Under the regulator’s draft, a battery keeps 20 years free of grid fees only if its investment decision comes before 1 January 2027.

The 20 year exemption from grid fees, § 118 (6) EnWG in force

A battery built after 2008 and first commissioned by 4 August 2029 pays no grid fees on the power it draws to store, for 20 years from commissioning. The exemption covers only the power the battery takes from a grid and later feeds back into that same grid.

Sources: Rödl (law firm), 19 February 2025 secondary source; pv magazine, guest article by Green BESS, 2 September 2026 secondary source. The law: § 118 EnWG.

The regulator’s first plan, January 2026 dropped

On 16 January 2026 the Bundesnetzagentur proposed ending the exemption before 4 August 2029, on the view that a full exemption cannot be squared with EU law. Developers objected that they had invested on the strength of the law. In May 2026 the regulator changed course and kept the exemption for batteries already under way, as the rules below set out.

Sources: Fieldfisher (law firm), 8 June 2026 secondary source; pv magazine, 30 January 2026 secondary source.

The regulator’s position of May 2026: a charge per kW at the generators’ level in consultation

Batteries will pay a moderate yearly charge per kW of connection, at the level generators will pay, and nothing per MWh. The regulator expects the generators’ charge to start at about €4–7 per kW a year, which for a 100 MW battery is about €0.4m to €0.7m a year (our arithmetic). Charging for existing batteries begins only once their exemption runs out.

Sources: Bundesnetzagentur, press release on the grid fee reform (AgNes), 27 May 2026; Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft determination: a new grid fee system from 1 January 2029 (AgNes, item 1.2) draft

The draft replaces today’s grid fee rules for every grid user from 1 January 2029. Everything in the rules marked draft below can still change before the regulator adopts it. Would take effect 1 January 2029.

Source: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft: the charge for a battery with its own connection (item 10.1) draft

A battery with its own grid connection pays a yearly charge on its contracted connection capacity in kW, at the same level as the national feed in charge for generators. Would take effect 1 January 2029.

Source: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft: how the national feed in charge is set (items 9.2 and 9.3) draft

The four transmission companies set one national charge per kW each calendar year and publish it by 15 October for the year after. It adds a basic part of €0.50 for every MWh fed in to half of their costs for balancing energy and for grid losses, spreads the total over the capacity it is charged on, and averages the actual figures of the previous five years. Would take effect 1 January 2029.

Source: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft: a battery that shares a connection with another plant (item 10.2) draft

A battery behind the same connection as a solar farm, a wind farm or a factory is charged together with that plant, under one charge. Would take effect 1 January 2029.

Source: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft: which batteries keep the exemption (item 17.5) draft

A battery keeps the full 20 years if its final investment decision comes before the determination is announced, which the draft sets for 1 January 2027, and it is commissioned by 4 August 2029. The developer must prove the decision to the grid company by 31 March 2027. A battery outside these conditions comes under the new charge per kW from 1 January 2029. Would take effect 1 January 2027.

Sources: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes); pv magazine, guest article by Green BESS, 2 September 2026 secondary source; Fieldfisher (law firm), 8 June 2026 secondary source.

Draft: what counts as a final investment decision (item 2, number 1) draft

Binding orders for components that cover at least half of the investment, under contracts the developer cannot leave without a large financial loss. Would take effect 1 January 2027.

Source: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes).

Draft: grid fees that vary by time and place (items 12.2 and 12.3) draft

Grid companies would bill batteries a fee that varies by time and place, starting no earlier than 1 January 2030 and by 1 January 2033 at the latest. It applies only once a separate determination sets its design at least two years ahead. Would take effect 1 January 2030.

Sources: Bundesnetzagentur, draft determination GBK-25-01-1#3 (AgNes); Bundesnetzagentur, press release on the grid fee reform (AgNes), 27 May 2026.

Timetable for the final determination awaiting decision

Comments on the draft closed on 18 September 2026, and the regulator still plans to adopt the determination in 2026.

Source: Bundesnetzagentur, AgNes procedure page, 21 September 2026.

The construction cost contribution (Baukostenzuschuss, BKZ), upheld by the Federal Court of Justice court ruling

A grid company may charge a battery a one off contribution towards upstream grid capacity, worked out from the grid’s price per kW. Germany’s Federal Court of Justice (BGH) upheld this on 15 July 2025, and the regulator expects it to be charged above low voltage. Decided 15 July 2025.

Source: Bundesnetzagentur, questions on storage and the BKZ. The law: BGH, EnVR 1/24.

The BKZ is due in full, and a flexible connection can lower it regulator’s guidance

The regulator says a battery pays the BKZ in full. A grid company may lower it when the battery accepts a flexible connection agreement, under which the grid company can cap its import or export.

Source: Bundesnetzagentur, questions on storage and the BKZ.

The BKZ for a transmission connection in 2026 in force

A battery connecting to the transmission grid in 2026 pays a one off €96.91 per kW at extra high voltage, or €113.15 per kW at the transformer level down to high voltage, before any regional reduction. The price is the five year average of the transmission price per kW, times the capacity ordered, whatever the type of load. For 100 MW that is about €9.7m or €11.3m (our arithmetic). In effect from 1 January 2026.

Sources: Four transmission companies, price sheet 2026, 5 December 2025; 50Hertz, price sheet 2026, 8 December 2025.

Five levels of BKZ by place on the transmission grid regulator’s guidance

The regulator’s position paper, which binds no one directly, sets out five levels of BKZ according to how a new connection point affects the transmission grid. In its own example, 600 MW pays about €60m at the full rate and about €12m at 20%. Contributions agreed for projects concluded up to 2024, or for 2025, stay valid. In effect from 20 November 2024.

Sources: Bundesnetzagentur, press release on the transmission BKZ, 20 November 2024; 50Hertz, price sheet 2026, 8 December 2025.

Bill: a BKZ for plants under the renewables law (§ 17 EEG, draft) draft

The grid connection bill would let grid companies charge a reasonable BKZ to plants connecting under the renewables law, once the regulator sets rules for it. This would matter for sites that pair a battery with solar or wind (our reading).

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

The transmission companies’ maturity procedure (Reifegradverfahren): round one in use

Batteries and large loads seeking a transmission connection now apply in fixed rounds and are ranked by how ready they are. Round one opened on 1 April 2026 and closed on 30 June 2026. Answers are due by 30 November 2026, offers must be accepted by 31 December 2026, and capacity left unclaimed is offered once more in January 2027. In use since 1 April 2026.

Source: Four transmission companies, maturity procedure, version 1.2, 16 June 2026.

Round one: the fee and the deposit in use

Each application costs €50,000, and half is refunded if it fails the entry checks. Accepting an offer needs a deposit of €1,500 per MW within a month, which is set against the BKZ once the project is built and is lost only if the project fails for reasons on the developer’s side. For 100 MW the deposit is €150,000 (our arithmetic). In use since 1 April 2026.

Source: Four transmission companies, maturity procedure concept, 5 February 2026.

Round one: how projects are ranked in use

Where a connection point is oversubscribed, projects score on land and permits (30%), the technical design (30%), the developer’s strength and equipment orders (30%) and the benefit to the grid (10%), from up to 11 points before weighting. Ties go to the earlier application, then to a need tied to an existing site, then to a lottery. In use since 1 April 2026.

Source: Four transmission companies, maturity procedure, version 1.2, 16 June 2026.

The queue behind the procedure in use

By 30 September 2025, battery requests for a connection to the four transmission companies had reached about 211 GW. 50Hertz alone reports connection requests of well over 100 GW and about 200 battery applications.

Sources: Four transmission companies, maturity procedure concept, 5 February 2026; 50Hertz, policy brief on large batteries.

Flexible connection agreements, § 17 (2b) EnWG in force

A grid company may connect a battery on terms that let it cap the battery’s import and export. The agreement must set the cap, when and for how long it applies, the technical rules for keeping to it, and who is liable. The law places no duty on grid companies to offer one. In effect from February 2025.

Sources: Bundesnetzagentur, grid connection page; Gleiss Lutz (law firm), 26 June 2026 secondary source. The law: § 17 EnWG.

Renewables have no right to connect ahead of a battery, § 17 (2a) EnWG in force

A wind or solar farm cannot use its legal right to an early connection to push a battery back in the queue.

Source: 50Hertz, policy brief on large batteries. The law: § 17 EnWG.

The transmission companies ask for compulsory flexible connections and quotas for batteries proposal

The four transmission companies want the law to require batteries to sign flexible connection agreements, and to set aside fixed shares of connection capacity for batteries and electrolysers.

Source: Four transmission companies, position paper on connections, 5 February 2026.

Northern distribution grid companies propose readiness proof for batteries proposal

Distribution grid companies in northern Germany, through their association VNEW, want developers to prove land, finance and permits before capacity is held for a battery, as the transmission companies have done since April 2026. No start date was given.

Source: pv magazine, 14 August 2026 secondary source.

The grid connection bill (Netzanschlusspaket) draft

The bill lets grid companies rank connection requests and asks them for more transparency and digital processes. The cabinet adopted it on 29 July 2026, and it is before the Bundestag as Drucksache 21/7866. The Bundestag held the first reading on 24 September 2026, the Bundesrat gave its opinion the next day, the government replied on 30 September 2026, and the economy committee heard experts on 7 October 2026. The Bundestag had not voted on the bill by 16 October 2026.

Sources: Federal Ministry for Economic Affairs and Energy, bill page, 12 August 2026; Bundestag, Drucksache 21/7866 (government bill), 7 September 2026; Bundestag, Drucksache 21/8299 (Bundesrat opinion and reply), 30 September 2026; Bundestag, hearing on the bill, 7 October 2026.

Bill: maps of available connection capacity, § 17c (1) EnWG draft

Grid companies would publish, on a map updated each month, the available connection capacity at the substations that step extra high voltage down to high voltage, and high voltage down to medium. The map would show developers where capacity exists.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: an online connection enquiry for 135 kW and above, § 17c (2) EnWG draft

From 1 January 2028 distribution grid companies would let anyone ask online, without commitment, where a connection of 135 kW or more could go. Would take effect 1 January 2028.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: a battery at an existing connection point, § 17 (2a) EnWG draft

A grid company could no longer refuse a battery at an existing connection point for lack of capacity, provided the site’s maximum import and export stay as they are, for example under a flexible connection agreement. This would ease adding batteries to existing solar or wind sites.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: one connection procedure for the transmission companies, § 17a EnWG draft

The transmission companies would submit a common connection procedure to the regulator by 1 January 2027. Where capacity is shown to be short, they could make a connection conditional on a flexible connection agreement approved by the regulator, unless the developer pays to remove the bottleneck. Would take effect 1 January 2027.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: ranking connection requests, § 17b EnWG draft

Transmission companies could rank requests using criteria such as the security of the power system, the build out targets in law, the grid planning scenarios and whether a load is tied to its site. Distribution grid companies could adopt the same rules.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: holding distribution capacity for a project, § 17f EnWG draft

Capacity held for a project would be time limited and tied to its progress, and distribution grid companies could charge a reasonable fee for holding it.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Bill: cutting connection capacity left unused, § 17 (1a) EnWG draft

If a site has not used its contracted capacity, or not in full, for more than five years, the grid company could reduce it, with 12 months’ notice.

Source: Bundestag, Drucksache 21/7866 (government bill), 7 September 2026.

Batteries allowed outside built up areas, § 35 (1) numbers 11 and 12 BauGB in force

Outside built up areas a battery counts as privileged on either of two routes. Under number 11 it is linked in place and function to an existing renewable plant. Under number 12 it stands alone, is at least 4 MW, and lies within 200 m of the plot of a substation stepping extra high voltage down to high, or high down to medium, or of a power plant of 50 MW or more, working or closed; all such batteries together may cover no more than 0.5% of the municipality and 50,000 m². Privileged means it can be permitted unless public interests stand against it. It still needs a permit that checks fire safety, nature, emissions and the grid connection. In effect from 23 December 2025.

Sources: Gleiss Lutz (law firm), 10 December 2025 secondary source; Rödl (law firm), 7 January 2026 secondary source; CMS (law firm), slides for the Ost-Ausschuss, 17 March 2026 secondary source. The law: § 35 BauGB.

Energy storage is in the overriding public interest, § 11c EnWG in force

Building and running a plant that stores electricity is by law in the overriding public interest and serves public health and safety.

Sources: energiezukunft, opinion article, 10 July 2025 secondary source; CMS (law firm), slides for the Ost-Ausschuss, 17 March 2026 secondary source. The law: § 11c EnWG.

Planning law bill: an exclusion of the first 100 m was dropped draft

The ministry’s first draft of the planning law reform would have taken the first 100 m, measured from the plot boundary, out of the battery privilege. According to a developer’s statement, the version the cabinet adopted no longer contains it.

Source: Statkraft, statement on the planning law bill, June 2026 secondary source.

Electricity tax: a registered battery counts as part of the grid, § 5 (4) StromStG in force

A battery registered in the market master data register (Marktstammdatenregister), in which suppliers store power and from which they feed it back into a supply grid, counts as part of that grid. Electricity tax is then not charged on the power it stores and returns. Customs still sees a risk of double taxation in some storage set ups, so each case needs checking.

Sources: Bundestag, Drucksache 21/2753 (finance committee report), 12 November 2025; Rödl (law firm), 28 July 2026 secondary source. The law: § 5 StromStG.

The electricity tax rate, § 3 StromStG in force

Where the tax is due, the standard rate is €20.50 per MWh. Manufacturing and farming businesses get €20 of it back, which leaves them at the EU minimum.

Source: Bundestag, Drucksache 21/2753 (finance committee report), 12 November 2025. The law: § 3 StromStG.

Levies on charging power, § 21 EnFG in force

The combined heat and power levy (KWKG-Umlage) and the offshore grid levy fall away on the power a battery draws, to the extent it feeds the same amount back into the grid in the same calendar year. The battery pays them only on the difference. Power lost inside the battery is also free of them.

Source: Rödl (law firm), 19 February 2025 secondary source. The law: § 21 EnFG.

Innovation tenders: the battery stores only the paired plant’s power, § 13 InnAusV in force

A battery in a combination that wins an innovation tender may store only the power of the plant it is paired with, so it cannot charge from the grid to trade.

Source: pv magazine, 3 July 2025 secondary source. The law: § 13 InnAusV.

Innovation tenders: the battery’s minimum size in force

The battery must have at least 25% of the combination’s installed power and must store at least two hours at that power, confirmed each year.

Source: GUTcert (environmental verifier), product sheet secondary source. The law: § 13 InnAusV.

Innovation tenders: no payment while prices are negative in force

No market premium is paid on power fed in while the exchange price is negative, which rewards using the battery to move output into hours with a positive price (our reading).

Source: pv magazine, 3 July 2025 secondary source.

The round of 1 September 2026: ceiling and registration result

The ceiling was 7.13 cents per kWh for 475 MW. Solar plants and batteries had to be registered as projects in the market master data register by the bid date.

Sources: Bundesnetzagentur, innovation tender of 1 September 2026, 29 September 2026; Bundesnetzagentur, innovation tenders page.

The round of 1 September 2026: results result

All 480 MW awarded, from 32 bids, went to combinations of solar and batteries, at 4.50 to 5.40 cents per kWh and 5.14 cents on average, down from 5.34 cents in the round before. Published 29 September 2026.

Source: Bundesnetzagentur, press release on the tender results, 29 September 2026.

Reserve capacity in 15 minute blocks, decision BK6-25-212 decided, not yet in force

The regulator approved letting providers bid capacity for automatic and manual frequency restoration reserve (aFRR and mFRR) in 15 minute blocks alongside today’s four hour blocks. Shorter blocks let a battery offer capacity for the hours it can cover (our reading). The bids are combined into four hour bids for the auction. The decision set 12 months to implement, with four weeks’ notice of the start. The transmission companies aimed for the second half of 2026. An aggregator’s update to its article of 13 August 2026 says the start has slipped and no new date is set.

Sources: Bundesnetzagentur, decision BK6-25-212, 28 October 2025; Four transmission companies, white paper on balancing reserve, 28 November 2025; Entelios (aggregator), 13 August 2026 secondary source.

Reserve energy already settles in 15 minute products in force

The energy side of aFRR has used 15 minute products since 22 June 2022, when Germany joined the European aFRR platform PICASSO. The 2026 change concerns the capacity side. In effect from 22 June 2022.

Source: regelleistung.net, history of reserve procurement.

A market for inertia (Momentanreserve), from 22 January 2026 in force

The transmission companies pay plants, batteries among them, a fixed yearly price for holding inertia, valid from 22 January 2026 to 21 January 2028. The premium product, at 90% availability, pays €805 to €888.50 per MWs a year. A battery counts as available only when it is synchronised with the grid for the whole quarter hour. A price secured in that period holds for the contract’s whole term, planned at two to ten years. In effect from 22 January 2026.

Sources: Four transmission companies, inertia procurement page; pv magazine, 23 January 2026 secondary source.

Storing renewable and grid power in one battery (MiSpeL) in force

A battery may mix grid power and renewable power and still receive renewable support on the stored renewable share, and it pays correspondingly fewer levies and grid fees on the power it draws from the grid. Grid and meter operators have until the end of September 2027 to put this in place, and until then a battery can use it with their agreement. The flat rate option still needs approval under EU state aid rules. In effect from 1 October 2026.

Source: Bundesnetzagentur, press release on MiSpeL, 1 October 2026.