Deadline calendar: digitalising the German energy transition
As of: 23 September 2026
German grid operators, metering point operators and municipal utilities work against a dozen parallel deadlines from laws and regulatory rulings in 2026 and 2027. This calendar puts them on one timeline: date, obligation, who is affected, status and the article that explains the implementation.
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 hits the same systems in the same quarter
Each deadline on its own is manageable. It gets tight where several deadlines need the same system and the same team in the same quarter. Three such bundles are due before mid-2027.
October 2026 to October 2027
Market communication and EDM wave
Mitteilung 56, WiM Gas 2.0 and the MiSpeL ruling all land on 1 October 2026. Mitteilung 57 then replaces UTILTS with API web services, in April or October 2027. Going live on one version and starting the project for the next fall into the same weeks.
Team: Market communication, EDM, IS-U operations
Shared systems: Market communication gateway (EDIFACT, AS4, API), EDM / MDM, SAP IS-U / S/4HANA Utilities
Both 90 percent rollout quotas, the target for §14a control and remote reading of heat meters all fall due at year end. TR-03109-6 version 2.0 follows with the next recertification. Every one of them pulls on the same installers, the same gateway administration system and the same control box deliveries.
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)
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.
Grid development scenarios 2027: end of the consultation
Distribution grid operators and municipal utilities can comment on the electricity and gas/hydrogen drafts. The assumptions frame the grid development plan.
Electricity grid operatoraffectedCan comment on load, generation and storage assumptions in the electricity scenario framework until 28 September.Typically affected: Regulatory management, controlling
Gas grid operatoraffectedCan comment on the gas and hydrogen scenario framework that shapes how distribution grids are converted.Typically affected: Regulatory management, controlling
25 AHB and MIG versions covering 13 EDIFACT message types, AS4 profile 1.2 and the AS4 transport rules 2.6 become binding. Test plan, exception handling and fallback scenarios need to be in place.
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
MiSpeL: ruling on market integration of storage and charging points
The Federal Network Agency plans to publish the ruling with a demarcation option and a flat-rate option for storage and charging points in mixed use. It sets how volumes are separated for EEG support and levy privileges.
Applicability: Concerns sites with storage or charging points that mix grid power and self-generated power. Exact duties are known only once the ruling is published.
Electricity grid operatorcheck applicabilityOnce published, checks which metering setups, demarcation formulas and billing steps apply to storage in its grid.Typically affected: EDM / MDM, Grid usage and customer billing
Default metering point operatorcheck applicabilityClarifies which extra 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
Digitalised metering switch processes for gas, new message formats.
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
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.
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
Grid expansion plan under section 14d EnWG: first filing
Distribution system operators with 100,000 or more customers submit their first grid expansion plan to the Federal Network Agency, then every two years by 31 October. Smaller operators are covered only if they curtailed more than 3 percent of wind or solar output in each of the two previous years.
Applicability: Only for distribution system operators with 100,000 or more customers. Smaller operators only if more than 3 percent of possible wind or solar output was curtailed in each of the two previous years.
Electricity grid operatorcheck applicabilityChecks customer count and curtailment share; if covered, submits the plan with congestion analysis and measures to the BNetzA.Typically affected: Grid planning, GIS, load flow, Regulatory management, controlling
EU AI Act: labelling duty extends to AI already in use
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.
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-widecheck 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
AgNeS: framework ruling on electricity grid charges
Time-variable charges, capacity prices and feed-in charges are set; follow-up rulings 2027, effect from 2029.
Electricity grid operatoraffectedPlans billing and tariff systems for time-variable charges, capacity prices and feed-in charges from 2029.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.Typically affected: Grid usage and customer billing
Heat suppliers retrofit or replace meters installed before 5 October 2021 that cannot be read remotely (FFVAV). Building owners do the same for heat and hot water meters and heat cost allocators (Heating Costs Ordinance).
Applicability: The FFVAV applies to heat suppliers, the Heating Costs Ordinance to building owners. Metering operators under the MsbG are not addressed.
Heat network operatorrole obligationRetrofits or replaces heat meters installed before 5 October 2021 that cannot be read remotely, by year end.Typically affected: Field service and work orders, EDM / MDM
Company-widecheck 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
Under the four-stage approach of Technical Study 2.0, working control with core processes for first use cases is due by the end of 2026. This is a target, not a statutory MsbG deadline.
Electricity grid operatorcheck applicabilityBuilds processes to send control commands to §14a devices through the metering operator.Typically affected: Grid control system / SCADA, Market communication gateway (EDIFACT, AS4, API)
Default metering point operatorcheck applicabilitySets up control via smart meter gateway and control box for first §14a use cases; the date is a target, not a statutory deadline.Typically affected: Gateway administration and CLS management, Market communication gateway (EDIFACT, AS4, API)
Smart meter rollout: 90 percent of the installation cases since February 2025
By the end of 2026 default metering point operators must have completed at least 90 percent of the metering points that have fallen due since 25 February 2025. The Bundesnetzagentur collects progress twice a year and has been running supervisory proceedings against laggards since March 2026.
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
WPG §32: decarbonisation roadmap for heat networks
Operators of existing heat networks submit the roadmap: 30 percent renewable by 2030, 80 percent by 2040.
Applicability: Heat networks under 1 km and networks with a BEW transformation plan are exempt. The pending WPG amendment would only give 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
Smart meter rollout: 90 percent of new generation capacity up to 100 kilowatts
By the end of 2026 default metering point operators must have equipped at least 90 percent of the generation capacity up to 100 kilowatts that came online between 25 February 2025 and 30 September 2026. The yardstick is installed capacity, not the number of metering points.
Electricity grid operatoraffectedSupplies plant master data from grid connection and the market master data register so the metering operator knows the cases.Typically affected: SAP IS-U / S/4HANA Utilities
Default metering point operatorrole obligationEquips generation up to 100 kW so that 90 percent of capacity commissioned from February 2025 to September 2026 is covered.Typically affected: Gateway administration and CLS management, Field service and work orders
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.
Gas grid operatoraffectedCalculates revenue caps for the fifth gas regulatory period from 2028 with the rate that is set.Typically affected: Regulatory management, controlling
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.
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)
Grid package: system-serving connection capacity instead of maximum output
The right to a grid connection no longer covers the maximum generation output. Grid operators are to prioritise connection projects by planning maturity and grid benefit and to show available capacity on grid maps every month. The electronic enquiry procedure from 135 kilowatts only arrives in 2028 under the draft.
Electricity grid operatorcheck applicabilityPrepares to prioritise connection requests by project maturity and grid benefit; the bill may still change in parliament.Typically affected: Customer and grid connection portal, Grid planning, GIS, load flow
New and re-certification under v2.0 with ISMS and pentest requirements; v1.0 runs in parallel until end of 2028.
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
At the start of the calendar year the Bundesnetzagentur publishes the name, address and website of the fallback metering operator responsible for each federal state, together with the operators that declared readiness. The basis is the monitoring data under section 35 EnWG.
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
Energy sharing: practical start with the BNetzA platform
Network operators jointly build a nationwide web platform under Section 20b EnWG that also registers energy sharing agreements. The Federal Network Agency sets the date; until then energy sharing runs through the service model.
Electricity grid operatorrole obligationTakes part in building and running the joint platform under Section 20b EnWG; the Federal Network Agency sets the date.Typically affected: Customer and grid connection portal, Market communication gateway (EDIFACT, AS4, API)
Suppliercheck applicabilityChecks whether energy sharing offers have to be registered on the platform once it is live.Typically affected: Customer and grid connection portal
MaKo format release, notice no. 57: UTILTS is replaced
UTILTS is fully replaced by API web services; metering periods, switching times and load curves move into new structures. Anyone processing UTILTS today needs an API connection by then.
Applicability: 1 April 2027 applies in principle; the EDI@Energy project group proposes going live on 1 October 2027.
Electricity grid operatorrole obligationReplaces UTILTS messages with API web services for metering time, switching time and calculation formula definitions.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
Default metering point operatorrole obligationReceives metering and switching time definitions via API instead of UTILTS and adjusts device configuration.Typically affected: Market communication gateway (EDIFACT, AS4, API), Gateway administration and CLS management, EDM / MDM
Supplierrole obligationConnects to the API web services if metering times or load curves currently arrive via UTILTS.Typically affected: Market communication gateway (EDIFACT, AS4, API)
AI in critical infrastructure and grid operations falls under Annex III; the BNetzA becomes market surveillance authority.
Electricity grid operatorcheck applicabilityChecks AI in grid control and control systems for high-risk classification under Annex III.Typically affected: Grid control system / SCADA, AI systems and chatbots
Company-widecheck applicabilityChecks whether AI systems act as safety components in grid operation or in HR and prepares the high-risk obligations.Typically affected: AI systems and chatbots, ISMS and security operations
After the framework ruling at the end of 2026, the Bundesnetzagentur sets the detail in 2027, including time variable charges and capacity prices. Distribution system operators plan billing and systems against these follow-up rulings.
Electricity grid operatoraffectedAligns billing and systems with the follow-up rulings on time-variable charges and capacity prices.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
Extended maintenance until 2030 at a surcharge. Migrations to S/4HANA Utilities take 18 to 36 months.
Applicability: Only affects companies running SAP ECC or IS-U. The date follows from SAP's maintenance strategy, not from law.
Company-wideaffectedPlans the move from SAP IS-U to S/4HANA Utilities or contracts extended maintenance until 2030.Typically affected: SAP IS-U / S/4HANA Utilities
New incentive regulation under the NEST rulings of December 2025, then three-year periods.
Gas grid operatorrole obligationEnters the fifth gas regulatory period with the new methodology and three-year periods.Typically affected: Regulatory management, controlling
From 1 June 2028 energy sharing must also work across adjacent balancing areas. According to the Federal Network Agency's Notice No. 73, the supplier based service model covers this too, with no further implementation by network operators.
Electricity grid operatorcheck applicabilityChecks coordination needs with the adjacent network operator; per the Federal Network Agency the service model suffices here too.Typically affected: Market communication gateway (EDIFACT, AS4, API)
Suppliercheck applicabilityChecks whether to offer energy sharing across adjacent balancing areas as a service.Typically affected: Grid usage and customer billing
WPG: heat plans for all municipalities under 100,000 inhabitants
After the large cities, all remaining municipalities must submit their heat planning; utilities provide the data basis.
Applicability: The planning duty lies with municipalities of 100,000 inhabitants or fewer; network operators contribute data.
Gas grid operatoraffectedAligns gas network areas and conversion paths with municipal heat planning.Typically affected: Grid planning, GIS, load flow
Heat network operatoraffectedProvides the municipality with data on network, generation and expansion plans for heat planning.Typically affected: Grid planning, GIS, load flow
Under the introduction scenario, market partners adapt their systems to the MaBiS hub by 1 July 2028. From 1 January 2029 the hub is filled with master and movement data.
Applicability: Date from the industry roll-out scenario; the Federal Network Agency has not yet fixed it in proceeding BK6-24-210.
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)
BSIG §39: first evidence for critical installations
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.
Applicability: Only for operators of critical facilities under the BSIG.
Company-widecheck applicabilityPrepares audit, inspection or certification if facilities count as critical; the BSI sets the date.Typically affected: ISMS and security operations
From 2029 grid-oriented control based on grid state data applies; preventive control ends.
Electricity grid operatorrole obligationMoves legacy devices under preventive control to grid-oriented control based on grid state data by the end of 2028.Typically affected: Grid control system / SCADA
Default metering point operatoraffectedProvides control box and gateway connection so grid-oriented control works from 2029.Typically affected: Gateway administration and CLS management, Field service and work orders
Smart meter rollout: 90 percent of the 2027 to 2028 installation cases
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.
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
StromNEV expires on 31 December 2028; the BNetzA rulings replace the ordinance.
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
New electricity incentive regulation with quality elements on digitalisation and energy transition capability.
Electricity grid operatorrole obligationEnters the fifth electricity regulatory period with quality elements on digitalisation and the energy transition.Typically affected: Regulatory management, controlling
Central electricity balance group settlement is scheduled to go live on 1 October 2029 under the introduction scenario. Block 1 of the ruling (BK6-24-210-1) was open for comment until 17 November 2025; block 2 on balance group settlement follows.
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
Smart meter rollout: 90 percent of the 2029 to 2030 installation cases
Third interim mark 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.
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
Smart meter rollout: 90 percent of all mandatory cases
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.
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
Gas WACC: end of the consultation on the rate of return
Gas distribution grid operators can comment on the draft decision on the flat-rate return on capital. The 3.76 percent rate carries the revenue caps from 2028.
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
EU AI Act: classification and transparency obligations
AI systems must be classified, transparency obligations apply. High-risk requirements follow in stages.
Applicability: Duties depend on the role: providers carry most obligations, deployers mainly transparency, oversight and AI literacy.
Company-widecheck applicabilityInventories all AI systems in use, assigns risk class and provider or deployer role, and applies the transparency duties.Typically affected: AI systems and chatbots
KI-MIG: the Bundesnetzagentur becomes market surveillance authority
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.
Company-wideaffectedAligns AI documentation and evidence with the Federal Network Agency as the competent market surveillance authority.Typically affected: AI systems and chatbots
Standard metering contracts for default metering operators
BK6-24-125: MSB-RV, MSV-AN and MSV-LF are binding for default metering point operators.
Default metering point operatorrole obligationConcludes metering contracts with connection users and suppliers on the standard MSV-AN and MSV-LF templates.Typically affected: SAP IS-U / S/4HANA Utilities, Customer and grid connection portal
SupplieraffectedSigns the standard MSV-LF metering contract with the default metering operator.Typically affected: SAP IS-U / S/4HANA Utilities
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.
Electricity grid operatorcheck applicabilityChecks whether the service model works in its grid area; under Notice No. 73 no further implementation duties apply.Typically affected: Market communication gateway (EDIFACT, AS4, API)
Suppliercheck applicabilityDecides whether to offer energy sharing as a service and, if so, settles allocation, balancing and residual supply by contract.Typically affected: Grid usage and customer billing, EDM / MDM
New supplier switch processes for gas, UTILMD Gas 1.1.
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
Physical resilience of critical facilities: registration with BBK and BSI, resilience plans. The original registration deadline was dropped; the ordinance will set the new one.
Applicability: Applies to operators of critical facilities. Thresholds and the registration deadline follow from the ordinance under the act.
Company-widecheck 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
24-hour supplier switch: full obligation, electricity
Star-shaped switch process via the MaLo ID; extension to gas and hydrogen still open.
Electricity grid operatorrole obligationConfirms registrations and deregistrations within the 24-hour cycle and keeps MaLo ID master data current.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities, EDM / MDM
Default metering point operatoraffectedDelivers meter readings and master data fast enough for the switch to complete within 24 hours.Typically affected: Market communication gateway (EDIFACT, AS4, API), EDM / MDM
Supplierrole obligationCompletes supplier switches via the MaLo ID within 24 hours on every working day.Typically affected: Market communication gateway (EDIFACT, AS4, API), SAP IS-U / S/4HANA Utilities
Applies without a transition period: registration, risk management, reporting within 24 and 72 hours, management liability.
Applicability: Applies to important and essential entities under the BSIG. Sector, headcount, turnover, balance sheet total and critical facility status decide.
Company-widecheck 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
Thirty minutes on your market role and your next deadline: which processes, systems and data hang off it, and in what order it can be solved. If you want, a one-page implementation map afterwards. Whether an obligation applies to your company is for your legal counsel to settle, not this call.