directive 2003/87/EC in conjunction with Regulation (EU) 2026/667), then annually by 31 May; 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 byexpected 31 January 2027, date open

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, date open

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

Due by31 January 2027

Negative prices: TSOs publish zero-value periods of 2026

TSOGeneration

TSOs publish by 31 January on a joint website the number of quarter-hours and hours of the previous year in which the applicable value fell to zero because of negative prices (Section 51a(4) EEG). Plant operators and direct marketers need these figures for the extension of the support period under Section 51a.

Law · adopted

If the deadline is missed: Regulator can enforce The EEG sets no specific sanction. The Federal Network Agency monitors the TSOs' duties and can order remedies under Section 85(3) EEG with Section 65 EnWG. Legal basis ↗

  • Transmission system operatorrole obligationDetermines the 2026 zero-value quarter-hours and hours and publishes them by 31 January 2027.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • Plant operator (generation)affectedUses the published figures to check the support period extension under Section 51a EEG.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by1 February 2027

EEG tender solar second segment (rooftop): bid date 1 February 2027

Direct marketingGeneration

Bids must reach the Federal Network Agency by the bid date; the dates are set by law (Section 28b(1) EEG): 1 February, 1 June and 1 October, until 2029.

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); 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: Volume: without state aid approval of Solar Package I, the Federal Network Agency applies Section 28b(2) EEG as in force on 15 May 2024; for 2026 that meant 1,100 MW instead of the statutory 2,300 MW. For 2027 the volume depends on the approval and on the EEG 2027.

  • Direct marketercheck applicabilityPrepares marketing of awarded rooftop systems.Typically affected: Direct marketing and remote control, Trading and procurement system (ETRM)
  • Plant operator (generation)check applicabilityAssesses participation and bid value for larger rooftop systems.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by5 February 2027

Methane Regulation: emissions report for non-operated assets

Gas gridStorage

Operators and undertakings in gas transmission, gas distribution, underground storage and LNG submit by 5 February 2027 a report quantifying source-level methane emissions for non-operated assets (Article 12(2)(b) Regulation (EU) 2024/1787). For operated assets the deadline was 5 February 2026.

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. Legal basis ↗

Applicability: Operators and undertakings in gas transmission, gas distribution, underground storage and LNG within the scope of Article 1 of Regulation (EU) 2024/1787.

  • Gas grid operatorrole obligationAs a gas distribution or transmission operator, reports source-level methane emissions of non-operated assets by 5 February 2027.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
  • Storage operatorrole obligationAs an underground storage operator, reports for non-operated assets by 5 February 2027.Typically affected: Plant master data and MaStR
Due by5 February 2027

Methane Regulation: verified report with site-level measurements

Gas gridStorage

Operators and undertakings in gas transmission, gas distribution, underground storage and LNG submit by 5 February 2027 a report on source-level methane emissions with site-level measurements for operated assets, assessed by a verifier, then each year by 31 May (Article 12(3) Regulation (EU) 2024/1787). For non-operated assets the German version gives 5 February 2028, while the English and other language versions give 5 August 2028.

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. Legal basis ↗

Applicability: Operators and undertakings in gas transmission, gas distribution, underground storage and LNG within the scope of Article 1 of Regulation (EU) 2024/1787.

  • Gas grid operatorrole obligationCarries out site-level measurements, has the report verified and submits it by 5 February 2027, then each year by 31 May.Typically affected: Grid planning, GIS, load flow, Field service and work orders
  • Storage operatorrole obligationSubmits the verified report for underground storage by 5 February 2027, then each year by 31 May.Typically affected: Plant master data and MaStR
Due by28 February 2027

EEG: data for the 2026 final settlement to the network operator (28 February)

Power gridDirect marketingGeneration

Plant operators provide the network operator by 28 February with all data needed for the final settlement of the previous year, per installation (Section 71(1) no. 1 EEG), i.e. for 2026 by 28 February 2027. In direct marketing these data often come from the direct marketer in practice.

Law · adopted

If the deadline is missed: Money is lost The plant operator's payment claim only falls due once and insofar as it has met its data obligations under Section 71(1) EEG (Section 26(2) EEG). Legal basis ↗

  • Electricity grid operatoraffectedCollects the data by 28 February and needs them for the final settlement to the TSO by 31 May.Typically affected: Grid usage and customer billing
  • Direct marketeraffectedProvides settlement data for the installations it markets where it supplies them on the plant operator's behalf.Typically affected: Trading and procurement system (ETRM)
  • Plant operator (generation)role obligationProvides the network operator with per-installation data for the 2026 final settlement by 28 February 2027.Typically affected: Plant master data and MaStR

Linked to: EnFG: final settlement of EEG and KWKG payments for 2026 to the TSO

Due by28 February 2027

Biomass: prove feedstock logbook and environmental expert report for 2026

Generation

Operators of biomass plants receiving EEG payments prove by 28 February for the previous year, where applicable, the share of electricity from liquid biomass with a copy of the feedstock logbook and the conditions of Section 44b(2) or Section 44c(4) or (5) with an environmental expert report (Section 44c(2) and (6) EEG).

Law · adopted

If the deadline is missed: Money is lost Without proof in the prescribed form, the claim to the market premium or feed-in tariff for biomass electricity falls to the market value for the whole calendar year (Section 44c(8) EEG). Legal basis ↗

  • Plant operator (generation)role obligationCompiles the 2026 feedstock logbook and expert report and submits them to the network operator by 28 February 2027.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Applies from1 March 2027

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

Power gridCompetitive metering

The 2026-03 edition replaces the 2018-11 edition. The end of the transition period on 1 March 2027 does not come from the standards body; according to VDE FNN, certificates under the 2018-11 edition remain sufficient until one of two periods expires: 12 months after DIN VDE V 0124-100 takes effect or 24 months after the application rule took effect. Technical connection conditions, notification forms (F.1.1, F.1.2) and the connection assessment up to 500 kW must be switched to the new edition.

Technical rule · adopted, date open

If the deadline is missed: Fine possible The rule is not a statute and carries no penalty of its own; according to VDE FNN it has been a technical safety rule since the procedure under Federal Network Agency determination BK6-23-037 (Section 49(2) sentence 2 EnWG), and complying with it creates a presumption of compliance with recognised engineering standards (Section 49(2) sentence 1 EnWG). 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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 operatoraffectedAligns metering concepts with feed-back capable charging equipment treated as storage.Typically affected: Grid usage and customer billing
Due by31 March 2027

Report customer numbers and federal states to the regulators

Power gridGas grid

Network operators report to the Federal Network Agency and the competent state regulator by 31 March the number of customers connected on 31 December of the previous year and the federal states in which their electricity or gas distribution network is located (Section 28 ARegV).

Law · adopted

If the deadline is missed: Fine possible No specific administrative offence is listed. The regulator can enforce compliance by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Applies as long as ARegV is applicable; the fifth regulatory period under the NEST determinations starts in 2028 for gas and 2029 for electricity.

  • Electricity grid operatorrole obligationReports the year-end customer count and the federal states of its electricity network to the federal and state regulators.Typically affected: Regulatory management, controlling, SAP IS-U / S/4HANA Utilities
  • Gas grid operatorrole obligationReports the year-end customer count and the federal states of its gas network to the federal and state regulators.Typically affected: Regulatory management, controlling, SAP IS-U / S/4HANA Utilities
Due by31 March 2027

Submit and publish the DSO compliance report

Power gridGas grid

The compliance officer of a distribution system operator belonging to a vertically integrated undertaking submits to the regulator by 31 March each year a report on the compliance programme measures of the previous year and publishes it without personal data (Section 7a(5) sentence 3 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 7a EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Not affected are DSOs of vertically integrated undertakings with fewer than 100,000 directly or indirectly connected customers (Section 7a(7) EnWG), separately for electricity and gas.

  • Electricity grid operatorrole obligationHas the compliance officer prepare the report on 2026, submits it to the regulator and publishes it.Typically affected: Regulatory management, controlling
  • Gas grid operatorrole obligationHas the compliance officer prepare the report on 2026, submits it to the regulator and publishes it.Typically affected: Regulatory management, controlling
Due by31 March 2027

Apply for the simplified procedure for electricity for the regulatory period from 2029

Power grid

Electricity DSOs that want to use the simplified procedure or the very small operator rule in the regulatory period from 2029 must apply to the regulator by 31 March 2027, the penultimate year before the period starts (RAMEN Strom para. 16.6 sentence 1 and para. 16.9). The authority decides within four weeks of a complete application; the operator is bound to the chosen procedure for the whole period.

Regulatory ruling · adopted

If the deadline is missed: Exclusion or loss of role Without a timely application the regular procedure with efficiency benchmarking applies for the whole regulatory period; the operator is bound to the procedure for the duration of the period (RAMEN Strom para. 16.6 sentence 3). Legal basis ↗

Applicability: Only electricity DSOs that meet the conditions for the simplified procedure or the very small operator rule under RAMEN Strom. The application deadline is a procedural rule under RAMEN Strom para. 19 and only applies to operators that fall within the Federal Network Agency's remit under Section 54(1) and (2) EnWG; for the others the state regulatory authority sets the procedure. For gas, the deadline for the period from 2028 passed on 31 March 2026.

  • Electricity grid operatorcheck applicabilityChecks whether the conditions for the simplified procedure or the very small operator rule are met and whether taking part pays off, and applies by 31 March 2027.Typically affected: Regulatory management, controlling
Due by31 March 2027

EnFG: report reduced levies for 2026 to the network operator (Section 52(2) EnFG)

Power gridSupplier

Grid users that claimed reduced levies for 2026, usually the supplier where supply runs under the supplier framework agreement, report to the network operator entitled to collect them the data under Section 52(2) EnFG by 31 March 2027, such as withdrawal points, privileged final consumers and volumes.

Law · adopted

If the deadline is missed: Money is lost If the report is not made or is late, the reduced levy claim rises to 100 percent (Section 53(1) no. 3 EnFG). Legal basis ↗

  • Electricity grid operatoraffectedReceives and checks the reports and charges the full levy without a timely report (Section 53(1) no. 3 EnFG).Typically affected: Grid usage and customer billing
  • Supplierrole obligationCompiles the 2026 data on withdrawals with reduced levies and reports it to the network operator by 31 March 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing
Due by31 March 2027

EU emissions trading: 2026 emissions report for power and heating plants

GenerationHeat network

Operators of installations in EU emissions trading, such as combined heat and power and heating plants with a total rated thermal input of 20 MW or more, determine their emissions under the approved monitoring plan and report them to the German Emissions Trading Authority by the end of 31 March of the following year (Section 21(1) TEHG).

Law · adopted

If the deadline is missed: Fine possible Failing to submit the report, or submitting it incorrectly, incompletely or late, is an administrative offence (Section 49(1) no. 1 TEHG); the fine is up to EUR 500,000 (Section 49(7)). Legal basis ↗

Applicability: Only operators of installations covered by EU emissions trading (ETS 1) under Annex 1 TEHG.

  • Plant operator (generation)role obligationPrepares the verified 2026 emissions report for power plants in EU emissions trading and submits it by 31 March 2027.Typically affected: Plant master data and MaStR, Trading and procurement system (ETRM)
  • Heat network operatorrole obligationPrepares the verified 2026 emissions report for heating and CHP plants in EU emissions trading and submits it by 31 March 2027.Typically affected: Plant master data and MaStR, Trading and procurement system (ETRM)
Due by31 March 2027

AgNes: proof of the final investment decision for grandfathering

Regulatory ruling · not yet adoptedPower gridGenerationStorage

Operators of generation plants, battery storage, pumped storage and electrolysers that rely on a final investment decision taken before publication for the charging rules prove it to the responsible network operator by 31 March 2027 (AgNes draft ruling, operative points 17.4 to 17.7).

If the deadline is missed: Regulator can enforce The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Electricity grid operatoraffectedReceives the proofs and takes them into account in network charge billing.Typically affected: Grid usage and customer billing
  • Plant operator (generation)role obligationSubmits proof of the investment decision to the network operator by 31 March 2027.Typically affected: Plant master data and MaStR
  • Storage operatorrole obligationSubmits proof for storage and pumped storage by 31 March 2027.Typically affected: Plant master data and MaStR

Q2 2027

24 deadlines
Applies fromdate open

Energy sharing: network operators' joint web platform (Section 20b EnWG)

Power gridTSOSupplier

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. Independently of the platform, every distribution system operator has had to enable energy sharing within its balancing area since 1 June 2026 (Section 42c(4) EnWG).

Law · adopted, date open

If the deadline is missed: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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)
  • Transmission system operatorrole obligationTakes part, as an electricity network operator, in building and running the joint platform under Section 20b EnWG.
  • 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). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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

Power 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.

Technical rule · adopted, date open

If the deadline is missed: Fine possible The rule is not a statute and carries no penalty of its own; according to VDE FNN it has been a technical safety rule since the procedure under Federal Network Agency determination BK6-23-037 (Section 49(2) sentence 2 EnWG), and complying with it creates a presumption of compliance with recognised engineering standards (Section 49(2) sentence 1 EnWG). 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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 partyrole obligationSubmits schedules under version 4.7 of the process description from 1 April 2027.Typically affected: Trading and procurement system (ETRM)

Part of the bundle: Market communication and EDM wave

Due by1 April 2027

Publish 2026 network losses

Power gridTSO

Electricity network operators publish on their website by 1 April the previous year's average losses per network and transformation level and the average procurement cost of loss energy in cents per kilowatt hour (Section 10(2) StromNEV).

Law · adopted

If the deadline is missed: Fine possible No specific administrative offence is listed. The regulator can enforce compliance by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Applies as long as StromNEV is applicable; the fifth regulatory period determinations (NEST) replace it for electricity from 2029. In addition, Section 23c(2) no. 7 and (3) no. 7 EnWG require transmission and electricity distribution system operators to publish loss volumes, average losses and procurement costs without delay.

  • Electricity grid operatorrole obligationDetermines 2026 losses per network and transformation level and procurement costs and publishes both by 1 April.Typically affected: Regulatory management, controlling, EDM / MDM
  • Transmission system operatorrole obligationPublishes 2026 losses and loss energy procurement costs by 1 April.Typically affected: Regulatory management, controlling
Due by1 April 2027

Section 23c EnWG: publish network structural data by 1 April

Power gridGas gridTSO

Every year by 1 April, electricity and gas network operators publish their network's structural data on their website, mostly as of 31 December of the previous year or for that year: line lengths, energy withdrawn, number of withdrawal points (gas: exit points), for electricity the area supplied, and further network data (Section 23c(1) and (4) EnWG). Electricity network operators also report the number of smart metering systems, of agreements under Section 14a(1) sentence 1 EnWG and of grid connections that, in the previous year, remained uncompleted for more than three and more than six months after receipt of the connection request, broken down by voltage level (subsection 1 nos. 4a to 4d).

Law · adopted

If the deadline is missed: Fine possible Section 95 EnWG does not mention Section 23c expressly. The Federal Network Agency can order publication under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG; failing to comply with an enforceable order under Section 65(1) or (2) is an administrative offence under Section 95(1) no. 3(a) EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Applies to all electricity and gas network operators, including transmission system operators for gas and closed distribution systems in industrial or commercial areas or areas with shared services (Section 110(1) and (2) EnWG; Section 110(1) does not exempt Section 23c but does exempt Section 14a, so no. 4d has nothing to count there). Customer installations under Section 3 nos. 65 and 66 EnWG are not networks. The number of inhabitants in the network area (subsection 1 no. 5) is required only from operators of low-voltage networks, and the smart metering figures (nos. 4a and 4b) only insofar as the network operator knows them. Gas transmission system operators also publish the data in English (subsection 7 sentence 3). Section 23c also requires ongoing publications without a fixed date, such as load profiles, feed-in and network losses for electricity networks (subsections 2 and 3) and calorific values for gas distribution networks (subsection 6); these must be updated without delay when they change, at least monthly or, where short-term services require it, daily (subsection 7).

  • Electricity grid operatorrole obligationCompiles line lengths, transformer capacity, energy withdrawn, withdrawal points, smart metering systems, Section 14a agreements and delayed grid connections, mostly as of 31 December 2026 or for calendar year 2026, and publishes them by 1 April.Typically affected: Grid planning, GIS, load flow, EDM / MDM, Customer and grid connection portal, Regulatory management, controlling
  • Gas grid operatorrole obligationGas distribution and transmission system operators publish line lengths per pressure level, energy withdrawn, exit points, the coincident annual peak load and network access terms by 1 April; transmission system operators also in English (subsection 7 sentence 3).Typically affected: Grid planning, GIS, load flow, EDM / MDM, Regulatory management, controlling
  • Transmission system operatorrole obligationPublishes the structural data under subsection 1 by 1 April, including delayed grid connections under no. 4c; the ongoing network data under subsection 2 come on top, and for operators with control area responsibility also those under subsection 2a.Typically affected: Regulatory management, controlling, Grid control system / SCADA
Due by1 April 2027

EEG tender biomass: bid date 1 April 2027

Generation

Bids must reach the Federal Network Agency by the bid date; the dates are set by law (Section 28c(1) EEG): 1 April and 1 October, until 2028.

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); 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 ↗

  • Plant operator (generation)check applicabilityAssesses participation and bid value for new biomass plants and follow-up support.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by1 April 2027

EEG tender biomethane: bid date 1 April 2027

Generation

Bids must reach the Federal Network Agency by the bid date; the dates are set by law (Section 28d(1) EEG): 1 April and 1 September, until 2028.

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); 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 ↗

  • Plant operator (generation)check applicabilityAssesses participation and bid value for biomethane CHP units.Typically affected: Plant master data and MaStR, Regulatory management, controlling
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 by30 April 2027

Electricity efficiency benchmarking: submit 2026 data to the Federal Network Agency

Regulatory ruling · not yet adoptedPower grid

Under the draft determination, electricity DSOs outside the simplified procedure submit their 2026 data for the efficiency benchmarking of the fifth regulatory period to the Federal Network Agency electronically and in full by 30 April 2027.

If the deadline is missed: Fine possible Under the draft, breaching the enforceable determination is an administrative offence under Section 95(1) no. 3(a) EnWG; the Federal Network Agency can also enforce submission with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Electricity DSOs that have not applied for the simplified or micro operator procedure by 31 March 2027 and fall below the applicable threshold. A different deadline may apply to operators under state regulators. Date and scope are final only once the determination is adopted.

  • Electricity grid operatorcheck applicabilityClarifies whether it falls under the standard procedure and prepares 2026 load, structural and sales data from source systems.Typically affected: Regulatory management, controlling, Grid planning, GIS, load flow, SAP IS-U / S/4HANA Utilities

Linked to: Electricity efficiency benchmarking: data collection consultation closes

Part of the bundle: Grid regulation and planning

Due by30 April 2027

Report on 2026 supply interruptions to the Federal Network Agency (Section 52 EnWG)

Power gridGas gridTSO

All electricity and gas network operators submit to the Federal Network Agency by 30 April a report on all supply interruptions of the previous year, with time, duration, extent and cause of each interruption, the measures taken and the average interruption duration per connected final customer (Section 52 EnWG). According to the agency this applies regardless of the deadlines in its general rulings.

Law · adopted

If the deadline is missed: Regulator can enforce Section 52 EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Applies to all operators of energy supply networks, electricity and gas, regardless of size, but not to operators of closed distribution systems (Section 110(1) EnWG). The data collection for the quality element for electricity DSOs in the regular procedure is a separate deadline.

  • Electricity grid operatorrole obligationEvaluates the 2026 fault data and reports each interruption with duration, extent and cause, plus the average interruption duration.Typically affected: Grid control system / SCADA, Regulatory management, controlling
  • Gas grid operatorrole obligationReports the 2026 supply interruptions in the gas network with duration, extent, cause and measures.Typically affected: Grid control system / SCADA, Regulatory management, controlling
  • Transmission system operatorrole obligationReports the 2026 supply interruptions in the transmission network with duration, extent, cause and measures.Typically affected: Grid control system / SCADA, Regulatory management, controlling
Due by30 April 2027

EU ETS 2: report 2026 fuel emissions (gas suppliers)

Supplier

Parties responsible under EU fuel emissions trading, such as gas suppliers, determine emissions of the fuels placed on the market from reporting year 2025 and report them by the end of 30 April of the following year (Section 43(1) TEHG), i.e. for 2026 by 30 April 2027. This report runs alongside the national report under Section 7 BEHG.

Law · adopted

If the deadline is missed: Fine possible Failing to submit the report, or submitting it incorrectly, incompletely or late, is an administrative offence (Section 49(1) no. 1 TEHG); the fine is up to EUR 500,000 (Section 49(7)). Legal basis ↗

  • Supplierrole obligationPrepares the 2026 ETS 2 emissions report for fuel quantities supplied and submits it by 30 April 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Trading and procurement system (ETRM)

Linked to: BEHG: 2026 emissions report of fuel suppliers to the German Emissions Trading Authority

Due by1 May 2027

Capacity market: TSO platform for prequalification by 1 May 2027

TSOGeneration

TSOs set up a joint web platform, for prequalification by 1 May 2027 and for capacity tenders by 15 October 2027 (Section 26(6) StromVKG). Plant operators submit their applications through it.

Law · adopted

If the deadline is missed: No direct legal consequence Section 26 StromVKG states no specific consequence of a late platform launch. Legal basis ↗

  • Transmission system operatorrole obligationSets up the joint platform for prequalification by 1 May 2027 and for tenders by 15 October 2027.Typically affected: Customer and grid connection portal, Regulatory management, controlling
  • Plant operator (generation)affectedPrepares prequalification of generation and storage plants on the platform.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by3 May 2027

EEG innovation tender: bid date 1 May 2027, bids by 3 May 2027

GenerationStorage

Bids must reach the Federal Network Agency by the bid date; the dates are set by law (Section 28e(1) EEG): 1 May and 1 September, until 2028. 1 May 2027 is a Saturday and a public holiday, so the submission period ends on Monday, 3 May 2027 (Sections 188 and 193 BGB).

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); 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 ↗

  • Plant operator (generation)check applicabilityAssesses plant combinations such as solar with storage for the innovation tender.Typically affected: Plant master data and MaStR, Regulatory management, controlling
  • Storage operatorcheck applicabilityAssesses the storage component in plant combinations.Typically affected: Plant master data and MaStR
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 by31 May 2027

EnFG: final settlement of EEG and KWKG payments for 2026 to the TSO

Power gridTSO

Distribution system operators send their upstream TSO by 31 May the final settlements of EEG and KWKG payments for the previous year, individually and in aggregate, for each installation with register number and volumes, plus the other data under Section 50 no. 2 EnFG. The aggregated settlements must be audited (Section 55(1) EnFG).

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency monitors that network operators run the equalisation mechanism properly (Section 62(1) EnFG) and can issue orders under Section 65 EnWG for this (Section 62(3) EnFG); failing to comply with an enforceable order is an administrative offence under Section 63(1) no. 2 EnFG (fine of up to EUR 200,000). If data are missing or late, the receiving network operator may estimate them; the duty to report remains (Section 61 EnFG). Legal basis ↗

  • Electricity grid operatorrole obligationPrepares the 2026 EEG and KWKG final settlements per installation, has the aggregated settlement audited and sends it to the TSO.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities, Regulatory management, controlling
  • Transmission system operatoraffectedReceives and checks the final settlements of downstream DSOs; it may estimate missing data (Section 61 EnFG).Typically affected: Grid usage and customer billing, Regulatory management, controlling
Due by31 May 2027

Publish the draft network development plans for electricity and for gas and hydrogen

Gas gridTSO

TSOs with control area responsibility are to publish the draft electricity network development plan by the end of 31 May of each odd year (Section 12b(3) sentence 3 EnWG). The draft network development plan for gas and hydrogen must be published on the same date; it is prepared by the coordination office of the gas TSOs (Section 15c(4) EnWG). Downstream network operators can comment on both drafts.

Law · adopted

If the deadline is missed: Regulator can enforce Sections 12b and 15c EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

  • Gas grid operatoraffectedGas TSOs present the gas and hydrogen draft via the coordination office; gas DSOs can comment on it.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
  • Transmission system operatorrole obligationPublishes the draft electricity network development plan and consults the public and downstream network operators.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
Due by31 May 2027

Electricity and energy tax 2026: annual return by 31 May, payment by 25 June

Supplier

Suppliers filing annually file electricity and energy tax for 2026 with the main customs office by 31 May 2027 and pay it, after credit for advance payments, by 25 June 2027 (Section 8(4) StromStG, Section 39(3) EnergieStG). With monthly filing the 15th of the following month applies (Section 8(3) StromStG).

Law · adopted

If the deadline is missed: Money is lost Filing late risks a late filing surcharge (Section 152 AO); paying late incurs late payment surcharges (Section 240 AO). Legal basis ↗

  • Supplierrole obligationPrepares the 2026 annual tax return from billing and volume allocation, files it by 31 May 2027 and pays by 25 June 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing

Linked to: Electricity and energy tax: choose monthly or annual filing for 2027

Due by31 May 2027

EnFG: report on storage and charging points with reduced levies for 2026

SupplierStorageCharge points

For grid withdrawals into storage and charging points claiming reduced levies under Section 21 EnFG, the report under Section 52(1) EnFG must be made by 31 May of the following year at the latest (Section 21(7) EnFG), i.e. by 31 May 2027 for 2026.

Law · adopted

If the deadline is missed: Money is lost If the report is not made in time, the reduced levy claim for the year rises by 20 percentage points (Section 53(2) EnFG with Section 21(7)). Legal basis ↗

Applicability: Under Section 52(1) EnFG the grid user must report: the storage or charging point operator only with its own grid use contract; where supplied under the supplier framework contract, the supplier. Section 52(1) requires notification without undue delay; 31 May is the outer limit under Section 21(7) EnFG.

  • Suppliercheck applicabilityReports as the grid user where storage or charging points are supplied under the supplier framework contract.Typically affected: SAP IS-U / S/4HANA Utilities
  • Storage operatorcheck applicabilityReports 2026 storage withdrawals with reduced levies by 31 May 2027 if the storage operator is itself the grid user; otherwise the supplier reports.Typically affected: Grid usage and customer billing, Plant master data and MaStR
  • Charge point operatorcheck applicabilityReports 2026 withdrawals via bidirectional charging points by 31 May 2027 if the operator is itself the grid user; otherwise the supplier reports.Typically affected: Charging backend (OCPP, PKI), Grid usage and customer billing
Due by31 May 2027

Methane Regulation: annual importer report under Annex IX

SupplierCompany-wide

Importers of natural gas, crude oil or coal from third countries submit the information listed in Annex IX to the competent authority each year by 31 May (Article 27(1) Regulation (EU) 2024/1787).

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. The Commission recommends that member states do not apply the penalties under Article 33(5)(m), (n) and (o) to importers' breaches of the obligations for 2027, 2028 and 2029, except in cases of fraud (Recommendation (EU) 2026/1835); the obligation itself remains. There is no German implementing act yet; the ministerial draft is still being coordinated within the federal government (Bundestag printed paper 21/8334). Legal basis ↗

Applicability: Only undertakings that import natural gas, crude oil or coal from third countries into the Union (importers under Regulation (EU) 2024/1787). Suppliers buying on the wholesale market inside the Union are not importers.

  • Suppliercheck applicabilityCompiles and reports the Annex IX information on origin and producers by 31 May.Typically affected: Trading and procurement system (ETRM)
  • Company-wide, several rolescheck applicabilityAs an importer, reports the Annex IX information by 31 May.Typically affected: Trading and procurement system (ETRM)
Due by31 May 2027

Hydrogen core network: submit planned costs by 31 May, actual costs by 30 June

Gas grid

Operators of the hydrogen core network submit the planned costs for the following year with their calculation basis to the Federal Network Agency each year by 31 May and the actual costs by 30 June (Section 14(2) and (3) WasserstoffNEV as amended by the KOSMO ruling, GBK-24-01-2#2, operative point 5).

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Operators of the hydrogen core network. For other regulated hydrogen networks, Section 14(2) and (3) WasserstoffNEV sets 30 September for both submissions.

  • Gas grid operatorrole obligationAs a core network operator, submits planned costs by 31 May and actual costs by 30 June.Typically affected: Regulatory management, controlling
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; the application for 2028 cannot be made up later. From the 2029 revenue cap, the application under Section 4(4) ARegV is replaced by a notification by 30 June under RAMEN Strom, operative item 11.8. 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

Due by30 June 2027

RAMEN Gas: notify the capital cost deduction for 2028

Gas grid

Gas network operators determine the capital cost deduction for each year of the regulatory period from 2028 themselves and notify it to the regulator by 30 June of the previous year, for 2028 by 30 June 2027 (RAMEN Gas para. 9.7 sentence 2). The authority first sets the revenue cap without this deduction (para. 9.7 sentence 1).

Regulatory ruling · adopted

If the deadline is missed: Fine possible RAMEN Gas sets no specific consequence for a missing notification. The regulator can order it under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Applies to gas distribution and transmission system operators in the regulatory period from 2028, each year for the following year (RAMEN Gas para. 1). For electricity the regulator determines the capital cost deduction itself. The application and notification deadline is a procedural rule under RAMEN Gas para. 19 and only applies to operators that fall within the Federal Network Agency's remit under Section 54(1) and (2) EnWG; for the others the state regulatory authority sets the procedure.

  • Gas grid operatorrole obligationDetermines the 2028 capital cost deduction from the starting level and asset disposals and notifies it by 30 June 2027; also applies to gas TSOs.Typically affected: Regulatory management, controlling, Plant master data and MaStR
Due by30 June 2027

Capital cost surcharge gas 2028: notify the regulator

Gas grid

Gas distribution and transmission system operators that include a capital cost surcharge in a year's revenue cap notify the regulator by 30 June of the previous year, for 2028 by 30 June 2027 (RAMEN Gas, operative point 11.7).

Regulatory ruling · adopted

If the deadline is missed: Money is lost Without timely notification the costs cannot be recognised, not even in the regulatory account (RAMEN Gas, reasoning on operative point 11.7). Legal basis ↗

Applicability: Applies to gas distribution and transmission system operators (RAMEN Gas para. 1) that include a capital cost surcharge, each year for the following year. The application and notification deadline is a procedural rule under RAMEN Gas para. 19 and only applies to operators that fall within the Federal Network Agency's remit under Section 54(1) and (2) EnWG; for the others the state regulatory authority sets the procedure.

  • Gas grid operatorrole obligationNotifies the capital cost surcharge for the 2028 revenue cap by 30 June 2027, then yearly by 30 June of the previous year; also applies to gas TSOs.Typically affected: Regulatory management, controlling

Q3 2027

21 deadlines
Due by1 July 2027

Five-year forecast of congestion measures to the Federal Network Agency (Section 13(10) EnWG)

TSO

The TSOs jointly prepare each year a forecast of the volume of grid-related measures under Section 13(1) and (2) EnWG for the next five years and send it to the Federal Network Agency by 1 July (Section 13(10) sentence 1 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 13(10) EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

  • Transmission system operatorrole obligationPrepares the five-year forecast of congestion measures with the other TSOs based on the system analysis and submits it by 1 July.Typically affected: Grid control system / SCADA, Regulatory management, controlling
Due by1 July 2027

Electricity disclosure: show the 2026 fuel mix from 1 July (Section 42 EnWG)

Supplier

Electricity suppliers state the fuel mix and environmental impact in bills, promotional material and on their website; from 1 July of each year at the latest the values of the previous year must be shown, i.e. those for 2026 from 1 July 2027 (Section 42(1) no. 1 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 42 EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

  • Supplierrole obligationCalculates the 2026 fuel mix from cancelled guarantees of origin and the residual mix and updates bill layout, marketing and website by 1 July 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Customer and grid connection portal

Linked to: Guarantee of origin register: report 2026 supply volumes and guarantees (Section 30(5) HkRNDV)

Due by1 July 2027

Guarantee of origin register: report 2026 supply volumes and guarantees (Section 30(5) HkRNDV)

Supplier

Every electricity supplier sends the register administration at the Federal Environment Agency, by 1 July for the previous year, the information under Section 30(5) HkRNDV: the share of renewable energy with guarantees of origin not supported under the EEG in its overall energy mix, the total electricity supplied to final consumers and the electricity from that renewable energy, each in kilowatt hours; this first applied on 1 July 2026.

Law · adopted

If the deadline is missed: Exclusion or loss of role If an electricity supplier does not report, the register administration is to block its account (Section 49(2) no. 4 HkRNDV); a blocked account cannot transfer or cancel guarantees of origin (Section 49(3)). Legal basis ↗

  • Supplierrole obligationReports for 2026 the share of unsupported renewables with guarantees of origin, total electricity supplied and the electricity from them to the register by 1 July 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Trading and procurement system (ETRM)
Due by1 July 2027

KWKG: apply for approval of heat networks and heat storage commissioned in 2026

Heat network

Operators of new or extended heat networks and new heat storage apply for approval of the KWKG surcharge by 1 July of the year after commissioning, i.e. by 1 July 2027 for 2026 commissioning (Section 20(3), Section 24(4) KWKG).

Law · adopted

If the deadline is missed: Exclusion or loss of role Without approval there is no claim to the surcharge (Section 18(1), Section 22(1) KWKG). BAFA rejects applications not filed on time. Legal basis ↗

  • Heat network operatorrole obligationFiles the approval application with BAFA for network sections and heat storage commissioned in 2026 by 1 July 2027.Typically affected: Plant master data and MaStR, Regulatory management, controlling
Due by1 July 2027

WasABi: set up the hydrogen data exchange platform

Gas gridSupplierBalancing

For hydrogen balancing under WasABi, the data exchange platform must be set up by 1 July 2027 and tested with market participants in an introduction phase until 1 January 2028; the IT interface specifications are announced to market participants beforehand (BK7-24-01-014, operative point 7(d)).

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Gas grid operatoraffectedSupplies the market area manager with data for the platform; as a hydrogen transport network operator, equips it with the necessary means by 1 January 2028.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
  • SupplieraffectedConnects hydrogen supply to the platform and takes part in testing.Typically affected: Trading and procurement system (ETRM)
  • Balance responsible partyaffectedRegisters on the platform and tests the interfaces until 1 January 2028.Typically affected: Trading and procurement system (ETRM)

Linked to: WasABi: balancing rules for hydrogen apply, data platform from July 2027

Due by15 July 2027

Submit the internal capacity order for 2028 to the gas TSO

Gas grid

The network operator directly downstream of the gas TSO submits its internal capacity order for the following year by 15 July; it agrees dates with its own downstream operators so that this deadline is met (KoV Section 11 no. 3). The TSO replies within 10 working days with acceptance or rejection (no. 4).

Technical rule · adopted

If the deadline is missed: Regulator can enforce The cooperation agreement is a contract among gas network operators; Section 20(1b) sentence 5 EnWG obliges them to cooperate within it. The agreement sets no specific sanction for the missed date. The regulator can enforce the duty to cooperate under Section 65 EnWG. Legal basis ↗

Applicability: Applies to gas DSOs directly downstream of a gas TSO; operators further downstream supply their data to them by agreed dates.

  • Gas grid operatorrole obligationDetermines the 2028 capacity requirement per interconnection point or exit zone, collects the values of downstream networks and submits the internal order by 15 July 2027.Typically affected: Regulatory management, controlling, Grid control system / SCADA
Due by31 July 2027

Cancel regional guarantees for 2026 (window 1 April to 31 July 2027)

Supplier

Regional guarantees for electricity generated in 2026 can only be cancelled from 1 April to 31 July 2027 (Section 31(1) no. 1 HkRNDV). Suppliers that want to show regional origin must have them cancelled in this window.

Law · adopted

If the deadline is missed: Exclusion or loss of role After 31 July a request to cancel guarantees for the previous year's electricity is no longer admissible; regional labelling for 2026 is then lost. Legal basis ↗

  • SupplieraffectedHas regional guarantees for 2026 cancelled in the window 1 April to 31 July 2027 if products claim regional origin.Typically affected: Trading and procurement system (ETRM), SAP IS-U / S/4HANA Utilities
Due by31 July 2027

BEHG: 2026 emissions report of fuel suppliers to the German Emissions Trading Authority

Supplier

Anyone placing fuels on the market, such as gas suppliers, reports the verified fuel emissions of the previous year to the German Emissions Trading Authority by 31 July (Section 7(1) BEHG), i.e. for 2026 by 31 July 2027. Because EU emissions trading for buildings and transport only starts in 2028, the duty also covers fuels placed on the market in 2027 (Section 24(1) sentence 2 in conjunction with Section 10(3) sentence 2 no. 5 BEHG); that report is due by 31 July 2028.

Law · adopted

If the deadline is missed: Fine possible Failing to submit the report, or submitting it incorrectly, incompletely or late, is an administrative offence (Section 22(1) BEHG); the fine is up to EUR 500,000, or up to EUR 50,000 if negligent (Section 22(2) and (4) BEHG). Legal basis ↗

  • Supplierrole obligationPrepares the verified 2026 emissions report for the fuel quantities supplied and submits it to the authority by 31 July 2027.Typically affected: SAP IS-U / S/4HANA Utilities, Trading and procurement system (ETRM)
Due by31 July 2027

EEG transparency: plant operators above EUR 100,000 report missing data

Generation

Plant operators that received more than EUR 100,000 in payments under Section 19(1) or Section 50 EEG in the previous year and whose data in the market master data register are unpublished or incomplete send the TSO by 31 July the data for the European Commission's transparency database, with address and register number (Section 71(4) EEG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 71(4) EEG sets no specific sanction. The Federal Network Agency monitors the reporting duties and can order remedies under Section 85(3) EEG with Section 65 EnWG. Legal basis ↗

Applicability: Only plant operators with more than EUR 100,000 in EEG payments in the previous year whose market master data register entries are unpublished or incomplete.

  • Plant operator (generation)check applicabilityChecks whether 2026 payments exceeded EUR 100,000 and register data are complete, and otherwise reports to the TSO by 31 July 2027.Typically affected: Plant master data and MaStR, Regulatory management, controlling
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: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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 by31 August 2027

EnFG: CHP forecast for 2028 and 2026 year-end settlement with the TSO

Power gridTSO

By 31 August distribution system operators send the TSO the forecast CHP volumes, bonuses and grid withdrawals for the following year (Section 50 no. 3 EnFG). On the same date the year-end settlement between distribution and transmission system operators for the previous year takes place (Section 19(1) no. 2 EnFG); the resulting payment claims must be settled by 15 September (Section 19(2)), as must the differences between passed-on and finally settled EEG volumes (Section 19(3)).

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency monitors that network operators run the equalisation mechanism properly (Section 62(1) EnFG) and can issue orders under Section 65 EnWG for this (Section 62(3) EnFG); failing to comply with an enforceable order is an administrative offence under Section 63(1) no. 2 EnFG (fine of up to EUR 200,000). If data are missing or late, the receiving network operator may estimate them; the duty to report remains (Section 61 EnFG). Legal basis ↗

  • Electricity grid operatorrole obligationDelivers the 2028 CHP forecast and the 2026 year-end settlement to the TSO and settles payments by 15 September.Typically affected: Grid usage and customer billing, SAP IS-U / S/4HANA Utilities
  • Transmission system operatoraffectedSettles with downstream DSOs on 31 August and balances payments by 15 September.Typically affected: Grid usage and customer billing

Linked to: EnFG: final settlement of EEG and KWKG payments for 2026 to the TSO

Due by31 August 2027

L-gas market area conversion: report actual and planned costs to the regulator

Gas grid

Gas network operators whose network is converted from L-gas to H-gas report to the regulator by 31 August each year which necessary conversion costs arose in the previous year and which are planned for the following year (Section 19a(2) sentence 1 EnWG). The network operator must prove the costs were necessary.

Law · adopted

If the deadline is missed: Fine possible Costs the regulator has found unnecessary may not be passed on (Section 19a(2) sentence 5 EnWG). The regulator can order the report under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Only gas network operators whose network is converted from L-gas to H-gas as part of the market area conversion, as long as conversion costs arise.

  • Gas grid operatorrole obligationReports the 2026 conversion costs and the planned 2028 costs with proof of necessity; also applies to gas TSOs.Typically affected: Regulatory management, controlling, Grid usage and customer billing
Due by31 August 2027

Report biogas costs for nationwide cost pooling (plan 2028, actual 2026)

Gas grid

Biogas feed-in network operators report by 31 August the forecast biogas costs for the following year including the pooling amount, and the actual biogas costs of the previous year, to the gas TSO to whose network theirs is connected, and in parallel to the Federal Network Agency via the data form (KoV Section 7 no. 2).

Technical rule · adopted

If the deadline is missed: Regulator can enforce The cooperation agreement is a contract among gas network operators; Section 20(1b) sentence 5 EnWG obliges them to cooperate within it. The agreement sets no specific sanction for the missed date. The regulator can enforce the duty to cooperate under Section 65 EnWG. Legal basis ↗

Applicability: Only gas network operators into whose network biogas plants feed (biogas feed-in network operators). The cost basis is Section 20b GasNEV, which expires at the end of 2027; whether the 2028 date stays depends on the successor rule.

  • Gas grid operatorrole obligationReports planned 2028 and actual 2026 biogas costs to the gas TSO and via the data form to the Federal Network Agency.Typically affected: Regulatory management, controlling, Grid usage and customer billing
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: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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

Due byEnd 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; the flat-rate option also only after state aid approval for Section 19(3c) EEG. 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). The flat-rate option (operative points 2 and 4) applies at the earliest from the month after the European Commission grants state aid approval for Section 19(3c) EEG (operative point 9 b). 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 operatorrole obligationSets up by 30 September 2027 the processes that let both MiSpeL options run without case-by-case consent from 1 October 2027 (operative item 7).Typically affected: EDM / MDM, Grid usage and customer billing
  • Default metering point operatorrole obligationProvides by 30 September 2027 the metering and data delivery the demarcation option needs at storage and charging sites (operative item 7).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

Due by30 September 2027

Determine and publish the default supplier for 2028 to 2030 (Section 36 EnWG)

Power gridGas gridSupplier

Operators of general supply networks determine on 1 July 2027 which undertaking supplies the most household customers in their network area and is therefore default supplier for 2028 to 2030, publish the result online by 30 September and notify the competent state authority in writing (Section 36(2) sentence 2 EnWG). Objections can be lodged with that authority by 31 October.

Law · adopted

If the deadline is missed: Regulator can enforce The competent state authority can take the measures needed to run the procedure properly and decides on objections to the result (Section 36(2) sentences 3 and 4 EnWG). Section 95 EnWG sets no specific administrative offence. Legal basis ↗

Applicability: Applies to operators of general supply electricity and gas networks regardless of size. The cut-off for the determination is 1 July 2027, the deadline for publication and notification 30 September 2027.

  • Electricity grid operatorrole obligationCounts household customers per supplier as of 1 July 2027, determines the default supplier, publishes the result by 30 September and notifies the state authority.Typically affected: SAP IS-U / S/4HANA Utilities, Regulatory management, controlling, Customer and grid connection portal
  • Gas grid operatorrole obligationCounts household customers per gas supplier as of 1 July 2027, determines the default supplier, publishes the result by 30 September and notifies the state authority.Typically affected: SAP IS-U / S/4HANA Utilities, Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedLearns whether it is or remains default supplier in the network area from 2028 and can lodge objections with the state authority by 31 October.Typically affected: SAP IS-U / S/4HANA Utilities
Due by30 September 2027

Determine and report the EEG and KWKG funding requirement for 2028 (Section 4 EnFG)

TSO

The TSOs determine by 30 September the EEG and KWKG funding requirements for the following year and report: to the Federal Ministry for Economic Affairs the EEG funding requirement and the expected amount of the claim under Section 6(1) sentence 1 or 2 EnFG for the current year, to the Federal Ministry of Agriculture the total follow-up support paid for small manure plants in the previous year, to the Federal Office for Economic Affairs and Export Control the KWKG funding requirement, and to the Federal Network Agency both funding requirements and the offshore connection costs (Section 4 nos. 1 to 4 EnFG).

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency monitors that the TSOs determine and report the funding requirements properly (Section 62(1) no. 1(a) EnFG) and can issue orders under Section 65 EnWG for this (Section 62(3) EnFG); failing to comply with an enforceable order is an administrative offence under Section 63(1) no. 2 EnFG (fine of up to EUR 200,000). Legal basis ↗

  • Transmission system operatorrole obligationDetermines the 2028 EEG and KWKG funding requirements and offshore connection costs and reports them to the ministry, BAFA and the Federal Network Agency.Typically affected: Grid usage and customer billing, Regulatory management, controlling
Due by30 September 2027

Compliance report of independent transmission operators (Section 10e EnWG)

Gas gridTSO

The compliance officer of an independent transmission operator prepares an annual report on the measures implementing the compliance programme and submits it to the regulator by 30 September (Section 10e(4) sentence 2 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 10e EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Only transmission system operators (electricity and gas) organised as independent transmission operators under Sections 10 to 10e EnWG. Distribution system operators report under Section 7a(5) by 31 March.

  • Gas grid operatorrole obligationGas TSOs under the independent transmission operator model submit their compliance officer's annual report by 30 September.Typically affected: Regulatory management, controlling
  • Transmission system operatorrole obligationHas the compliance officer prepare the annual report and submits it by 30 September; only under the independent transmission operator model.Typically affected: Regulatory management, controlling
Due by30 September 2027

BEHG: surrender emission allowances for 2026

Supplier

Fuel suppliers surrender to the German Emissions Trading Authority by 30 September as many allowances as the emissions shown in their report for the previous year (Section 8 BEHG), i.e. for 2026 by 30 September 2027.

Law · adopted

If the deadline is missed: Money is lost For each tonne for which no allowance was surrendered, the authority sets a payment obligation (Section 21(1) BEHG); its amount follows Section 21(1) sentence 2 BEHG. Legal basis ↗

  • Supplierrole obligationBuys missing allowances in time and surrenders the amount for 2026 emissions by 30 September 2027.Typically affected: Trading and procurement system (ETRM)

Linked to: BEHG: 2026 emissions report of fuel suppliers to the German Emissions Trading Authority

Due by30 September 2027

EU emissions trading: surrender allowances for 2026

GenerationHeat network

Operators of installations in EU emissions trading surrender to the German Emissions Trading Authority by 30 September as many allowances as their installations emitted in the previous year (Section 7(1) TEHG).

Law · adopted

If the deadline is missed: Money is lost For each tonne without a surrendered allowance the authority sets a payment of EUR 100, adjusted to the European consumer price index since 2012 (Section 46(1) TEHG). Legal basis ↗

  • Plant operator (generation)role obligationSurrenders the allowances for 2026 emissions by 30 September 2027.Typically affected: Trading and procurement system (ETRM)
  • Heat network operatorrole obligationSurrenders the allowances for 2026 emissions of heating and CHP plants by 30 September 2027.Typically affected: Trading and procurement system (ETRM)

Linked to: EU emissions trading: 2026 emissions report for power and heating plants

Due by30 September 2027

Controllability check: network operators' tests and reports by 30 September via the TSOs' portals

Power gridMetering

Every electricity network operator carries out test adjustments under Section 13a(1) EnWG and retrievals of actual feed-in every year, since 2026 also for plants below 100 kW; every default metering operator checks the deployment status of smart metering systems and control units every year and sends it to the network operator (Section 12(2b) EnWG). Under the TSOs' guidelines, tests and data submission via their portals must be completed by 30 September; upstream network operators check the data from 1 to 31 October.

Law · adopted

If the deadline is missed: Exclusion or loss of role If a default metering operator fails its checking duty and compliance with the deployment obligations therefore cannot be established, 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: All electricity network operators and all default metering operators. Process, data format and timeline are set by the TSOs' guidelines under Section 12(2d) EnWG; the TSOs may amend them within two months of each overall report, after the report of 30 November 2026 by 31 January 2027.

  • Electricity grid operatorrole obligationCarries out the controllability tests and actual feed-in retrievals and reports the results, together with the default metering operator's data, via the TSO portal by 30 September; as an upstream operator checks downstream data from 1 to 31 October.Typically affected: Grid control system / SCADA, Regulatory management, controlling
  • Default metering point operatorrole obligationChecks the deployment status of smart metering systems and control units in the grid area and sends it to the network operator in time before 30 September.Typically affected: Gateway administration and CLS management

Q4 2027

15 deadlines
Applies from1 October 2027

Rules for secure data exchange in the scheduling process v2.4 become binding

TSOBalancing

From 1 October 2027 version 2.4 of the rules for secure data exchange in the scheduling process applies to all market participants required to implement it (Notice no. 17 on BK6-18-061).

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce Like the schedule nomination process description, the rules are part, through Annex 3, 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Transmission system operatorrole obligationApplies version 2.4 of the secure exchange rules in scheduling.Typically affected: Trading and procurement system (ETRM), Market communication gateway (EDIFACT, AS4, API)
  • Balance responsible partyrole obligationMoves schedule data exchange to version 2.4 of the secure exchange rules by 1 October 2027.Typically affected: Trading and procurement system (ETRM)

Part of the bundle: Market communication and EDM wave

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 by1 October 2027

Renewables grid cost pass-through: notify the regulator of the 2028 amount

Power grid

Distribution system operators that intend to notify their TSO of a pass-through of renewables-related extra costs for 2028 must notify the competent regulator of the calculated amount by 1 October 2027 and submit the survey form under Section 28 nos. 3 and 4 ARegV (ruling BK8-24-001-A, operative item 5(d)). By this date the data needed to calculate the amount are sufficient; the complete form including the tariff cross-check is only due on 1 January under Section 28 ARegV.

Regulatory ruling · adopted

If the deadline is missed: Fine possible The ruling attaches no specific consequence to a late notification; operative item 5(b) removes reimbursement only for a late notification to the TSO. For network operators, failing to comply with conditions set under Section 29(1) EnWG is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Legal basis ↗

Applicability: Only DSOs claiming a particular burden from renewables connections under BK8-24-001-A that fall within the Federal Network Agency's remit under Section 54(1) and (2) EnWG (operative item 12). State regulators may set their own procedural rules (reasoning, para. 153). The notification to the TSO follows by 14 October 2027.

  • Electricity grid operatorrole obligationNotifies the regulator of the 2028 pass-through amount with the survey form by 1 October 2027, before reporting it to the TSO.Typically affected: Regulatory management, controlling

Part of the bundle: Grid regulation and planning

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

Linked to: Renewables grid cost pass-through: notify the regulator of the 2028 amount

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: Fine possible 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). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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

Due by25 October 2027

2028 levies: publication by the transmission system operators

Power gridTSOSupplier

The transmission system operators publish the 2028 CHP levy and offshore grid levy by 25 October 2027. 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
Due by25 October 2027

TSOs: five-year outlook on renewables expansion and EEG payments

Power gridTSO

TSOs prepare and publish by 25 October an outlook for the expansion of renewables (Section 74(1) EEG) and for the payments due (Section 60(1) EnFG) over the following five calendar years.

Law · adopted

If the deadline is missed: Regulator can enforce The EEG sets no specific sanction. The Federal Network Agency monitors the TSOs' duties and can order remedies under Section 85(3) EEG with Section 65 EnWG. Legal basis ↗

  • Electricity grid operatoraffectedSupplies data on connected plants and uses the forecast for its own planning.Typically affected: Regulatory management, controlling
  • Transmission system operatorrole obligationPrepares the medium-term forecast of renewables expansion and payments and publishes it by 25 October 2027.Typically affected: Regulatory management, controlling, Customer and grid connection portal
Due by25 October 2027

Surcharge for special grid use: show contributions separately

Power gridTSOSupplier

Each year by 25 October the TSOs show the contributions from the surcharge for special feed-in-related grid use (renewables grid cost pass-through) and from the mechanism under Section 19(2) sentence 15 StromNEV for the following year separately on netztransparenz.de (BK8-24-001-A, operative point 7 sentence 2).

Regulatory ruling · adopted

If the deadline is missed: Fine possible The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatoraffectedTakes the surcharge for special grid use into price sheets and billing.Typically affected: Grid usage and customer billing
  • Transmission system operatorrole obligationShows the contributions of both mechanisms for the following year separately on netztransparenz.de by 25 October.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedPrices next year's tariffs with the published surcharge.Typically affected: Grid usage and customer billing
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 by31 October 2027

Congestion income 2028: report the planned use to the Federal Network Agency

TSO

Transmission system operators tell the Federal Network Agency in advance how they plan to use the 2028 congestion income from allocating cross-zonal capacity (Article 4 of the ACER methodology under Article 19(4) of Regulation (EU) 2019/943). The date is set by the Federal Network Agency deadline calendar; in 2026 it was 31 October.

Regulatory ruling · adopted, date open

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. The exact 2027 date is set only once the Federal Network Agency publishes its 2027 deadline calendar.

  • 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 by31 October 2027

Default metering point operators: publish services and price sheets by 31 October 2027

Metering

By 31 October 2027, default metering point operators publish the scope of their installation duties under Section 29 MsbG, their standard and possible additional services, and price sheets with expected annual prices for at least three years (Section 37(1) MsbG).

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG sets no penalty of its own for a missing publication. The Federal Network Agency can order it under Section 76(2) MsbG and enforce the order with coercive fines under Section 94 EnWG (Section 76(4) MsbG); whether breaching such an order can also be fined as an administrative offence under Section 95 EnWG is unsettled: Section 76(4) MsbG does refer to Part 8 of the EnWG and thus to Section 95, but Section 95(1) no. 3(a) EnWG only lists orders under the EnWG, such as Section 65, and none under the MsbG. Legal basis ↗

Applicability: Applies only to default metering point operators. Notice of installation to individual customers is governed by Section 37(2) MsbG (at least three months ahead).

  • Default metering point operatorrole obligationPublishes the scope of its installation duties, standard and additional services and price sheets for at least three years on its website.Typically affected: Customer and grid connection portal, 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 and small mid-caps (Art. 99(6) and (6a)). 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 directly protects the asset as a safety component and whether the company counts as a critical entity; under the Commission's draft guidelines, 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

After that, extended maintenance until the end of 2030 at a premium of two percentage points on the maintenance basis, followed by customer-specific maintenance.

If the deadline is missed: No direct legal consequence The date is set by SAP, not by law. From 2028 extended maintenance runs at a premium until the end of 2030; under the customer-specific maintenance that follows, or applies without it, SAP delivers no legal changes. For its largest customers SAP offers the Transition Option for SAP ERP from 2031 to 2033 if the system has moved to SAP ERP, private edition, on SAP HANA by the end of 2030. Legal basis ↗

Applicability: Affects companies running SAP ERP 6.0 (ECC, IS-U) on one of the three latest enhancement packages. 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

12 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: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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: Money is lost 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. Network operators include them each year at the actual values of the year before last.

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; for allocations that are not appropriate, such as catch-up or one-off allocations, the ruling chamber considers a regulatory adjustment conceivable (para. 231). Amounts not recognised do not enter the revenue cap as cost shares outside the efficiency benchmark. Legal basis ↗

Applicability: Concerns operators of gas distribution and transmission networks under incentive regulation (operative item 1). 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 operatoraffectedRecords provisions for necessary decommissioning and unavoidable dismantling and, from 2028, includes them each year at the actual values of the year before last.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+

Applies from1 January 2028

EEG: control via the smart meter gateway from 2028

Power gridMeteringDirect marketingGeneration

From 1 January 2028, and once a smart metering system is installed, plants above 25 kW in direct marketing must be readable and remotely controllable via the smart meter gateway (Section 10b(2) EEG). From 2028, after a smart metering system and control device have been installed, grid operators pay the plant operator EUR 100 gross for each year begun until the controllability test has succeeded (Section 9(2a) EEG).

Law · adopted

If the deadline is missed: Money is lost Until the test succeeds, the grid operator pays the plant operator EUR 100 gross for each year begun from 2028 under Section 9(2a) EEG, unless it is not responsible for the failed test. Plant operators in breach of Section 10b EEG pay the grid operator up to EUR 10 per kilowatt and calendar month under Section 52(1) no. 4 and (2) EEG. Legal basis ↗

Applicability: Section 10b EEG covers plants above 25 kW in direct marketing, Section 9(2a) EEG plants from 25 kW with a control device under Section 29(1) no. 2 MsbG. Where control does not run via the gateway, transmission technology in line with the state of the art at commissioning must be used (Section 10b(2) sentence 2 EEG). Under the government draft for EEG 2027 the 25 kW threshold in Section 10b would be dropped.

  • Electricity grid operatorrole obligationTests controllability after a smart metering system and control device are installed and, from 2028, pays the plant operator EUR 100 for each year begun until the test succeeds.Typically affected: Grid control system / SCADA, Grid usage and customer billing
  • Default metering point operatoraffectedProvides data communication via the smart meter gateway and control device for direct marketing as a standard service.Typically affected: Gateway administration and CLS management
  • Direct marketeraffectedMoves retrieval of actual feed-in and remote control for plants with a smart metering system to the smart meter gateway channel.Typically affected: Direct marketing and remote control
  • Plant operator (generation)role obligationEnsures that, from 2028 and once a smart metering system is installed, the direct marketer can read and control the plant via the smart meter gateway.Typically affected: Plant master data and MaStR
Applies from1 January 2028

WaKandA: hydrogen network access rules and joint booking platform

Gas gridSupplierBalancing

Operators of regulated hydrogen networks apply the WaKandA network access rules from 1 January 2028 and allocate entry and exit capacity through a joint capacity booking platform. Existing entry and exit contracts are adapted by then.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce No specific administrative offence is listed. The regulator can enforce compliance by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG; failing to comply with an enforceable order under Section 65(1) or (2) is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Only hydrogen networks within Part 3 Section 3b EnWG (core network, hydrogen infrastructure confirmed under Section 15d(3) sentence 1 EnWG and opt-in under Section 28j(3) EnWG) and their shippers.

  • Gas grid operatorcheck applicabilityChecks whether its own hydrogen network is covered, adapts contracts and connects capacity allocation to the joint platform.Typically affected: Market communication gateway (EDIFACT, AS4, API), Grid usage and customer billing, Regulatory management, controlling
  • Suppliercheck applicabilityAs a hydrogen shipper, checks which bookings and registrations on the platform will be needed.Typically affected: Trading and procurement system (ETRM)
  • Balance responsible partycheck applicabilityChecks how balancing and capacity booking interact in the hydrogen market area under the new rules.Typically affected: Trading and procurement system (ETRM)

Linked to: WaKandA: publish an overview of the hydrogen clusters

Applies from1 January 2028

Metering point operators: data communication for the balancing market via the gateway on request

MeteringCompetitive metering

From 1 January 2028 metering point operators must, on request, offer as an additional service the data communication needed to take part in the balancing market via the smart meter gateway, including the IT connection (Section 34(2) sentence 2 no. 5 MsbG). They may only refuse while the service is technically impossible or while they are exempt from it under Section 31(1) MsbG, and only with comprehensible reasons in text form (Section 34(2) sentences 3 and 5 MsbG).

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG sets no administrative offence. The Federal Network Agency can order measures under Section 76 MsbG and enforce them with coercive fines under Section 94 EnWG (Section 76(4) MsbG). Legal basis ↗

Applicability: Applies when an entitled party requests the service: energy supply undertakings, direct marketers, final consumers, parties seeking connection under the EEG, plant operators and connection owners, each for themselves or their customers (Section 34(2) sentence 2 MsbG), at metering points with a smart metering system.

  • Default metering point operatorrole obligationBuilds an offer for balancing market data communication via gateway administration and the CLS channel and sets a price for the additional service.Typically affected: Gateway administration and CLS management, EDM / MDM
  • Competitive metering point operatorrole obligationBuilds an offer for balancing market data communication via gateway administration and the CLS channel.Typically affected: Gateway administration and CLS management, EDM / MDM
Applies from1 January 2028

Hydrogen meters: only devices that connect to the smart meter gateway

MeteringCompetitive metering

From 1 January 2028 new hydrogen meters may only be installed if they can be securely connected to a smart meter gateway (Section 20(3) with (1) MsbG).

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG sets no administrative offence. The Federal Network Agency can order measures under Section 76 MsbG and enforce them with coercive fines under Section 94 EnWG (Section 76(4) MsbG). Legal basis ↗

  • Default metering point operatorrole obligationProcures only gateway-capable meters for hydrogen metering points from 2028.Typically affected: Gateway administration and CLS management, Field service and work orders
  • Competitive metering point operatorrole obligationProcures only gateway-capable meters for hydrogen metering points from 2028.Typically affected: Gateway administration and CLS management, Field service and work orders
Applies from1 January 2028

WasABi: balancing rules for hydrogen apply, data platform from July 2027

Gas gridSupplierBalancing

The hydrogen market area manager and the hydrogen network operators apply the WasABi balancing rules from 1 January 2028 (BK7-24-01-014, operative point 10). The market area manager sets up the data exchange platform by 1 July 2027 and tests it with market participants until 1 January 2028 (operative point 7(d)); the hydrogen network operators supply it with the data it needs.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Gas grid operatorrole obligationAs a hydrogen network operator, supplies the market area manager with the data it needs, equips it as a transport network operator by 1 January 2028 and balances under WasABi from 1 January 2028.Typically affected: EDM / MDM, Market communication gateway (EDIFACT, AS4, API)
  • SupplieraffectedAligns hydrogen supply with the balancing rules from 2028.Typically affected: Trading and procurement system (ETRM)
  • Balance responsible partyaffectedRuns hydrogen balancing groups under the WasABi rules from 1 January 2028 and joins platform testing beforehand.Typically affected: Trading and procurement system (ETRM)

Linked to: WaKandA: hydrogen network access rules and joint booking platform

Applies from1 January 2028

Avoided network charges: 75 per cent cut from 2028

Power gridGeneration

Electricity DSOs cut the avoided upstream costs underlying the charges for decentralised feed-in in stages: by 50 per cent from 1 July 2026 and from 1 January 2027, and by 75 per cent from 1 January 2028 (GBK-25-02-1#1, operative point 2).

Regulatory ruling · adopted

If the deadline is missed: Fine possible The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationSettles avoided network charges with a 75 per cent cut from 1 January 2028 and reflects this in the planned cost approach of the revenue cap.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Plant operator (generation)affectedReceives much lower payments for avoided network charges for decentralised feed-in from 2028.Typically affected: Plant master data and MaStR
Applies from1 March 2028

VDE-AR-N 4105: deadline for power limitation evidence

Power gridGeneration

According to VDE FNN, power limitation under Section 9 EEG can be implemented until 1 March 2028 through P AV,E protection certified under VDE-AR-N 4105:2026-03, P AV,E monitoring certified under the 2018-11 edition, or a permanent active power reduction at the inverter.

Technical rule · adopted

If the deadline is missed: Money is lost The application rule itself carries no penalty. Power limitation is a duty under Section 9(2) EEG, however; a breach obliges the operator to pay the network operator EUR 10 per kilowatt of installed capacity and calendar month under Section 52(1) no. 1 and (2) EEG, reduced retroactively to EUR 2 once the duty is met (Section 52(3) no. 1 EEG). Legal basis ↗

Applicability: Concerns generation plants on the low-voltage grid with power limitation under Section 9 EEG. For certificates under the 2018-11 edition VDE FNN names two transition periods, 12 months after DIN VDE V 0124-100 takes effect and 24 months after the application rule took effect; the certificates suffice "until one of the two periods expires".

  • Electricity grid operatoraffectedFrom March 2028 checks in connection requests whether power limitation is evidenced under the 2026-03 edition or by permanent reduction, and updates forms and TAB.Typically affected: Customer and grid connection portal, Plant master data and MaStR
  • Plant operator (generation)check applicabilityFor new installations checks which evidence of power limitation still suffices after the cut-off date.Typically affected: Plant master data and MaStR

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

Due by1 March 2028

Report the long-term gas and hydrogen forecast to the gas TSO

Gas grid

For the scenario framework of the gas and hydrogen network development plan, the directly downstream DSOs report their long-term forecast to the gas TSOs by 1 March of each even year; their own downstream networks must send them their forecast at least 20 working days earlier (KoV Section 16 no. 2).

Technical rule · adopted

If the deadline is missed: No direct legal consequence If a downstream operator cannot determine the forecast, it must give reasons and the upstream operator sets suitable forecast values (KoV Section 16 no. 2). The agreement sets no further sanction. Legal basis ↗

  • Gas grid operatorrole obligationCollects the forecasts of downstream networks, prepares the long-term gas and hydrogen forecast and reports it to the gas TSO by 1 March 2028.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling

Q2 2028

8 deadlines
Due by1 April 2028

AgNes: network operators identify prosumers and notify suppliers

Regulatory ruling · not yet adoptedPower gridSupplier

For the prosumer base price surcharge from 2029, network operators first identify metering points with prosumer status by 1 April 2028 and provide the information to suppliers via market communication (AgNes draft ruling, operative point 17.8).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationIdentifies prosumer metering points by 1 April 2028 and reports them via market communication.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
  • SupplieraffectedTakes the prosumer flag into billing and customer master data.Typically affected: SAP IS-U / S/4HANA Utilities
Applies from1 April 2028

AgNes: show prosumer status on the electricity bill

Regulatory ruling · not yet adoptedSupplier

Electricity suppliers show the prosumer status of the metering point on the energy bill from 1 April 2028 (AgNes draft ruling, operative point 8.3).

If the deadline is missed: Regulator can enforce The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Supplierrole obligationAdds the prosumer flag to bill layout and billing from 1 April 2028.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing
Due by30 April 2028

EU ETS 2: report on passing allowance costs on to consumers (Section 43(3) TEHG)

Supplier

Regulated entities under EU ETS 2, such as gas suppliers, report to the competent authority for calendar years 2027 to 2029, each by the end of 30 April of the following year, the average share of costs from surrendering ETS 2 allowances that they passed on to consumers in the previous year (Section 43(3) TEHG). The first report is due on 30 April 2028, the last on 30 April 2030.

Law · adopted

If the deadline is missed: Fine possible Failing to submit the report under Section 43(3) TEHG, or submitting it incorrectly, incompletely or late, is an administrative offence (Section 49(3) no. 9 TEHG); the fine is up to EUR 100,000 (Section 49(7)). Legal basis ↗

Applicability: The postponement of EU ETS 2 to 2028 (Article 2 of Regulation (EU) 2026/667 with Article 30k(2) of Directive 2003/87/EC) changes neither Article 30f(3) of the Directive nor Section 43(3) TEHG. The first surrender is only due on 31 May 2029. The Commission sets report requirements and templates in implementing acts (Article 30f(3) of Directive 2003/87/EC). 30 April 2028 is a Sunday.

  • Supplierrole obligationDetermines the share of ETS 2 allowance costs passed on to customers through the previous year's prices and reports it by 30 April 2028.Typically affected: SAP IS-U / S/4HANA Utilities, Grid usage and customer billing
Applies from1 June 2028

Energy sharing across the grid boundary

Power gridSupplier

From 1 June 2028 energy sharing must also work with the balancing area of a directly adjacent DSO in the same control area; the adjacent operator must cooperate. 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 operatorrole obligationEnsures with the directly adjacent operator in the same control area that energy sharing works across the grid boundary; 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 with 100,000 inhabitants or fewer

Gas gridHeat network

After the large cities, heat plans must be drawn up for all other municipal areas by 30 June 2028; 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 federal states must ensure heat plans are drawn up and usually delegate the duty to municipalities by ordinance (Section 4(1), Section 33(1) WPG); the population on 1 January 2024 is decisive. 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
Due by30 June 2028

Submit the draft scenario framework for electricity and for gas and hydrogen

Gas gridTSO

TSOs with control area responsibility submit the draft electricity scenario framework to the regulator by the end of 30 June of each even year (Section 12a(2) sentence 1 EnWG). For gas and hydrogen the coordination office of the gas TSOs submits it for approval on the same date (Section 15b(4) sentence 1 EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Sections 12a and 15b EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

  • Gas grid operatoraffectedGas TSOs submit the gas and hydrogen draft via the coordination office; gas DSOs deliver the long-term forecast for it by 1 March 2028.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
  • Transmission system operatorrole obligationPrepares the draft 2028 electricity scenario framework and submits it by 30 June 2028.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling

Linked to: Report the long-term gas and hydrogen forecast to the gas TSO

Due by30 June 2028

AgNes: DSOs report feed-in data to the TSO

Regulatory ruling · not yet adoptedPower gridTSO

Connecting distribution system operators send the control-area TSO, by 30 June each year, the data from two years earlier that it needs to calculate the capacity-based feed-in charge (AgNes draft ruling, operative point 9.5).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationSupplies feed-in capacity, gross capacity and feed-in volume of generation plants to the TSO by 30 June.Typically affected: EDM / MDM, Regulatory management, controlling
  • Transmission system operatoraffectedCollects the data for calculating the feed-in charge.Typically affected: Regulatory management, controlling
Due by30 June 2028

AgNes: final consumption data to the upstream network operator

Regulatory ruling · not yet adoptedPower grid

Electricity network operators send the upstream operator the data on grid-related final consumption for the following year's cost allocation key each year; operators without downstream distributors by 30 June, the others two weeks later, first in 2028 for 2029 (AgNes draft ruling, operative point 5.8).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance under Section 65 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationSupplies grid-related final consumption to the upstream operator by 30 June.Typically affected: EDM / MDM, Regulatory management, controlling

Q3 2028

5 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 operatorrole obligationConnects newly installed interval-metered gas meters to existing smart meter gateways.Typically affected: Gateway administration and CLS management, EDM / MDM
Due by1 July 2028

"Use instead of curtail": first evaluation and report (Section 13k(9) EnWG)

Power gridTSO

TSOs with control area responsibility evaluate the application of "use instead of curtail" under Section 13k(1) to (7) EnWG for the first time by 1 July 2028 and every two years thereafter and submit a report. DSOs that have used the option under subsection 8 for at least twelve months evaluate their application likewise (Section 13k(9) EnWG).

Law · adopted

If the deadline is missed: Regulator can enforce Section 13k EnWG sets no specific administrative offence. The regulator can enforce the duty under Section 65(2) EnWG with coercive fines under Section 94 EnWG; failing to comply with an enforceable order is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Duty of TSOs with control area responsibility; DSOs only if they have applied Section 13k(8) EnWG for at least twelve months.

  • Electricity grid operatorcheck applicabilityChecks whether it has used the option under Section 13k(8) for at least twelve months; if so, it evaluates its own application by the same date.Typically affected: Grid control system / SCADA, Regulatory management, controlling
  • Transmission system operatorrole obligationEvaluates the application of "use instead of curtail" and submits the report by 1 July 2028.Typically affected: Grid control system / SCADA, Regulatory management, controlling
Due by5 August 2028

Methane Regulation: report the methane intensity of production

SupplierCompany-wide

By 5 August 2028 and every year thereafter, producers in the Union and importers report, for supply contracts concluded or renewed since 4 August 2024, the methane intensity of the production of the natural gas, crude oil and coal they place on the Union market (Article 29(1) Regulation (EU) 2024/1787).

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. The Commission recommends that member states do not apply the penalties under Article 33(5)(m), (n) and (o) to importers' breaches of the obligations for 2027, 2028 and 2029, except in cases of fraud (Recommendation (EU) 2026/1835); the obligation itself remains. There is no German implementing act yet; the ministerial draft is still being coordinated within the federal government (Bundestag printed paper 21/8334). Legal basis ↗

Applicability: Producers in the Union and importers under Regulation (EU) 2024/1787 that place crude oil, natural gas or coal on the Union market. Suppliers buying on the wholesale market inside the Union without producing themselves are neither producers nor importers.

  • Suppliercheck applicabilityObtains the methane intensity per supply contract from producers and reports it by 5 August.Typically affected: Trading and procurement system (ETRM)
  • Company-wide, several rolescheck applicabilityAs an importer, reports the methane intensity by 5 August.Typically affected: Trading and procurement system (ETRM)
Due by30 September 2028

AgNes: final consumption data to the Federal Network Agency

Regulatory ruling · not yet adoptedPower grid

Electricity DSOs send the Federal Network Agency the data on grid-related final consumption for the following year electronically each year by 30 September, first in 2028 for 2029 (AgNes draft ruling, operative point 5.9). The draft's reasoning gives 31 August instead.

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance under Section 65 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatorrole obligationSubmits grid-related final consumption electronically to the Federal Network Agency by 30 September.Typically affected: Regulatory management, controlling

Q4 2028

8 deadlines
Due by1 October 2028

AgNes: TSOs adjust network charges by 1 October

Regulatory ruling · not yet adoptedPower gridTSO

Under the AgNes draft, TSOs adjust their network charges for the following year by 1 October, DSOs by 15 October (operative point 14.4 sentence 1).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatoraffectedFeeds the upstream charges into its own calculation by 15 October.Typically affected: Regulatory management, controlling
  • Transmission system operatorrole obligationAdjusts the network charges for the following year by 1 October.Typically affected: Regulatory management, controlling, Grid usage and customer billing
Due by15 October 2028

AgNes: publish the uniform national feed-in charge

Regulatory ruling · not yet adoptedTSOGeneration

The TSOs determine a uniform national capacity-based feed-in charge each year and publish it by 15 October for the following year as a separate item in the price sheet, first in 2028 for 2029 (AgNes draft ruling, operative point 9.2).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Under the draft, only operators of generating plants above 30 kW installed gross capacity without a transition period under item 17.4 must pay; prosumers paying the low-voltage base price surcharge and plug-in solar devices are exempt (item 9.1).

  • Transmission system operatorrole obligationCalculates the feed-in charge and publishes it in the price sheet by 15 October.Typically affected: Regulatory management, controlling
  • Plant operator (generation)affectedBudgets the feed-in charge from 2029 in the plant's economics.Typically affected: Plant master data and MaStR
Due by31 October 2028

Grid expansion plan under section 14d EnWG: filing due 31 October 2028

Power grid

Distribution system operators with 100,000 or more customers submit their next grid expansion plan to the Federal Network Agency by 31 October 2028, in the statutory two-year cycle following the 2026 plan. Smaller operators are covered only if they curtailed more than 3 percent of onshore 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 operatorrole obligationChecks 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 byDate open; December 2028 at the earliest, for existing KRITIS operators three years after their last audit

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; for existing KRITIS operators at the earliest three years after their last audit under the former Section 8a(3) BSIG (Section 39(3) BSIG).

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. Until the ordinance under the KRITIS umbrella act applies, classification as a critical installation still follows the former version (Section 66 BSIG), that is the BSI-KritisV.

  • 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 by14 December 2028

AgNes: explain a late adjustment of network charges for 1 January

Regulatory ruling · not yet adoptedPower gridTSO

If network operators adjust their network charges again for 1 January because of significant later deviations, they explain this to the regulator at least 10 working days before 1 January (AgNes draft ruling, operative point 14.4 sentences 2 and 3). For 1 January 2029 that is 14 December 2028 (working days Monday to Friday).

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Only if an operator makes a late adjustment, and under operative point 18 of the draft only for operators under the Federal Network Agency's responsibility.

  • Electricity grid operatorrole obligationExplains a late adjustment of charges for 1 January at least 10 working days beforehand.Typically affected: Regulatory management, controlling
  • Transmission system operatorrole obligationExplains a late adjustment of charges for 1 January at least 10 working days beforehand.Typically affected: Regulatory management, controlling
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

Due by31 December 2028

Smart meter rollout: 90 percent of new generation capacity by the end of 2028, for the first time also above 100 kilowatts

Power gridMetering

By the end of 2028 default metering point operators must have equipped, for systems above 7 and up to 100 kilowatts, at least 90 percent of the capacity commissioned from 1 October 2026 to 30 September 2028 and at least 50 percent of the capacity commissioned from 1 January 2018 to 25 February 2025. For systems above 100 kilowatts equipping starts in 2028 at the latest, and by the end of 2028 the equipped metering points must cover 90 percent of the capacity commissioned from 1 October 2027 to 30 September 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 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. 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 systems above 7 and up to 100 kW to cover 90 percent of the capacity commissioned from October 2026 to September 2028 and 50 percent of the capacity from 2018 to February 2025, and starts equipping systems above 100 kW.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of new generation capacity from plants above 7 and up to 100 kilowatts

Due by31 December 2028

Smart meter rollout: 90 percent for final consumers above 100,000 kWh by end of 2028

Metering

For final consumers with more than 100,000 kWh annual consumption (Section 30(1) no. 1 MsbG), default metering point operators start installing smart metering systems in 2028 at the latest and equip at least 90 percent of the metering points to be newly equipped per installation case group in that period by the end of 2028 (Section 45(1) sentence 1 no. 3(a) MsbG). Further milestones follow at the end of 2030 and 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). Legal basis ↗

  • Default metering point operatorrole obligationPlans installation and communication for large consumers above 100,000 kWh from 2028 and reaches the 90 percent quota per case group by the end of 2028.Typically affected: Gateway administration and CLS management, Field service and work orders, EDM / MDM

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

Q1 2029

6 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: Fine possible 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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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 ↗

Applicability: The network reliability quality element only applies to electricity DSOs in the standard procedure; under operative item 2 sentence 3 of the ruling it does not apply to operators in the simplified procedure and micro operators, and the Federal Network Agency is evaluating an extension.

  • 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 either the connection user has consented or the installation was made on the basis of a BSI determination under the old law (version of 26 May 2023). 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 of its own. 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 (Section 76(4) MsbG). Whether breaching such an order can be fined as an administrative offence under Section 95 EnWG is unsettled, because Section 95(1) no. 3(a) EnWG only lists orders under the EnWG, such as Section 65, and none under the MsbG. 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 the connection user's consent for continued use, unless the installation already rests on a BSI determination under the old law.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

Due by1 January 2029

AgNes: submit network charge review data and charge report by 1 January

Regulatory ruling · not yet adoptedPower gridTSO

Operators of public electricity networks send the regulator, by 1 January each year, the data needed to review network charges together with a report on how the charges were calculated: basis and process under operative point 14, the documented allocation keys and other relevant aspects, so that an expert third party can follow the calculation without further information (AgNes draft ruling, operative point 16). The duty replaces the data and reporting duties under Section 28 StromNEV and Section 28 ARegV.

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance under Section 65 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Only network operators within the Federal Network Agency's remit under Section 54(1) and (2) EnWG (operative point 18); state regulators may set their own procedural rules. First date 1 January 2029, because network charges are set under AgNes from then on (operative point 1.2) and StromNEV and ARegV for electricity expire at the end of 31 December 2028; the draft gives no separate start date for operative point 16. Until 1 January 2028 Section 28 ARegV applies (aregv-28-mitteilungen-1-januar-2027).

  • Electricity grid operatorrole obligationSubmits the network charge review data with the report on how the charges were calculated by 1 January.Typically affected: Regulatory management, controlling, Grid usage and customer billing
  • Transmission system operatorrole obligationSubmits the network charge review data with the report on how the charges were calculated by 1 January.Typically affected: Regulatory management, controlling

Linked to: AgNes: framework ruling on electricity grid charges

Q2 2029

2 deadlines
Due by1 April 2029

WaKandA: hydrogen network operators' joint annual report to Ruling Chamber 7

Gas grid

Operators of regulated hydrogen networks submit a joint report on the previous year to Ruling Chamber 7 by 1 April each year, first by 1 April 2029 for 2028: number of clusters, status of cluster connections and cross-cluster capacity, booking rates of capacity products and the booking situation at border points, storage facilities and terminals. The report is combined with the reporting duties under the WasABi ruling and published by the Federal Network Agency.

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce No specific administrative offence is listed. The regulator can enforce compliance by order under Section 65 EnWG, backed by coercive fines under Section 94 EnWG; failing to comply with an enforceable order under Section 65(1) or (2) is an administrative offence under Section 95(1) no. 3(a) EnWG. Legal basis ↗

Applicability: Only operators of hydrogen networks within Part 3 Section 3b EnWG: the hydrogen core network, hydrogen infrastructure confirmed under Section 15d(3) sentence 1 EnWG, or operators that opted in under Section 28j(3) EnWG. The duty covers all hydrogen network operators, not only transmission operators (reasoning, para. 215).

  • Gas grid operatorcheck applicabilityChecks whether its own hydrogen network is covered and then supplies the previous year's cluster, capacity and booking data for the joint report.Typically affected: Regulatory management, controlling, Grid planning, GIS, load flow
Due by31 May 2029

EU ETS 2: first surrender of allowances for 2028 emissions

SupplierCompany-wide

Regulated entities under the EU ETS 2, for example suppliers placing natural gas or heating oil on the market for buildings and transport, surrender allowances for 2028 emissions for the first time by 31 May 2029, then each year by 31 May for the previous year (Article 30k(2)(d) of Directive 2003/87/EC, applicable by virtue of Article 2 of Regulation (EU) 2026/667). The wording of Section 7(2) TEHG has not been adapted to the postponement.

Law · adopted

If the deadline is missed: Money is lost For each tonne without a surrendered allowance the authority sets a payment of EUR 100, adjusted to the European consumer price index; the missing allowances must be surrendered by 31 May of the following year, and names are published in the Federal Gazette (Section 46(1), (3) and (4) TEHG). Legal basis ↗

  • Supplierrole obligationBuys allowances for the 2028 fuel volumes and surrenders them by 31 May 2029.Typically affected: Trading and procurement system (ETRM), Grid usage and customer billing
  • Company-wide, several rolesrole obligationAs the entity placing fuels on the market, surrenders allowances by 31 May.Typically affected: Trading and procurement system (ETRM)

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

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 operatoraffectedReimburses DSOs for lost revenue only for exempt electrolysers (Section 118(6) sentence 9 EnWG), not for other storage.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)

Q1 2030

1 deadline
Applies from1 January 2030

Heat networks: at least 30 percent renewable heat or waste heat from 2030

Heat network

Every heat network must cover at least 30 percent of its annual net heat generation from renewables, unavoidable waste heat or a combination from 1 January 2030 and at least 80 percent from 1 January 2040 (Section 29(1) WPG), unless an exemption or deferral under Section 29(2) to (5) applies.

Law · adopted

If the deadline is missed: Civil-law consequence Customers can demand proof of compliance; if a heat network does not comply, they have the right to disconnect (Section 29(7) WPG). The WPG contains no fine. Legal basis ↗

  • Heat network operatorrole obligationPlans the generation mix and investments so that at least 30 percent of net heat generation is renewable or waste heat from 2030 and keeps proof ready for customers.Typically affected: Plant master data and MaStR, Regulatory management, controlling

Linked to: WPG § 32: decarbonisation roadmap for heat networks

Q3 2030

2 deadlines
Due by5 August 2030

Methane Regulation: meet maximum methane intensity values

SupplierCompany-wide

By 5 August 2030 and every year thereafter, producers in the Union and importers prove for supply contracts concluded or renewed after 5 August 2030 that the methane intensity of production is below the maximum values the Commission sets by delegated act (Article 29(2) Regulation (EU) 2024/1787).

Law · adopted

If the deadline is missed: Regulator can enforce Article 33 of the Methane Regulation (EU) 2024/1787 requires member states to lay down effective penalties, at least fines and periodic penalty payments. Legal basis ↗

Applicability: Producers in the Union and importers under Regulation (EU) 2024/1787 that place crude oil, natural gas or coal on the Union market. Suppliers buying on the wholesale market inside the Union without producing themselves are neither producers nor importers.

  • Suppliercheck applicabilityFrom August 2030 only concludes supply contracts with volumes below the maximum values and proves this each year.Typically affected: Trading and procurement system (ETRM)
  • Company-wide, several rolescheck applicabilityAs an importer, proves compliance with the maximum values from 2030.Typically affected: Trading and procurement system (ETRM)
Due by15 September 2030

AgNes: publish the final settlement of the surcharge for special grid use

Regulatory ruling · not yet adoptedPower gridTSO

The TSOs publish on their joint website, by 15 September each year, the final settlements of the surcharge for special grid use and, per DSO, the payments for the previous year (AgNes draft ruling, operative point 15.6 sentence 1 no. 2), first for the year 2029.

If the deadline is missed: Fine possible The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Once adopted, a breach is also, for network operators, an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

  • Electricity grid operatoraffectedSupplies the final settlement data to the TSO.Typically affected: Grid usage and customer billing
  • Transmission system operatorrole obligationPublishes the final settlement of the surcharge by 15 September on the joint website.Typically affected: Regulatory management, controlling

Q4 2030

3 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

Due by31 December 2030

Smart meter rollout: 90 percent of new generation capacity by the end of 2030

Power gridMetering

By the end of 2030 default metering point operators must have equipped at least 90 percent of the generation capacity commissioned from 1 October 2028 to 30 September 2030, separately for systems above 7 and up to 100 kilowatts and systems above 100 kilowatts. 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. 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 so that 90 percent of the capacity commissioned from October 2028 to September 2030 is covered.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of new generation capacity by the end of 2028, for the first time also above 100 kilowatts

Q1 2031

3 deadlines
Due by1 January 2031

Redispatch 2.0: move controllable resources into the plan-value model

Power gridTSODirect marketing

By 1 January 2031, distribution system operators, in coordination with the TSOs, are to move at least all controllable resources that can improve the efficiency of congestion management in the transmission grid into the plan-value model (BK6-23-241, annex BilAReM, section 2.3.1).

Regulatory ruling · adopted

If the deadline is missed: Regulator can enforce The ruling frames the target as a "should" requirement. The Federal Network Agency can order implementation of rulings under Section 65 EnWG. Legal basis ↗

  • Electricity grid operatorrole obligationPlans the move of relevant controllable resources into the plan-value model by 2031 with the TSO.Typically affected: Grid control system / SCADA, Direct marketing and remote control, Market communication gateway (EDIFACT, AS4, API)
  • Transmission system operatoraffectedAgrees with the DSOs which resources belong in the plan-value model.Typically affected: Grid control system / SCADA
  • Direct marketeraffectedSupplies plan values instead of operator forecasts for transferred plants.Typically affected: Trading and procurement system (ETRM)
Applies from1 January 2031

Hydrogen networks: publish network charge setting and methods

Gas grid

From 1 January 2031 hydrogen network operators or the regulators publish complete information on network charge setting, methods and charge structure (Article 66(2) Regulation (EU) 2024/1789).

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency performs the regulator's tasks under Regulation (EU) 2024/1789 and applies the procedural rules of the EnWG (Section 56(1) sentence 1 no. 2 EnWG); it can order compliance under Section 65 EnWG. Legal basis ↗

Applicability: Operators of hydrogen networks; in Germany mainly the operators of the hydrogen core network.

  • Gas grid operatoraffectedAs a hydrogen network operator, prepares publication of charge setting from 2031.Typically affected: Regulatory management, controlling, Customer and grid connection portal
Due by31 March 2031

Simplified procedure gas for the sixth regulatory period: application

Gas grid

Gas distribution system operators that want to use the simplified procedure or the very small operator rule in the sixth regulatory period (2033 to 2035) apply by 31 March of the second-to-last year before the period starts, i.e. by 31 March 2031 (RAMEN Gas, operative points 2.3, 3.1, 16.6 and 16.9). From the sixth period on each period lasts three years, so the next application is due on 31 March 2034.

Regulatory ruling · adopted

If the deadline is missed: Exclusion or loss of role Without an application the standard procedure with efficiency benchmarking applies for the whole regulatory period; the operator is bound to the chosen procedure for the period (RAMEN Gas, operative point 16.6 sentence 3). Legal basis ↗

Applicability: Gas distribution system operators below the thresholds for the simplified procedure or the very small operator rule under RAMEN Gas. The application and notification deadline is a procedural rule under RAMEN Gas para. 19 and only applies to operators that fall within the Federal Network Agency's remit under Section 54(1) and (2) EnWG; for the others the state regulatory authority sets the procedure.

  • Gas grid operatorrole obligationDecides on the simplified procedure for 2033 to 2035 and applies by 31 March 2031.Typically affected: Regulatory management, controlling

Q4 2031

2 deadlines
Due by31 October 2031

Capacity market: apply to complete provisional prequalification by 31 October 2031

Direct marketingGeneration

Capacity providers with provisional prequalification submit the application to complete it, with the data and evidence under Section 62 StromVKG, to the responsible TSO via the joint platform by the end of 31 October 2031 (Section 61(2) StromVKG). By then every plant in a plant pool must have a smart metering system and load profile metering (Section 21 StromVKG).

Law · adopted

If the deadline is missed: Exclusion or loss of role Without a timely application the TSO refuses to complete the provisional prequalification (Section 63(3) StromVKG). The award then lapses (Section 53 sentence 1 no. 4), and for commitment periods of more than one year the non-realisation penalty is owed to the TSO (Section 64(1)). Legal basis ↗

  • Direct marketeraffectedPlans smart metering for plant pools by 31 October 2031.Typically affected: Direct marketing and remote control
  • Plant operator (generation)role obligationApplies to complete prequalification by 31 October 2031 and equips pool plants with smart metering and load profile metering.Typically affected: Plant master data and MaStR, Regulatory management, controlling
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

3 deadlines
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

Due by31 December 2032

Smart meter rollout: 90 percent of total generation capacity

Power gridMetering

By the end of 2032 default metering point operators must have equipped metering points covering at least 90 percent of the total installed generation capacity, separately for systems above 7 and up to 100 kilowatts and systems above 100 kilowatts. 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. 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 so that 90 percent of the total installed capacity is covered.Typically affected: Gateway administration and CLS management, Field service and work orders

Linked to: Smart meter rollout: 90 percent of new generation capacity by the end of 2030

Due by31 December 2032

Modern metering devices: equip all remaining metering points by end of 2032

Metering

Where no smart metering system is planned, default metering point operators equip metering points of final consumers and plant operators at least with modern metering devices, where economically justifiable, by the end of 31 December 2032; for new buildings and major renovations by completion of the building (Section 29(3) MsbG).

Law · adopted

If the deadline is missed: Regulator can enforce The MsbG sets no administrative offence. The Federal Network Agency can order measures under Section 76 MsbG and enforce them with coercive fines under Section 94 EnWG (Section 76(4) MsbG). Legal basis ↗

  • Default metering point operatorrole obligationPlans the replacement of remaining Ferraris and electronic meters with modern metering devices by end of 2032.Typically affected: Field service and work orders, EDM / MDM

Q1 2033

2 deadlines
Applies from1 January 2033

AgNes: dynamic network charge for battery storage at levels 1 to 5

Regulatory ruling · not yet adoptedPower gridTSOStorage

Network operators set up a dynamic network charge and bill it to battery storage operators at grid and transformer levels 1 to 5 from 1 January 2033 at the latest, not before 1 January 2030 (AgNes draft ruling, operative point 12.2 sentence 1, subject to the condition in operative point 12.3).

If the deadline is missed: Regulator can enforce The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Electricity grid operatorrole obligationSets up calculation and billing of the dynamic network charge for storage by 2033 at the latest.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Transmission system operatorrole obligationSets up calculation and billing of the dynamic network charge for storage by 2033 at the latest.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Storage operatoraffectedAligns storage operation with the dynamic charge.Typically affected: Plant master data and MaStR, Trading and procurement system (ETRM)
Applies from1 January 2033

Hydrogen transmission: entry-exit rules and charges on the ENNOH platform

Gas grid

From 1 January 2033 hydrogen networks are organised as entry-exit systems (Article 7(6) Regulation (EU) 2024/1789), and hydrogen transmission network operators meet the requirements for transmission system operators under Articles 5, 10 and 13 of Regulation (EU) 2024/1789 and publish the network charges for each network point on the platform of the European Network of Network Operators for Hydrogen (ENNOH) (Article 7(9)).

Law · adopted

If the deadline is missed: Regulator can enforce The Federal Network Agency performs the regulator's tasks under Regulation (EU) 2024/1789 and applies the procedural rules of the EnWG (Section 56(1) sentence 1 no. 2 EnWG); it can order compliance under Section 65 EnWG. Legal basis ↗

  • Gas grid operatorrole obligationAs a hydrogen transmission operator, moves capacity services and charge publication to the EU rules by 2033.Typically affected: Regulatory management, controlling, Customer and grid connection portal

Linked to: WaKandA: hydrogen network access rules and joint booking platform

Q1 2035

1 deadline
Applies from1 January 2035

AgNes: dynamic network charge for generation plants at levels 1 to 5

Regulatory ruling · not yet adoptedPower gridTSOGeneration

Network operators bill the dynamic network charge to operators of generation plants at grid and transformer levels 1 to 5 from 1 January 2035 at the latest, not before 1 January 2032; offshore wind is exempt (AgNes draft ruling, operative point 12.2 sentence 2, subject to the condition in operative point 12.3).

If the deadline is missed: Regulator can enforce The draft ruling sets no specific consequence. Once adopted, the regulator can order compliance with the ruling under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

  • Electricity grid operatorrole obligationExtends the dynamic network charge to generation plants by 2035 at the latest.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Transmission system operatorrole obligationExtends the dynamic network charge to generation plants by 2035 at the latest.Typically affected: Grid usage and customer billing, Regulatory management, controlling
  • Plant operator (generation)affectedBudgets the dynamic charge from 2032 to 2035 in operation and economics.Typically affected: Plant master data and MaStR

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
  • date open1 deadline
  • End of September 20271 deadline
  • 1 October 20271 deadline

5 of 8 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 20264 deadlines
  • 1 January 20273 deadlines

7 of 7 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, passed
  • 31 October 20261 deadline, passed
  • 31 December 20261 deadline
  • End of 20262 deadlines
  • 1 January 20271 deadline
  • 30 April 20271 deadline
  • 1 October 20271 deadline
  • 14 October 20271 deadline
  • 15 October 20271 deadline
  • 31 October 20281 deadline

9 of 13 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 (17)

Show all 17
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 no earlier than two days and no later than two hours before the day-ahead auction closes (D-1, 10:00), 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

Since 1 October 2026 the new gas metering point operator framework contract applies; ruling BK7-17-026 was revoked on the same day. Gas network operators and all metering point operators conclude the contract in its current version and adapt existing contracts, and gas network operators publish it (BK7-24-01-009, operative items 13 to 15).

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. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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 operatorrole obligationConcludes 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). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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 have been binding since 1 October 2026 for all market participants required to implement the market communication determinations.

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, applied to metering point operators via Section 76(4) MsbG); breaching an enforceable order under Section 65 EnWG is an administrative offence under Section 95(1) no. 3(a) EnWG (up to EUR 100,000). Whether this also covers orders under Section 76 MsbG is unsettled: Section 76(4) MsbG applies Part 8 EnWG, except Section 91 and Division 6, accordingly and thus also Section 95, but Section 95(1) no. 3(a) EnWG only lists orders under the EnWG, such as Section 65, and none under the MsbG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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: Since 1 July 2026 default metering point operators conclude metering contracts only on the MSV-AN and MSV-LF templates, adapt existing metering contracts to them and publish them for conclusion in text form. Electricity network operators and all metering point operators conclude the framework contract (MSB-RV) in its amended version and adapt existing contracts.

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, adapts existing metering contracts to them and publishes both templates on its website so they can be concluded in text form.Typically affected: SAP IS-U / S/4HANA Utilities, Customer and grid connection portal
  • Competitive metering point operatorrole obligationSigns 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 operatorrole obligationEnsures under Section 42c(4) no. 1 EnWG that energy sharing is possible within its balancing area; under Notice No. 73 the service model suffices.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). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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 the BBK via the joint BSI/BBK registration facility no later than three months after a facility counts as critical (Section 8(1) KRITISDachG), plus resilience plans. When a facility counts as critical only follows from the ordinance setting the thresholds.

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. The thresholds at which a facility counts as critical are set by the ordinance under the act; the three-month registration period runs from that point.

  • 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: statutory duty since 2026

Power gridGas gridMeteringSupplier

Since 1 January 2026 the technical supplier switch must be completed within 24 hours and be possible on every working day (Section 20a(2) sentence 4 EnWG); under Section 3 no. 31 EnWG energy includes gas and hydrogen. So far the Federal Network Agency has set the processes only for electricity (star-shaped switch via the MaLo ID, BK6-22-024); it did not change the gas switching processes in BK7-24-01-009.

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). If the switch is not completed in time, the final customer can claim damages from the supplier or network operator responsible for the delay, which bears the burden of proving it is not responsible (Section 20a(4) EnWG). Affected customers and market partners can also demand remedy and cessation under Section 32 EnWG, and damages where there is fault. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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
  • Gas grid operatorcheck applicabilityChecks how the statutory 24-hour switch is implemented for gas while the gas switching processes remain unchanged.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
  • 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

In force since 6 December 2025 with no general implementation period: registration within three months (Section 33 BSIG; network operators outside NIS2 by 6 March 2026 under Section 5d(4) EnWG), 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. Under Section 95(2) to (4) EnWG, breaches under Section 95(1) nos. 3b to 3e carry fines of 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. 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 under Section 94 EnWG (EUR 1,000 to EUR 10 million) and names the companies concerned publicly (Section 74 EnWG); by 13 October 2026 it had threatened four network operators with a fine and imposed none. That list names only network operators, but in 2026 the agency did impose coercive fines to enforce supplier duties under Sections 40 and 41 EnWG (against one electricity supplier EUR 100,000 on 31 March 2026 and EUR 175,000 on 31 July 2026, case 4.07.01/8#2, not yet final). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 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 module 1 network charge reduction and the network charges per module 3 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 from1 March 2025

Section 14a: publish control measures monthly by the 15th

Power grid

Network operators that control devices in a grid-oriented or preventive way show the affected network areas on a joint web platform and publish, machine-readable per postcode of the network area, the type of control, the number of devices affected, the average power reduced and the total duration, in monthly resolution by the 15th calendar day of the following month, together with whether and which measures they take to reduce control actions and when these will be completed (BK6-22-300 Annex 1 para. 8.4(a) and (b), first from 1 March 2025 under para. 10.7).

Regulatory ruling · in force

If the deadline is missed: Fine possible BK6-22-300 sets no specific sanction. The regulator can order publication under Section 65(2) EnWG and enforce it with coercive fines under Section 94 EnWG. For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). Legal basis ↗

Applicability: Network operators are obliged for network areas in which control measures under para. 4 or 10.5 took place in the month.

  • Electricity grid operatorrole obligationEvaluates control actions per network area every month and posts them machine-readable on the joint platform by the 15th of the following month.Typically affected: Grid control system / SCADA, Customer and grid connection portal, Regulatory management, controlling
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 whose reference value was not already set in a bid date before that day, 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, plants below 2 kW only from the end of the year of the determination under Section 85(2) no. 12 EEG.

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. Excluded are plants whose reference value was set in a bid date after 31 December 2022 and before 25 February 2025 (Section 100(46) EEG: previous version) and biogas plants with an award, to which Section 51b EEG applies.

  • 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
Applies from27 May 2023

MsbG Section 3(3a): requested meter changes within one month

MeteringCompetitive metering

If a connection owner or user requests a change or addition to the meter in the low-voltage grid, for instance for a cascade connection, the metering point operator carries it out within one month of receiving the order. After six weeks the connection owner may have the work done by a qualified third party at its own cost.

Law · in force

If the deadline is missed: Regulator can enforce After six weeks the connection owner may have the work done by a qualified third party (Section 3(3a) sentence 2 MsbG). The Federal Network Agency can order compliance under Section 76 MsbG and enforce it with coercive fines under Section 94 EnWG (Section 76(4) MsbG); an association's injunction claim failed because, according to the Higher Regional Court of Schleswig (13 November 2025, 6 U 36/24), the provision is neither a market conduct rule nor a consumer protection law. Legal basis ↗

Applicability: Only meters in the low-voltage grid. The deadline does not apply where a smart meter gateway is already part of the metering point (Section 3(3a) sentence 6 MsbG).

  • Default metering point operatorrole obligationCarries out requested changes or additions to meters, for instance for cascade connections, within one month of the order.Typically affected: Field service and work orders
  • Competitive metering point operatorrole obligationSince 16 May 2024 (Solar Package I) carries out requested changes or additions to its own meters within one month of the order.Typically affected: Field service and work orders

Past dates (18)

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 18
Target31 December 2026

§ 14a control: target for working control

droppedPower gridMetering

Under the four-stage approach of Technical Study 2.0, a study by a consultancy, working control with core processes for first use cases is due by the end of 2026. No law and no authority sets this target; it is 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

Due by2 November 2026

EEG onshore wind tender: bid deadline 1 November 2026

Law · date passedDirect marketingGeneration

Bids for onshore wind turbines must reach the Federal Network Agency by the bid deadline; as 1 November 2026 is a Sunday, bids are due by midnight on Monday, 2 November 2026. According to the agency, the volume is about 2,495 MW and the 2026 ceiling price is 7.25 cents per kilowatt hour.

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 with a federal immission control permit granted and registered in the market master data register by 5 October 2026.

  • 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 by1 November 2026

Hydrogen core network: publish the network charge for the following year

Regulatory ruling · date passedGas gridSupplier

Operators of the hydrogen core network publish the network charge, during the ramp-up phase the ramp-up charge, by 1 November for the following calendar year and correct the publication without delay if the charge changes afterwards (WANDA, GBK-24-01-2#1, operative point 2 sentences 3 and 4, operative point 3).

If the deadline is missed: Regulator can enforce The ruling sets no specific consequence. The regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. Legal basis ↗

Applicability: Only operators of the hydrogen core network.

  • Gas grid operatorrole obligationAs a core network operator, publishes the charge for 2027 by 1 November 2026, then yearly.Typically affected: Regulatory management, controlling, Customer and grid connection portal
  • SupplieraffectedPrices hydrogen supply with the published core network charge.Typically affected: Trading and procurement system (ETRM)
Due by1 November 2026

Gas storage: 80 per cent fill level on 1 November, 30 per cent on 1 February

Law · date passedStorage

Gas storage operators ensure by contract that each facility is filled to 80 per cent of its working gas volume on 1 November 2026 and to 30 per cent on 1 February 2027. The Gas Storage Fill Level Ordinance sets these values in place of the 90 per cent in Section 35b(1) sentence 2 EnWG; Bad Lauchstädt, Frankenthal, Hähnlein, Rehden, Stockstadt and Uelsen need 45 per cent on 1 November, Bierwang, Breitbrunn, Inzenham-West and Wolfersberg 40 per cent on 1 February (Section 1 GasSpFüllstV). The ordinance and the fill level rules apply until the end of 31 March 2027 (Section 2 GasSpFüllstV, Section 35i EnWG).

If the deadline is missed: Regulator can enforce Section 35b(1) EnWG sets no specific sanction. Failing to make unused storage capacity available to the market area manager under Section 35b(5) is an administrative offence under Section 95(1) no. 4a EnWG. Legal basis ↗

Applicability: Only operators of gas storage facilities. The fill level rules expire on 31 March 2027 unless extended.

  • Storage operatorrole obligationManages injection so that 80 per cent (45 per cent at the six named facilities) is reached on 1 November 2026 and 30 per cent (40 per cent at the four named) on 1 February 2027, and reports unused capacity to the market area manager.Typically affected: Grid control system / SCADA, Trading and procurement system (ETRM)
Due by31 October 2026

Default metering point operators: publish services and price sheets by 31 October

Law · date passedMetering

Every year by 31 October, default metering point operators publish the scope of their installation duties under Section 29 MsbG, their standard and possible additional services, and price sheets with expected annual prices for at least three years (Section 37(1) MsbG). Prices for additional services must be reviewed at least every two years.

If the deadline is missed: Regulator can enforce The MsbG sets no penalty of its own for a missing publication. The Federal Network Agency can order it under Section 76(2) MsbG and enforce the order with coercive fines under Section 94 EnWG (Section 76(4) MsbG); whether breaching such an order can also be fined as an administrative offence under Section 95 EnWG is unsettled: Section 76(4) MsbG does refer to Part 8 of the EnWG and thus to Section 95, but Section 95(1) no. 3(a) EnWG only lists orders under the EnWG, such as Section 65, and none under the MsbG. Legal basis ↗

Applicability: Applies only to default metering point operators. Notice of installation to individual customers is governed by Section 37(2) MsbG (at least three months ahead).

  • Default metering point operatorrole obligationPublishes the scope of its installation duties, standard and additional services and price sheets for at least three years on its website.Typically affected: Customer and grid connection portal, Regulatory management, controlling
Due by31 October 2026

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

Regulatory ruling · date passedTSO

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.

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. 31 October 2026 is a Saturday; under Section 31(3) VwVfG, to which the deadline calendar refers, the deadline ends on Monday, 2 November 2026.

  • 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 by31 October 2026

Grid expansion plan under section 14d EnWG: filing due 31 October 2026

Law · date passedPower grid

Distribution system operators with 100,000 or more customers submit their grid expansion plan to the Federal Network Agency by 31 October 2026, the first filing in the statutory two-year cycle following the 2024 plans. Smaller operators are covered only if they curtailed more than 3 percent of onshore wind or solar output in each of the two previous years.

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 operatorrole obligationChecks 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

Comments by26 October 2026

Electricity efficiency benchmarking: data collection consultation closes

Consultation · closedPower 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 that do not take part in the simplified procedure or the micro operator procedure.

  • 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 by25 October 2026

2027 levies: publication by the transmission system operators

Law · date passedPower 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.

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 by21 October 2026

Redispatch without balancing: consultation on cost reimbursement closes

Consultation · closedPower gridGeneration

Ruling Chamber 8 is consulting on how DSOs pay plant operators compensation when redispatch measures are not balanced: under the draft, per MWh of curtailed energy, a blended price of 72.5 percent ID-AEP and 27.5 percent reBAP plus a flat EUR 1.35/MWh, with a negative blended price triggering a payment by the plant operator. 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
  • Plant operator (generation)affectedUnder the draft receives compensation per MWh of curtailed energy from the DSO; with a negative blended price the plant operator pays.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 operatoraffectedSubmitted the amendment together with the Austrian and Czech TSOs and applies the approved method at the Czech border.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: Fine possible 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). For network operators a breach is also an abuse of their market position (Section 30(1) sentence 2 no. 1 EnWG). The regulator can require it to stop (Section 30(2)) and can also establish it after the fact (Section 30(3)); for distribution system operators with fewer than 100,000 customers whose network does not extend beyond one federal state, the state regulatory authority is responsible (Section 54(2) no. 8). Section 95(1) nos. 4 and 3(b) EnWG threaten fines of up to EUR 1 million for the abuse and for breaching an order to stop it (Section 95(2) no. 3). Those affected can apply for abuse proceedings (Section 31) and claim removal, injunctive relief or, where there is fault, damages (Section 32 EnWG). 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 store grid power, with or without their own generation, subsidised or not. 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 the gas and hydrogen network development plan.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

Those affected and interested parties could comment on the draft decision on the flat-rate return on capital; it applies to gas distribution and transmission system operators. The draft proposes a 3.76 percent rate for the revenue caps from 2028; it only becomes binding with the final decision.

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. Since March 2026 the Bundesnetzagentur has opened supervisory proceedings against 434 companies that missed the quota; 150 of them had been closed by 21 September 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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