Authors

Dr. Markus Böhme, LL.M. (Nottingham)

Partner

Duesseldorf

Dr. Christian Ertel

Salary Partner

Munich

Fiammetta Kremer

Associate

Munich

Authors

Dr. Markus Böhme, LL.M. (Nottingham)

Partner

Duesseldorf

Dr. Christian Ertel

Salary Partner

Munich

Fiammetta Kremer

Associate

Munich

25 September 2025

Publication series – 5 of 66 Insights

Federal Network Agency discussion paper on reforming grid fees for industry and commerce

Quick read

The Federal Network Agency has published a discussion paper (link) on the future structure of electricity network charges for industry and commerce. The aim is to replace the current band load regulation, which expires at the end of 2028, with a new system that provides incentives for more flexible consumption behaviour.

Background

Under Section 19(2) of the Electricity Network Access Ordinance (StromNEV), large electricity consumers currently receive network fee discounts if they consume a constant load for more than 7,000 hours per year. This so-called band load regulation is considered legally contestable, often prevents an economic response to price developments and expires on 31 December 2028 at the latest. A new regulation is therefore urgently needed.

Proposed regulations

The Federal Network Agency is putting forward three possible approaches for discussion:

Market-oriented consumption behaviour – discounts for companies that align their consumption more closely with electricity price signals.
Flexibility utilisation – discounts for the use of storage facilities or other measures for grid-friendly load control.
Direct controllability – discounts if grid operators can access loads directly when necessary.

All proposals have in common that they require a specific consideration, must not significantly impair production processes and should be supplemented by transitional arrangements.

Status of the process and outlook

The process of revising the regulations began in July 2024 and was integrated into the General Grid Fee System (AgNeS) in May 2025 to better coordinate general grid fees and special regulations for industry (further information here).

30 September 2025: Industry workshop on the discussion paper
21 October 2025: End of the consultation period

Comments can be submitted by email to gbk@bnetza.de with the subject line “GBK-25-01-1#3; Name of your institution” until the end of the consultation period. The Federal Network Agency will publish the comments received on its website.

Conclusion

The planned changes are of considerable practical importance for industrial and commercial customers with high electricity consumption. In particular, the future structure of the discounts will depend largely on consumption behaviour and the flexibility offered.

If you have any questions about the consultation or its possible impact on your company, we will be happy to advise you.

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Federal Network Agency discussion paper on reforming grid fees for industry and commerce

Background

Proposed regulations

Status of the process and outlook

Conclusion

In this series

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